Article 137: Remedies by way of review jurisdiction of Supreme Court u/r Art.137  of Constitution. 

The Power of Self-Correction

Article 137 empowers the Supreme Court to review its own judgments. This is an exception to the principle of Functus Officio (once a judgment is delivered, the court's authority ends). However, this power is discretionary and heavily restricted.

1. Scope: It is NOT an Appeal

A common mistake litigants make is treating a Review Petition as a "re-hearing" of the case. The Supreme Court has clarified:

• ⛔ No Re-Appreciation of Evidence: You cannot argue the same points again hoping for a different view.
• ⛔ No "Second Thoughts": Just because a judgment is erroneous on law, it does not automatically warrant review. It must be a glaring error.
• Key Principle: "A Review is by no means an Appeal in disguise." — Parsion Devi vs. Sumitri Devi (1997)

2. The "Triple Test" for Review

In the landmark judgment of Kamlesh Verma vs. Mayawati (2013), the Supreme Court summarized the specific conditions under which Article 137 can be invoked:

3. Distinction from BNSS & CPC

Article 137 is a Constitutional power, making it distinct from statutory appeals.

*Note: Under BNSS (formerly CrPC), subordinate criminal courts generally cannot review their own judgments (except for clerical errors), but the Supreme Court CAN review its own criminal judgments under Art 137.

4. Procedure & The "Curative" Remedy

• ⚖️ Limitation: Must be filed within 30 Days of the judgment.
• ⚖️ Circulation: Unlike open court hearings, Review Petitions are usually decided by "Circulation" (Judges discuss in chambers). Open court hearing is rare (mostly in Death Penalty cases — Mohd. Arif Case).
• ⚖️ The Curative Petition: If a Review is dismissed, is it the end? No.
  In Rupa Ashok Hurra vs. Ashok Hurra (2002), the SC invented the "Curative Petition" to cure gross miscarriage of justice or violation of Natural Justice. This is the absolute final resort.