Punjab National Bank and Ors. Vs C.J. Arora

$~37

IN THE HIGH COURT OF DELHI AT NEW DELHI

- LPA 733/2025

PUNJAB NATIONAL BANK AND ORS .....Appellants Through: Mr. Saurabh Mishra, Senior Advocate with Mr. Bitu Kumar Singh, Mr. Prakash Sharma, Mr. Rajeev Ranjan, Mr. Shiv Pratap Singh and Mr. Prakash Kumar Singh, Advocates.

¶5

versus C.J. ARORA .....Respondent Through: Dr. Ashwani Bhardwaj, Advocate.

¶6

CORAM: HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE TEJAS KARIA O R D E R % 10.04.2026

¶7

CM APPL. 23169/2026(Exemption)

¶8

Exemption is allowed, subject to all just exceptions.

¶9

The Application stands disposed of.

¶10

CM APPL. 23168/2026

¶11

The present Application is filed on behalf of the Respondent seeking condonation of delay of 18 days in filing the accompanying Review Petition. 4. For the reasons stated in the Application, the same is allowed. The delay of 18 days in filing the accompanying Review Petition is hereby condoned.

¶12

The Application stands disposed of.

¶13

REVIEW PET. 158/2026

¶14

The present Review Petition is filed by the Respondent in LPA No. 733/2025 (“ LPA ”) under Order XLVII Rule 1 read with Section 151 of

¶15

This is a digitally signed order.

¶16

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 13/04/2026 at 12:00:23

¶17

Code of Civil Procedure, 1908 seeking review of the judgment dated 13.02.2026 (“ Judgment ”) passed in the LPA.

¶18

The learned Counsel for the Respondent submitted that when writ petition being W.P.(C) 6696/2003 (“ Writ Petition ”) was heard before the learned Single Judge, the hearing was limited to only one aspect of whether the de novo inquiry could have been initiated as recorded in paragraph no. 8 of the order dated 09.12.2024, which was challenged in the LPA. Paragraph No. 8 of the order impugned in the LPA reads as under:

¶19

“ 8. Heard learned counsels for the parties on the limited aspect whether the de novo inquiry could have been initiated pursuant to the order of the Disciplinary Authority dated 28.12.1992. ”

¶20

The learned Counsel for the Respondent submitted that in view of the limited scope of enquiry by the learned Single Judge, the other submissions made on behalf of the Respondent in the Writ Petition were not considered. It was further submitted that the Respondent, who was the Petitioner in the Writ Petition, had raised various other issues before the learned Single Judge with regard to non-compliance of principles of natural justice and the flaws in the inquiry such as opportunity to cross-examine the witnesses were declined to the Respondent, the defence of the Respondent was closed without any opportunity and disproportionality of punishment.

¶21

The learned Counsel for the Respondent submitted that in view of the Judgment passed in the LPA, whereby the LPA filed by the Appellants was allowed and the judgment and order dated 09.12.2024 passed by the learned Single Judge in the Writ Petition was set aside, the other issues raised by the Respondent before the learned Single Judge never got adjudicated.

¶22

This is a digitally signed order.

¶23

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 13/04/2026 at 12:00:23

¶24

In view of the above, it was submitted on behalf of the Respondent that the Writ Petition be remanded back to the learned Single Judge for determining the remaining issues raised by the Respondent in the Writ Petition, which were not considered as evident from paragraph no. 8 of the judgment and order dated 09.12.2024 passed in the Writ Petition.

¶25

We have heard the learned Counsel for the Respondent. 12. The main ground for filing the present Review Petition by the Respondent is that the learned Single Judge while considering the Writ Petition observed that the same was decided on the limited aspect of whether the de novo inquiry could have been initiated pursuant to the order of the Disciplinary Authority dated 28.12.1992. Although the judgment and order dated 09.12.2024 passed in the Writ Petition restricted the enquiry in the Writ Petition to the said aspect, the Respondent, who was the Petitioner in the Writ Petition, did not challenge the same and accepted the final decision by the learned Single Judge.

¶26

It is only once the LPA was allowed and the judgment and order dated 09.12.2024 passed by the learned Single Judge in the Writ Petition was set aside, the present Review Petition has been filed by the Respondent. 14. The stand taken by the Respondent cannot be accepted as there is no error apparent on the face of the record that requires review of the Judgment passed in the LPA. The Judgment has considered all arguments as raised in the LPA and, therefore, no case is made out for reviewing the same on the ground that the scope of enquiry before the learned Single Judge was limited to only one aspect and the matter should be remanded back to the learned Single Judge for reconsideration on other aspects. The Respondent having accepted the judgment and order dated 09.12.2024 passed in the Writ

¶27

This is a digitally signed order.

¶28

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 13/04/2026 at 12:00:23

¶29

Petition filed by the Respondent, is not entitled to seek review of the Judgment passed in the LPA, despite there being no error apparent on the face of the record.

¶30

It is a settled law that the scope for reviewing any judgment is very limited and the Respondent has no opportunity to re-argue the case by filing the Review Petition. It is also a settled law that an error apparent on the face of the record must be such an error, which may strike one on a mere looking at the record and would not require any long-drawn process of reasoning. Further, a review petition has a limited purpose and it cannot be an appeal in disguise. It is well established that the power of review can be exercised for correction of a mistake, but not to substitute a view.

¶31

The contentions raised in the present Review Petition by the Respondent are in nature of re-arguing the case. The Respondent has not been able to show any error apparent on the face of the record in the Judgment. Reliance placed on observation made in the judgment and order dated 09.12.2024 that the Counsel for the Parties were heard on the limited aspect is not helpful to the Respondent as there is no error pointed out in the Judgment passed in the LPA.

¶32

In view of the above, no case is made out for reviewing the Judgment Accordingly, the present Review Petition is dismissed. There shall be no order as to costs.

¶33

DEVENDRA KUMAR UPADHYAYA, CJ

¶34

TEJAS KARIA, J

¶35

APRIL 10, 2026 ap

¶36

This is a digitally signed order.

¶37

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 13/04/2026 at 12:00:23

Punjab National Bank and Ors. v. C.J. Arora

Case brief

What is this about?

What did the court decide?

Punjab National Bank and Ors. v. C.J. Arora

Case brief

What is this about?

What did the court decide?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

Similar cases

Arvind Kejriwal Vs Directorate of Enforcement

Shannu Baghel Vs Bar Council of India

Brij Bihari Giri Vs Municipal Corporation of Delhi and Others

Methodex Systems Pvt. Ltd. Vs Terracis Technologies Ltd. & Anr.

Jigyansh Gadi Vs University of Delhi and Ors.

Hazrat Khwaja Garib Nawaz Welfare Association Vs Government of National Capital Territory of Delhi