Dismissed¶40

T.G.Subramaniam v. the Secretary

Madras HC27 Oct 2025REV.APPL/201/2023

Case brief

AI extract

What is this about?

Madras High Court dismisses Review Applications Nos.201 & 202 of 2023 (decided 27.10.2025; coram M.S. Ramesh and R. Sakthivel JJ.) seeking review of order dt.12.03.2021 in W.A.Nos.2374 & 2832 of 2019; grounds of G.O.Ms.856 PWD (01.06.1977) benefits to similarly placed candidates and condonation of delay in similar cases held barred by constructive res judicata; review limited to errors apparent on face of record; Order 47 Rule 1 r/w S.114 CPC; applicants incl. T.G.Subramaniam and K.Jeevanandam; respondents incl. Secretary, RD & PR Department.

What did the court decide?

The scope of entertaining a Review Application is very limited; the Reviewing Court is justified only in correcting errors apparent on the face of the record and nothing more. ¶36

T.G.Subramaniam Vs the Secretary — Madras HC (2025) — LawSathi Research

What the court decided

AI extract

Outcome

Dismissed

¶40

Issue for consideration

Whether the Review applicants could rely on orders passed in similar circumstances touching implementation of G.O.Ms.856, PWD, dated 01.06.1977 (benefits to similarly placed candidates) as a ground to review the order in W.A.Nos.2374 and 2832 of 2019. +2 more

¶35

Court's answer

The ground regarding benefits obtained by similarly placed candidates under G.O.Ms.No.856, as well as the ground of delay, were available to the applicants when the Writ Appeals were argued.

¶39

Ratio / Principle

The scope of entertaining a Review Application is very limited; the Reviewing Court is justified only in correcting errors apparent on the face of the record and nothing more.

¶36

Key takeaways

Having failed to canvas these grounds before the Coordinate Bench, the applicants cannot now raise them; they are barred by the doctrine of constructive res judicata.ratio¶39
The Court found no reason to interfere with the order passed in W.A.Nos.2374 and 2832 of 2019 and accordingly dismissed both Review Applications.ratio¶40

Detailed headnote1 paragraphs

Madras High Court (M.S. Ramesh and R. SakthivEL, JJ.), 27.10.2025: Review Applications Nos.201 and 202 of 2023, filed under Order 47 Rule 1 CPC r/w Section 114 CPC seeking review of the order dated 12.03.2021 in W.A.Nos.2374 and 2832 of 2019, were dismissed. The applicants had relied on orders passed in similar circumstances implementing G.O.Ms.856, PWD, dated 01.06.1977 (benefits to similarly placed candidates) and challenged the ground of delay on the plea that delay was condoned in similar cases. The Court reiterated that review jurisdiction extends only to correcting errors apparent on the face of the record; since the G.O.Ms.856 and delay grounds were available when the Writ Appeals were argued but were not canvasssed before the Coordinate Bench, they could not now be raised in view of the doctrine of constructive res judicata. Finding no reason to interfere with the Writ Appeal order, both Review Applications were dismissed.

¶1

Review Applications Nos.201 and 202 of 2023

¶2

IN THE HIGH COURT OF JUDICATURE AT MADRAS

¶3

DATED : 27.10.2025

¶4

CORAM :

¶5

THE HONOURABLE MR. JUSTICE M.S. RAMESH

¶6

and

¶7

THE HONOURABLE MR. JUSTICE R.SAKTHIVEL

¶8

Review Applications No.201 and 202 of 2023

1.T.G.Subramaniam

2.U.Bagavathy

3.K.Chandra Sekaran

4.R.Elumalai

¶13

5.G.Subramani

¶14

6.A.M.Palanisamy

¶15

7.R.Deenadayalan 8.P.M.Sampath

¶16

... Applicants in Rev.Appln.201/2023

¶17

K.Jeevanandam

¶18

... Applicant in Rev.Appln.202/2023

¶19

Vs.

¶20

1.The Secretary to Government Rural Development & Panchayat Raj Department Fort St. George Chennai 600 009

¶21

2.Director

¶22

Rural Development and Panchayat Department Panakal Building Saidapet

¶23

Page 1 of 6

¶24

https://www.mhc.tn.gov.in/judis

¶25

Review Applications Nos.201 and 202 of 2023

¶26

Chennai 600 015

¶27

3.The Principal Accountant General 361, Anna Salai Chennai 600 018 4.The District Collector Tiruvallur 5.C.Jayaraman 6.A.T.Chandran 7.K.Perumal 8.R.Jaya ... Respondents in Rev.Appln.201/2023 1.The Secretary to Government Rural Development & Panchayat Raj Department Fort St. George Chennai 600 009 2.Director Rural Development and Panchayat Department Panakal Building Saidapet Chennai 600 015 3.The Principal Accountant General 361, Anna Salai Chennai 600 018 4.The District Collector Vellore ... Respondents in Rev.Appln.202/2023 Common Prayer: Review Applications are filed under Order 47 Rule 1 of

¶28

Page 2 of 6

¶29

https://www.mhc.tn.gov.in/judis

¶30

Review Applications Nos.201 and 202 of 2023

¶31

CPC r/w under Section 114 of CPC), praying to review the order dated 12.03.2021 made in W.A.Nos.2374 and 2832 of 2019 on the file of this Court.

¶32

F or Applicants : Mr.G.Murugendran For Respondents : Mr.G.Ameedius Government Advocate - R1, 2&4

¶33

COMMON ORDER

¶34

M.S.RAMESH, J. and R.SAKTHIVEL, J.

¶35

In the grounds raised by the Review applicants, a reference has been made to orders passed in similar circumstances, touching upon implementation of G.O.Ms.856, PWD, dated 01.06.1977. This apart, the ground of delay, pointed out in the judgment passed in the Writ Appeals, has also been challenged before us, claiming that in similar cases, the delay has been condoned.

¶36

2.It is a settled proposition of law that the scope of entertaining a Review Application is very limited, and the Reviewing Court will be justified in correcting certain errors that are apparent on the face of Page 3 of 6

¶37

https://www.mhc.tn.gov.in/judis

¶38

Review Applications Nos.201 and 202 of 2023

¶39

record and nothing more. The grounds raised by the applicants, with regard to the benefits obtained by similarly placed candidates under G.O.Ms.No.856, were very much available to the applicants when the Writ Appeals were argued, so also the ground of delay. When that being so, having failed to canvass these grounds before the Coordinate Bench, it would now not be permissible for the applicants to raise the same grounds in view of doctrine of constructive res judicata .

¶40

3.We do not find any reason to interfere with the order passed in W.A.Nos.2374 and 2832 of 2019. Therefore, both the Review Applications stand dismissed.

¶41

kas

¶42

Index: Yes / No Neutral Citation Speaking / Non Speaking

¶43

Page 4 of 6

¶44

https://www.mhc.tn.gov.in/judis

¶45

Review Applications Nos.201 and 202 of 2023

¶46

To.

¶47

1.The Secretary to Government Rural Development & Panchayat Raj Department Fort St. George Chennai 600 009 2.Director Rural Development and Panchayat Department Panakal Building Saidapet Chennai 600 015 3.The Principal Accountant General 361, Anna Salai Chennai 600 018 4.The District Collector Tiruvallur 5.The District Collector Vellore

¶48

Page 5 of 6

¶49

https://www.mhc.tn.gov.in/judis

¶50

Review Applications Nos.201 and 202 of 2023

¶51

M.S.RAMESH, J. and R.SAKTHIVEL, J.

¶52

kas

¶53

Review Applications No.201 and 202 of 2023