B.Lakshmi Narayanan v. The Secretary to Government
Case brief
What is this about?
Madras High Court, Rev.Appl.Nos. 222-228 of 2025, decided 04-11-2025, Coram M.S. Ramesh J. (author) and R. Sakthivel J. Review applications by police personnel (B. Lakshmi Narayanan; V.S. Ebenezer) against State respondents (Secretary to Government, Home Police-II Department; Director General of Police; Chairman, Tamil Nadu Uniform Services Recruitment Board) seeking review under Order 41 Rules 1 & 2 r/w Section 114 CPC of orders dated 23.04.2018 in W.A.Nos. 1489 and 1545 of 2016. Sole ground: Supreme Court precedents allegedly overlooked by Co-ordinate Bench. Court held: ground available only in appeal, barred by constructive res judicata, no proof precedents were cited below, no error apparent on face; review applications dismissed.
What did the court decide?
The ground that certain precedents were inadvertently not brought before the Co-ordinate Bench when final orders were passed in the Writ Appeals can only be a ground for appeal and not for review.