In a brief but significant order circulated on Tuesday, the Supreme Court refused to reopen a dispute between the Union of India and Virendra Amrutbhai Patel, holding that the government cannot seek review merely because another Bench later took a different legal view. The order, passed by Justices B.V. Nagarathna and Augustine George Masih, leaned heavily on a prior three-judge ruling and avoided what one judge informally called “unnecessary revisiting of settled issues.”
Background
The dispute traces back to a Special Leave Petition (SLP) filed in 2024, which the Union of India later attempted to review. The government argued that a later three-judge Bench judgment-Union of India v. Ganpati Dealcom Pvt. Ltd.-had given liberty to parties affected by earlier decisions to reopen their matters. Essentially, they wanted to use that later ruling as a ground to re-enter the courtroom.
However, the Bench today did not agree. The judges pointed out a simple but critical rule: under the Code of Civil Procedure, a review cannot be sought just because a later judgment changes the legal interpretation. This principle, tucked quietly inside the “Explanation” to Order 47 Rule 1, became the focal point of today’s order.
Court’s Observations
During their consideration, the judges directly addressed the conflict between two earlier Supreme Court decisions-Ganpati Dealcom on the one hand and KL Rathi Steels Ltd. on the other. The latter, delivered in May 2024 by a co-equal three-judge Bench, had clearly said that a subsequent change in interpretation by another Bench cannot be a reason for reopening concluded cases.
In today’s order, the Bench stated that it was “unable to agree” with the observations in Ganpati Dealcom that had granted such liberty. Referring to KL Rathi Steels, the court remarked that the earlier Bench had taken a consistent view aligned with the Code of Civil Procedure.
“The bench observed, ‘The fact that the decision on a legal question has later been reversed is not a ground for review. The KL Rathi Steels ruling, being prior in time and equal in strength, must prevail.’”
The judges also pointed out a crucial gap: the Bench in Ganpati Dealcom had not noticed the earlier KL Rathi Steels decision at all. Because of this oversight, the present Bench said it could not rely on the later ruling to reopen cases that had already attained finality.
Decision
With this reasoning, the Supreme Court dismissed the review petition. The order is short and direct: the delay in filing was condoned, but the review itself was rejected on merits. No liberty was granted to revive the already-decided matter, and the judgment ends by formally disposing of all pending applications.
And with that, the dispute was effectively closed, leaving the government without a fresh avenue to challenge the earlier SLP dismissal.
Case Title (English): Union of India & Ors. vs. Virendra Amrutbhai Patel – Review Petition Dismissed
Court: Supreme Court of India
Bench: Justice B.V. Nagarathna & Justice Augustine George Masih
Case Type: Review Petition (Civil) arising from SLP(C) No. 8229/2024
Diary No.: 41584/2025
Date of Order: 04 November 2025
