Key Points: - The judgment discusses the scope and maintainability of a review petition under Article 137, including grounds like error apparent on the face of the record and discovery of new matter (!) (!) (!) (!) . - It clarifies that in criminal matters, review lies on an error apparent on the face of the record and is not an appeal in disguise, with caution against re-arguing merits (curative aspects and limitations) (!) (!) (!) (!) (!) . - It outlines the parameters of review in civil matters vs. criminal matters, and references Order XLVII Rule 1 of CPC, including timelines and procedures for filing, circulation, and grounds for review (!) (!) (!) (!) (!) . - The decision emphasizes that fresh material must be relevant and could not have been produced despite due diligence, and that review cannot reweigh evidence or re-argue merits, especially in respect of national security/defence judgments where the court’s limited review applies (!) (!) (!) (!) (!) . - It cites Lalita Kumari and P. Sirajuddin to delineate when preliminary inquiries and FIRs are warranted or prohibited, affecting the scope of judicial review in review petitions (!) (!) (!) (!) . - It holds that a review petition in criminal matters must show palpable error on the face of the record; mere two views or new interpretations do not suffice (!) (!) (!) (!) . - It confirms the remedy of curative petition under Order XLVIII for rehearing when review fails, per constitutional guidelines (!) (!) . - It ultimately dismisses the review petitions in the Rafael/Mudra matter, reaffirming Article 32 review constraints (!) (!) (!) .

How to determine whether a review petition is maintainable in criminal matters under Article 137 of the Constitution and Order XLVII CPC?