Review applications require a clear error on record to succeed, as they do not allow re-examination of evidence or prior conclusions unless an apparent error occurs.

ORDER :

MANINDRA MOHAN SHRIVASTAVA, C.J.,

All these applications seek review of the common order dated 27.4.2023 passed by a Division Bench of this Court in W.P.Nos.7735, 11186 and 11408 of 2023.

2. The factual backdrop necessitous for consideration of these review applications is as under:

2.1. The writ petitions were filed challenging the order passed by the Commissioner of Land Administration dated 14.02.2023, in and by which, it was held that: (i) the claim of one A.R.Sridharan, in respect of the subject land, is not justifiable and based on fraudulent documents; (ii) the claim of Tripower Enterprises (Private) Limited to grant patta cannot be acceded to, since its sale certificate under the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 remains unregistered; and (iii) the claim of one V.A.K Engineering Private Limited was rejected, as they also had a Memorandum of Understanding with the said A.R.Sridharan in respect of the land in its possession and the matter is pending arbitration between the two parties. While rejecting the claim made by the three parties, referred supra, the Commissioner of Land Administration held that, pending further declaration by any appropriate court of law regarding title, the said lands in T.S.No.3 and 138 of Block No.I, Ward No.E at Adambakkam Village, Alandur Taluk, Chennai District, are to be treated as Anadheenam and to be maintained as such in the revenue records.

2.2. The Division Bench of this Court, vide the order which is sought to be reviewed, after threadbare analysis of the facts and the earlier decisions governing the parties and upon pondering over the submissions made on either side, rendered the following findings qua each party to the said order:

In re A.R.Sridharan:

“5.1. ... Therefore, when the very basis of the title, on the face of it and on the basis of the documents produced before the authority are ex facie fraudulent and when the authority has taken into consideration the very many details including the findings in the earlier Writ Petitions, the proceedings of the Assistant Settlement Officer and the Settlement Officer, field location, physical possession etc., and when the authority has concluded that A.R.Sridharan has no right or title in respect of the land in question and has only produced false documents and his claim is fraudulent, we are unable to come to a contrary conclusion and therefore, the claim of A.R.Sridharan is bound to fail.”

In re V.A.K.Engineering Pvt Ltd:

“5.2. ... As rightly contended by Mr.N.R.Elango, learned Senior Counsel appearing on behalf of M/s.V.A.K Engineering Pvt. Ltd., it can be seen that merely because the said Company, which is claiming independent title and which had claimed independent title in all the earlier proceedings, had entered into a without prejudice compromise to buy peace by paying money to A.R.Sridharan so that he will relinquish all his claims and that the consequential arbitration, arising out of the said Memorandum of Understanding, will not come in the way of the said Company claiming patta. As a matter of fact, once the Commissioner of Land Administration had found the entire claim of A.R.Sridharan itself is fraudulent, then the said benefit has to be granted to the said M/s.V.A.K Engineering Pvt. Ltd and as such, we find that the conclusion reached by the Commissioner of Land Administration, in respect of M/s.V.A.K Engineering Pvt. Ltd., as erroneous.”

In re Tripower Enterprises (Private) Limited:

“5.3. ... Thus, it can be seen that it is not mandatory for the sale certificate to be registered and it is enough if it is shown in the books under Section 89 of the Registration Act, 1908 . The said exercise has been factually carried out and learned Additional Advocate General would also admit the same.

5.4. A copy of the encumbrance certificate, issued