16.04.2026 Ct. No. 30 S.L. No. 1-5 SM RVW 69 of 2026 With IA No.: CAN 1 of 2026 M/s. Murlidhar Ratanlal Exports Limited Versus The State of West Bengal & Ors.

With RVW 84 of 2026 With IA No.: CAN 1 of 2026 CAN 2 of 2026 Congress Yadav Versus M/s. Murlidhar Ratanlal Exports Limited In WPA 2944 of 2026 M/s. Murlidhar Ratanlal Exports Limited Versus The State of West Bengal & Ors.

With RVW 70 of 2026 IA No. CAN 1 of 2026 M/s. Murlidhar Ratanlal Exports Limited Versus The State of West Bengal & Ors.

In WPA 25131 of 2024 M/s. Murlidhar Ratanlal Exports Limited & Anr.

Versus The State of West Bengal & Ors.

With RVW 71 of 2026 IA No. CAN 1 of 2026 M/s. Murlidhar Ratanlal Exports Limited Versus The State of West Bengal & Ors.

In WPA 3562 of 2026 M/s. Murlidhar Ratanlal Exports Limited Versus The State of West Bengal & Ors.

With RVW 85 of 2026 IA No. CAN 1 of 21026 CAN 2 of 2026 Shankar Chowdhury Versus M/s. Murlidhar Ratanlal Exports Limited & Ors.

Ms. Amrita Pandey Mr. Ghanshyam Pandey ……for the petitioners Mr. Bikash Shaw …….for the workman Mr. Bipin Ghosh …….for the respondent nos. 4 & 5 Mr. Susanta Pal …….for the State in RVW 69 of

2026 & RVW 71 of 2026

1. All five review applications are taken up for disposal by a common order.

2. It is submitted by the petitioners herein that a common judgment dated 19.02.2026 in WPA 2944 of 2026 along with two other writ applications was passed by this Court relying upon the judgment in Bhanu Prakash Versus Assistant Labour Commissioner & Ors. in WPA 9532(W) of 2010 dated 2nd May, 2012 as placed by the petitioner.

3. It is submitted that after the judgment in Shanti Devi @ Shanati Mishra Versus Union of India and Ors. reported in (2020) 12 SCR 279, the issue of territorial jurisdiction has been decided otherwise.

4. It is submitted by the petitioner that ground for review under Order 47 Rule 1 of CPC exists in this case. The ground is covered by the phrase “error apparent” on the face of the record, or for any other “sufficient reason”. The said phrase has been explained by the Hon‟ble Supreme Court in the case reported at BCCI versus Netaji Cricket Club & Ors.

(2005) 4 SCC 741, decided on January 10, 2005, (Paras 89, 90).

“89. Order 47 Rule 1 of the Code provides for filing an application for review. Such an application for review would be maintainable not only upon discovery of a new and important piece of evidence or when there exists an error apparent on the face of the record but also if the same is necessitated on account of some mistake or for any other sufficient reason

90. Thus, a mistake on the part of the court which would include a mistake in the nature of the undertaking may also call for a review of the order. An application for review would also be maintainable if there exists sufficient reason therefor. What would constitute sufficient reason would depend on the facts and circumstances of the case. The words “sufficient reason” in Order 47 Rule 1 of the Code are wide enough to include a misconception of fact or law by a court or even an advocate. An application for review may be necessitated by way of invoking the doctrine “actus curiae neminem gravabit.”

5. The petitioner prays for review of the said judgment and order stating that grounds for review has been clearly made out and the said order dated 19.02.2026 be reviewed in the interest of justice, there being an error apparent on the face of the record.

6. The Supreme Court in BCCI versus Netaji Cricket Club & Ors. (supra) has categorically held that a review would be maintainable not only upon discovery of new and important piece of evidence or when there exists some error apparent on the face of the record but also if the same be necessitated on account of some mistake or for any other sufficient reason (as in the present case).

7. On hearing the learned counsels for the parties and on perusal of the judgments relied upon, it appears that the judgment dated 19.02.2025 of which review has been prayed for, was passed relying upon the judgment