GURU GHASIDAS VISHWAVIDYALAYA

BILASPUR, C.G.
(A CENTRAL UNIVERSITY)

Department of law

Session 2023-24

CIVIL PROCEDURE CODE

Topic – REFERENCE, REVIEW AND
REVISION

Guided by: Submitted by:

SUDHANSHU SHEKHAR BISEN SHIVA SONI
(Asst. Professor) Roll No. 21100158
B.COM. LL.B. (6th Sem.)
 ACKNOWLEDGEMENT

I would like to express my deepest and earnest gratitude

to, SUDHANSHU SHEKHAR BISEN faculty for
CIVIL PROCEDURE CODE, School of Law, for
giving me this opportunity to do a project on such a
valuable case law topic of REFRENCE, REVIEW
AND REVISION. I am grateful for the assistance,
guidance, and support that were extended during the
course of excellent research. I am also thankful to the
college administration for providing the resources
necessary for the research work. I thank my parents and
friends their moral support and love throughout my
research work and project preparation. Above all I
thank the God almighty for blessing me with the health
and the vitality to complete this project.

SHIVA SONI
Roll No. 21100158
B.COM. LL.B. (6th Sem.)
 CERTIFICATE

I am glad to submit this project report on REFRENCE,

REVIEW AND REVISION, a part of my academic
assignment. The project is based on Research
methodology and further discusses the interview
method. I think this would be significant for academic
purposes as well as prove information to all the readers.
Here though I declare that this paper is an original piece
of research and the borrowed text and ideas have been
duly acknowledged.

SHIVA SONI
Roll No. 21100158
B.COM. LL.B. (6th Sem.)
 DECLARATION

I, SHIVA SONI, B.Com. LL.B. (6th Sem.) of the Guru

Ghasidas University do hereby declare that, this
project is my original work and I have not copied this
project or any part thereof from any source without
acknowledgement. I am highly indebted to the authors
of the books that I have referred in my project as well as
all the writers of all the articles and the owners of the
information taken from the website for it. It is only
because of their contribution and proper guidance of my
faculty advisor SUDHANSHU SHEKHAR BISEN that I
was able to gather light on the subject.

SHIVA SONI
Roll No. 21100158
B.COM. LL.B. (6th Sem.)
 Table of Contents

S. CONTENTS / TOPICS Page

No. No.
1. Introduction 1

2. REFRENCE 1

3. Nature, Scope, And Object of Reference 1

4. REVISION 2

5. Nature and Scope of Revision 2

6. REVIEW 3

7. Nature and Scope of Review 3

8. Conditions for Reference 4

9. Circumstances in which review lies 8

10. Review and Revision Distinguish 12

11. Conclusion 15

12. Bibliography 16
 INTRODUCTION

In India, there are three tiers Judiciary i.e. District Courts, High Courts and
hon’ble Supreme Court of India. The appeal, review and revision lies in all the
three Courts depending on which Court’s Order is being challenged. Therefor it
is necessary to know the nature and scope of all these three words and also how
they are different from each other. It is imperative to know the scope of all these
to exercise the power of reviewability against the impugned order of the
respective Court. In this paper I am going to discuss in elaborative manner the
extent and scope of “Reference, Review and Revision”.
REFERENCE
A. Nature and Scope

Section 113 of the Civil Procedure Code empowers a subordinate court to state a
case and refer the same for the opinion of the High Court. Such an opinion can
be sought when the code itself feels some doubt about a question of Law.The
word ‘Court’ wherever it occurs in the code means a Court of civil Judicature.The
reference can only be made by a Court but not by a persona designate.
A reference can only be made by a Court when there is a reasonable doubt about
a question of Law or only when it is of opinion that Act is ultra vires.
Unnecessary observations made by the High Court while disposing of the
reference having no legal effect must be treated to have been rendered infructuous
and superfluous but such power of reference is discretionary.1
B. Object and references under the proviso

The object for the provision of reference is to enable subordinate courts to obtain
in non-appealable cases the opinion of the High Court in the absence of a question
of law and thereby avoid the commission of an error which could be remedied
later on.
When all the following conditions are satisfied the Court is bound to make a
reference to the High Court under this proviso under setting out its opinion and

1
Order XLI, Rule 3 and 4 of the Civil Procedure Code

1
the release for it.

i) A question as to validity of any Act, ordinance or Regulation or any

provision therein arises in a case before the court.
ii) The Court is of the opinion that the same is invalid or inoperative.
iii) The same has not till then been declared invalid by the High Court to which
the Court is subordinate or by the Supreme Court, and
iv) The determination of the validity thereof is necessary for the disposal of
the case.

REVISION
A. Meaning

Section 115 of the Code of Civil Procedure empowers A High Court to entertain
a revision in any case decided by a subordinate Court in certain circumstances.
This jurisdiction is known as revisional jurisdiction of the High court .Revision
meaning the action of revising, especially critically or careful examination or
perusal with a view to correcting or improving.
B. Nature and Scope

In Major S.S Khanna v. Brig F.J Dillon, the Court stated “The section consists
of two parts, the first prescribes the conditions in which the jurisdiction of the
High Court arises, i.e. there is a case decided by a subordinate Court in which no
appeal lies to the High Court, the second sets out the circumstances in which no
appeal lies to the High court, the second out the circumstances in which the
Jurisdiction may be exercised.’’2
For the effective exercise of the High court’s superintending and visitorial powers
over subordinate courts, this revisional jurisdiction has been conferred by the
High Court under S.115; the powers given are clearly limited to the keeping of
subordinate courts within the bound of their jurisdiction.It is a part of general

2
Order XLI, Rule 5 of the Civil Procedure Code

2
appellate jurisdiction of the High court though the jurisdiction is strictly restricted
by the terms of S.115 investing it.Though revisional Jurisdiction is only a part of
appellate jurisdiction, it cannot be equated with full that of a full fledged appeal.

REVIEW
A. Meaning

Review means to reconsider, to look again or to re examine. In legal sense, it is a

judicial re-examination of the case by the same court and by the same Judge.
B. Nature and Scope

According to the general principle of law, once the judgment is passed the court
becomes functus officio. A power of review should not be confused with the
appellate powers which enables an appellate court to enable all errors committed
by the subordinate Court. Greater care, seriousness and restrain should be given
in review application as would not be fair to court to deal with the same case with
the same party over again and again and it would increase the backlog of the case
over the court.3
A right of review is both substantive as well as procedural. As a substantive right,
it has to be conferred by law, either expressly or by necessary implications. There
can be no inherent right of review. As a procedural provision, every Court or
tribunal can correct an inadvertent error which has crept in the order due to
procedural defect or mathematical or clerical error or by misrepresentation or
fraud of a party to the proceeding, which can be corrected asex debito justitae. If
a review is not maintainable I, it cannot be allowed by describing such application
as an ‘’clarification’’ or ‘’modification’’

REFERENCE
The underlying object for the provision for reference is to enable subordinate

3
Order XLI, Rule 6 (2) of the Civil Procedure Code

3
courts to obtain in non appealable cases the opinion of the High Court in the
absence of a question of law and thereby avoid the commission of an error which
could not be remedied later on. Such provision also ensures that the validity of a
legislative provision (Act, Ordinance or Regulation) should be interpreted and
decided by the highest court in the State.
Section 77 of the Civil Procedure code, empowers a subordinate court to state
a case and refer the same for the opinion of the High Court. Such an opinion can
be sought when the court itself feels some doubt about a question of law. The
High Court may make such order thereon as it thinks fit. Such opinion can be
sought by a court when the court trying a suit, appeal or execution proceedings
entertains reasonable doubt about a question of law.
Conditions for Reference
The right of reference, however, is subject to the conditions prescribed by Order
XLI Rule 1 and, unless they are fulfilled, the High Court cannot entertain a
reference from a subordinate court. The rule requires the following conditions to
be satisfied to enable a subordinate court to make a reference:
i) There must be a pending suit or appeal in which the decree is not subject
to appeal or a pending proceeding in execution of such decree;
ii) A question of law or usage having the force of law must arise in the course
of such suit, appeal or proceeding; and
iii) The court trying the suit or appeal or executing the decree must entertain a
reasonable doubt on such question.

Questions of law on which a subordinate court may entertain a doubt may be

divided into two classes:
i) Those which relate to the validity of any Act, Ordinance or Regulation; and
ii) Other questions.

In the latter case, the reference is optional, but in the former case it is obligatory
if the following conditions are fulfilled:

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 i) It is necessary to decide such question in order to dispose of the case;
ii) The subordinate court is of the view that the impugned Act, Ordinance or
Regulation is ultra vires; and
iii) There is no Reference, review and revision under CPC- Prepared by
Mwakisiki Mwakisiki Edwards determination either by the Supreme Court
or by the High Court to which such court is subordinate that such Act,
Ordinance or Regulation is ultra vires.

The court making a reference may either stay the proceedings or pass a decree
contingent upon the decision of the High Court on the point referred, such decree
or order not being executable until the receipt of a copy of the judgment of the
High Court upon the reference4.
The High Court after hearing the parties, if they desire to be heard, shall decide
the points and transmit a copy of its judgment to the court which made the
reference. Such court shall then dispose of the case in conformity with the
decision of the High Court. The costs consequent on a reference for the decision
of the High Court shall be costs in the case5.
Power of the High Court
The High Court may on reference return the case for amendment, or alter, cancel
or set aside any decree or order which the court making the reference has passed
or made, and make such order as it thinks fit6 . This provision shows that when
the High Court hears a reference it acts like a court of appeal.

Power to refer to High Court questions as to jurisdiction

At any time before judgment a court in which a suit has been instituted may refer
to the High Court questions as to jurisdiction where it entertains doubts whether
the suit is cognizable by a court of small causes or not7 . On receiving the record

4
Order XLI, Rule 2 of the Civil Procedure Code
5
Order XLI, Rule 3 and 4 of the Civil Procedure Code
6
Order XLI, Rule 5 of the Civil Procedure Code
7
Order XLI, Rule 6 (1) of the Civil Procedure Code

5
and statement, the High Court may order the court either to proceed with the suit
or to return the plaint for presentation to such other court as it may in its order
declare to be competent to take cognizance of the suit8.

REVIEW
According to the general principle of law, once the judgment is passed the court
becomes functus officio. A power of review should not be confused with the
appellate powers which enables an appellate court to enable all errors committed
by the subordinate Court. Greater care, seriousness and restrain should be given
in review application as would not be fair to court to deal with the same case with
the same party over again and again and it would increase the backlog of the case
over the court.
A right of review is both substantive as well as procedural. As a substantive right,
it has to be conferred by law, either expressly or by necessary implications. There
can be no inherent right of review. As a procedural provision, every Court or
tribunal can correct an inadvertent error which has crept in the order due to
procedural defect or mathematical or clerical error or by misrepresentation or
fraud of a party to the proceeding, which can be corrected asex debito justitae. If
a review is not maintainable I, it cannot be allowed by describing such application
as an ‘’clarification’’ or ‘’modification’’.
Basically as per the decision in Attilio v Mbowe9 , where Georges C.J. said:
"Review involves correction of an error which was either apparent on the face of
the record or had been clear because of subsequently discovered circumstances."
And Mnzavas J. noted in Mbolve Mhurula v. Sanva Mbolye M10 that: "the
Principle underlying a review is that the Court would not have acted as it had if
all the circumstances had been known."
The provisions of the law governing REVIEW, are set out under Order XL II of

8
Order XLI, Rule 6 (2) of the Civil Procedure Code
9
[1970] H.C.D. 3
10
[1974) L.R.T. N. 48

6
the Civil Procedure Code Cap. 33 R.E. 2002 and Rule 1 that Order, provides as
follows:
1. Any person considering himself aggrieved a) by a decree or order from
which an appeal is allowed, but from which no appeal has been preferred;
or (b) by a decree or order from which no appeal is allowed, and who, from
the discovery of new and important matter or evidence which, after the
exercise of due diligence, was not within his knowledge or could not be
produced by how at the time when the decree was passed or order made,
or on account of some mistake or error apparent on the face of the record,
or for any other sufficient reason, desires to obtain a review of the decree
passed or order made against him may apply for a review of judgment of
the court which passed the decree or made the order.
2. A party who is not appealing from the decree or order may apply for a
review of judgment notwithstanding the pendency of an appeal by same
other party except where the ground of such appeal is common to the
applicant and the appellant, or when, being respondent, he an present to the
appellate court the case on which he applied for review".

From the above provision it can be rightly said there are three grounds on which
an application for review may be made. The first ground is, from the discovery
of new and important matter or Evidence. The second ground is, "on account
of some mistake or error apparent on the face of the record' and the third
ground, is "for any other sufficient reason".
As far as it could be ascertained, the court for the first time stumbled on review
in the case of Felix Bwogi v. Registrar of Buildings11, an application to rectify
a judgment of the court which had been based on a wrong record. A document
withdrawn at the trial before the High Court had somehow found its way into the
record of appeal and judgment had proceeded on the basis of that document. The

11
Civil Application No. 26 of 1989 (unreported)

7
court granted the application and reversed its earlier decision. In doing so,
however, the court considered itself to be acting pursuant to Rule 40(1) of the
Court of Appeal Rules which provides for the correction of clerical or
arithmetical mistakes in judgments or errors arising therein from accidental slips
or omissions.
It was not realized that the exercise amounted to a review of the court's decision.
The misconception was realized and the court's inherent powers of review were
concretized in Transport Equipment Ltd v. Devram P. Valambhia12, where a
Full Bench consisting of seven justices ostensibly sat to consider whether the
court had inherent power to review its decisions.
It was observed that the court's powers derived from statute but inherent
jurisdiction was by its nature not a creature of statute although it may sometimes
be embodied in a statute. It is power which is necessary for the proper and
complete administration of justice and one which is resident in all courts of
superior jurisdiction and essential to their existence.
CIRCUMSTANCES IN WHICH REVIEW LIES
Cases in which no appeal lies
A decree or order from which no appeal lies is open to review. Hence, an
application for review against a decree passed by a Court of Small Causes is
competent. On the same principle, where an appeal is dismissed on the ground
that it was incompetent or was time-barred, the provisions of review would get
attracted.
Cases in which appeal lies but not preferred
A review petition is also maintainable in cases where appeal is provided but no
such appeal is preferred by the aggrieved party. The fact that an order is subject
to appeal is no ground to reject an application for review. An application for
review can be presented so long as no appeal is preferred against the order.

12
Civil Application No. 18 of 1993(unreported)

8
Where, however, an appeal is already instituted before making an application for
review, the court cannot entertain such application. Likewise, where an appeal is
preferred and is disposed of, no review would lie against the decision of the lower
court. But if an application for review is preferred first and then an appeal is filed,
the jurisdiction of the court to deal with and decide the review petition is not
affected.
The words "from which an appeal is allowed" should be constructed liberally
keeping in mind the underlying object of the provision that before making a
review application, no superior court has been moved for getting the same relief,
so that for one and the same relief two parallel proceedings before two forums
are not taken. If review is granted before disposal of the appeal, the decree or
order ceases to exist.
Conversely before an application of review is heard, such petition becomes
infructuous and is liable to be dismissed. The principle applies to dismissal of
Special Leave Petition by the Supreme Court. But if a Special Leave Petition is
merely filed and is not decided, the bar would not apply.
To whom application of Review be made
Order XLII Rule 2 of the Civil Procedure Code reads thus: An application for
review of a decree or order of a court, other than the High Court, upon some
ground other than the discovery of such new and important matter or evidence as
is referred to in rule 1 or the existence of a clerical or arithmetical mistake or error
apparent on the face of the decree, shall be made only to the magistrate who
passed the decree or made the order sought to be reviewed; but any such
application may, if the magistrate who passed the decree or made the order has
ordered notice to issue under paragraph (b) of the proviso to sub-rule (2) of rule
4.
Form of application for review
Order XLII Rule 3 of the Civil Procedure Code, The provisions as to the form of
preferring appeal shall apply, mutatis mutandis, to applications for review.

9
Granting or rejecting an application for Review
In the case where the court feels that there is no ground for a review, the court is
entitled to reject the application. This is according to Order XLII Rule 4 (1) of
the Civil Procedure Code which states: "When it appears to the Court that there
is no sufficient ground for a review, it shall reject the application".
However if a good grounds have been shown by the applicant court shall grant
the same. This is in accordance to the provision of Order XLII Rule 4 (2) of the
Civil Procedure Code. Further the same provision sets some conditions in
entertaining the application for review.
These conditions are; (a) no such application shall be granted without previous
notice to the opposite party, to enable him to appear and be heard in support of
the decree or order, a review of which is applied for; (b) and no such application
shall be granted on the ground of discovery of new matter or evidence which the
applicant alleges was not within his knowledge, or could be adduced by him when
the decree or order was passed or made, without strict proof of such allegation.

REVISION
Revision is the power of higher courts to call for and examine the record of an
inferior court for the purpose of satisfying as to the correctness, legality or
propriety of any finding, sentence or order recorded, imposed or passed by such
inferior court and as to the regularity of any proceedings of such court.
It is not a substantive right of the parties but is a mere privilege granted to them.
The higher court's interference while exercising revisional powers must be
limited to correction of errors of jurisdiction or non-compliance of any statutory
provisions of law and interference must not be on merits.
The civil procedure code has some provision regarding revision. Section 79 of
the Civil Procedure Code mentions revisional powers of Higher Courts. It states
that the higher court may call for the record of any case which has been decided
by any subordinate court and to which no appeal lies.

10
Act 25 of 2002, the Written Laws (Miscellaneous Amendments) (No. 3)
amended Section 79 of the Civil Procedure Code as follows:- (i) by designating
the old Section 79 as 79 (1); and (ii) by creating a new subsection (2) which
provides as follows:-
"Notwithstanding the provisions of subsection (1), no application for revision
shall lie or be made in respect of any preliminary or interlocutory decision or
order of the Court unless such decision or order has the effect of finally
determining the suit."
Actually, Act 25 of 2002 effected amendments to the Appellate Jurisdiction Act,
1979; the Civil Procedure Code and the Magistrates Courts Act which disallowed
appeals and applications for revision on preliminary and interlocutory decisions
of the High Court to the Court of Appeal and those of the Resident Magistrate
Court and the District Magistrates Court to the High Court.
Undoubtedly, Revision is exercised if the subordinate court has exercised a
jurisdiction not vested in it by law or failed to exercise a jurisdiction so vested or
has acted illegally or with material irregularity. The above position was
emphasized in the case of ABDAL HASSAN v. MOHAMED AHMED13 (per
Katiti J.), It was stated that “The High Court revisional power under Section 79
(1) of the Civil Procedure Code of 1966 are limited to cases where no appeal lies
and issue such as whether the Subordinate Court has exercised jurisdiction not
vested, if vested, whether it has failed to exercise the same or has acted illegally
or with material irregularity."
Again in MWANAHAWA MUYA VS MWANAIDIMARO14, “(ii) In the
proper case, the High Court can invoke its powers of revision in a grant to letters
of Administration by the District Court. Powers of Revision are however usually
exercised by the High Court suo moto when exercising its supervisory powers
over subordinate courts.» (iii) It is wrong, indeed improper, for the High Court to

13
[1989] TLR 181
14
[1992] TLR 78 (C.A)

11
resort to its revisional Powers where ( as it was in this case) there are specific
issues calling for determination by the court."
In ZABLON PANGALAMEZA VS JOACHIM KIWARAKA &
ANOTHER15, "(iii) Unlike Section 79 (c) of the Civil Procedure Code, Section
44 (l)of the Magistrates Courts Act goes beyond jurisdictional issues and covers
all situations where it appears that there has been an error material to the merit of
the case involving injustice."
Section 79 of the Civil Procedure Code the High Court may only exercise its
revisional jurisdiction under the Civil Procedure Code in the following
circumstances:" (a) The Subordinate Court has exercised a jurisdiction not rested
in it by law; or(b) The subordinate Court have failed to exercise a jurisdiction
rested in it, or(c) The Subordinate Court have acted in the exercise of its
jurisdiction illegally or with material irregularity;(d) But of course with another
condition that no appeal has thereto".
REVIEW AND REVISION DISTINGUISHED
Essentially, a review and a revision are two different matters. A revision, under
the Civil Procedure Code envisages a correction of errors; apparent on the face
of the record. But, the correction higher court not the same court.
A review on the other hand, is also a correction of apparent on the face of the
record. But, this is done by the same court that gave the earlier judgment. This is
what the author Aaarwala says, in The Civil Procedure Code - 3rd edition, on
reviews:
"It is well settled that the power of review is not an inherent power of a judicial
officer, but such a right can only be conferred by statute".
"A review is practically the hearing of an appeal by the same' officer who decided
the case and a right to review is not an inherent power."
"One judge cannot set aside an order made by another Judge of the same court,

15
[1987] TLR 140 [CA]

12
although it may be wrong.". "A Court is not entitled to review its order without
notice to the other side". 'Discovery of fresh evidence is not ground for review on
second appeal." "An error of law is not sufficient reason for granting review."
"Any other sufficient reason must be taken rejusdem generis with the clauses
preceding.'
"The person who wants review should at leas prove strictly the diligence he
claims, to have exercised and also that the matter or evidence which he wishes to
have access to is, if not absolutely conclusive, nearly conclusive of the matter.
The application for review cannot succeed on the ground of discovery of new and
important matter or evidence which after exercise of due diligence, could not be
produced at the time of passing the decree."
"The ground for review must be something which existed on the date of the
decision of decree and not subsequent to the date of the decree." "A court has
jurisdiction to decide wrongly." "In correct interpretation of the law is not an
apparent mistake on the face of the record:
"An error of law is not sufficient reason for granting review." "A party ought not
to be allowed in review to raise a case which was never raised at the trial and on
which no evidence was adduced." "Grounds for review must be in existence on
the date of the decree."
"When appeal is preferred, review is out of question and the party's procedure is
to apply to the appellate court to admit additional evidence."
"When an application for review is ordered, the judgment sought to be reviewed
is not set aside, but only held in suspense until the case has been re-heard."
"A ground of review must be something which existed at the time of the decree.
The rule does not authorize the review of a judgment which was right when made,
but is shown to be erroneous by the happening of a subsequent event. So, when a
judgment is based on a decision of Court, but subsequently it is set aside by a
Superior Court, that fact is not a good ground for the granting of review"
"A review maybe granted, even on a ground not argued at the original hearing of

13
the suit, in order to rectify some mistake or error apparent on the face of the
record. Where the mistake is apparent on the face of the record, then, irrespective
of whether the forward appeared to be outside the ambit of . the rule."
Incidentally, the words "any other sufficient reason" got defined in the Indian
case of Chhajju Ram v. Neki and Others 1922 3 Lah 1 27 to mean: "a reason
sufficient on grounds at least analogous to those specified immediately
previously:
Revisions, as I said earlier, are different matters. They are, as I said, instigated by
higher courts, in most cases. A better illustration would be, in the words of our
brothers Mrosso J. (as he then was) in Awaki Shauri v Christopher Gwandu &
Another Civil Revision No. 9 of 98 Arusha High Court Registry, where he said:
"It is true that the High Court can decide to revise lower Court proceedings,
decree or order after reading periodic civil returns or upon receiving an informal
complaint either by word of mouth, by a letter or even as a result of radio or
newspaper information It is then that the Court, of its own motion, orders revision
proceedings to be opened."
And, indeed , as pointed out by Mchome J. in Israel Mwakalabeya v. Ibrahim
Mwaiiamba Miscellaneous Civil Application No. 21/91 Mbeya HC:
"the right to invoke the Courts powers of revision is not an alternative to
appealing. Where the order complained against is appellable, the court will not
use its revisional powers, for the right to appeal is a remedy open to the aggrieved
party. Even where the time for appealing has expired, a party has the remedy of
applying to appeal out of time."

14
 Conclusion
According to the Code of Civil Procedure, 1908, when a party is aggrieved by the
decree passed by the court, he can approach the superior court by way of appeal,
against the decree passed by the trial court. Generally, under appeal, the whole
dispute is re-heard by the appellate court. But in cases where there are
technical/procedurals errors, the aggrieved party need not take the pain of
approaching the higher court for going through the hassle of contesting another
suit which is in the form of appeal. For the same purpose, the Code of Civil
procedure has introduced the concepts called Reference, Review and Revision
under Sections 113, 114 & 115 respectively. An application for Reference,
Review and Revision can be filed in the concerned courts as provided by the
Code and the proceedings under these applications do not deal with merits (facts
or evidence) of the case.16 They are solely based on technical grounds. Reference
is made by a subordinate court to the High court where there is a doubt regarding
the question of law. The review is made by the same court which has passed the
decree to rectify the mistake or error on the record. Revision application is made
to only High court when the decree passed by subordinate court is not in
accordance with appropriate jurisdictions

16
https://www.indiafilings.com/learn/reference-review-revision-code-of-civil-procedure/

15
 BIBLIOGRAPHY

Books:
C.K. TAKWANI, Civil Procedure with Limitation Act,1963 564 (Eastern
Book Company,7th edition 2013

Websites
https://www.indiafilings.com/learn/reference-review-revision-code-of-civil-
procedure/
http://www.legalservicesindia.com/article/2580/Reference,-Revision-And-
Review.html
file:///C:/Users/Dell/Downloads/ORDER_XLI_II_REFERENCE_REVIEW
_AND_REVISI.pdf

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