The Bombay High Court dismissed a review plea filed by an LL.M. student of MNLU Chhatrapati Sambhajinagar seeking permission to appear for exams despite low attendance. The Court held review cannot act as an appeal and rejected attempts to reopen already decided issues.
The Bombay High Court has dismissed a review application filed by an LL.M. student of Maharashtra National Law University (MNLU), Chhatrapati Sambhajinagar, who had sought reconsideration of an earlier order refusing her permission to appear for the semester examinations due to insufficient attendance. The Court held that review jurisdiction cannot be used as an appellate remedy, and observed that the student was, in substance, only attempting to re-argue issues already decided in the writ proceedings.
A Division Bench comprising Justice Vibha Kankanwadi and Justice Ajit B. Kadethankar was hearing the review application filed by Ankita Jagannath Sonawale, who appeared in person. Advocate S.K. Kadam represented the respondents.
Earlier, the student had challenged the University’s decision barring her from appearing in the second semester LL.M. examination on the ground that she failed to satisfy the mandatory attendance requirement under the Maharashtra National Law University Regulations, 2020. Her writ petition was dismissed on April 30, 2026.
In her review application, the student sought broad reliefs, including reconsideration of the earlier judgment, directions to produce attendance records, CCTV footage from grievance committee proceedings, and an order for a special examination. She also alleged errors in the calculation of her attendance, discrimination in granting attendance-related benefits to other students, and failure by the University to take her medical circumstances into account.
The Bench, however, found no merit in the contentions. On the attendance issue, it noted that under the University’s regulations, 75 percent attendance is mandatory. It further observed that the University had adopted a policy for relaxation allowing students with at least 67 percent attendance, provided there was valid medical justification through a committee resolution approved by the Vice-Chancellor. The judges recorded that the applicant did not even claim to have crossed the 67 percent threshold.
The Court also noted that, even based on the student’s own calculations, her attendance could not exceed 51.12 percent, which was far below both the prescribed requirement and the relaxation benchmark. Rejecting the allegations that attendance had been miscomputed, the Bench held that the student failed to demonstrate any error apparent on the face of the record. It further stated that the applicant’s understanding of what constitutes an “error apparent on the face of the record” was fundamentally misconceived.
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The Court was also critical of allegations made against the University, faculty members, and a fellow student. It described several assertions in the review application as “absolutely reckless and irresponsible” and noted that they were unsupported by evidence. The judges also took exception to the applicant’s attempt to question a batchmate’s attendance record, and directed the Registry to mask the student’s name in court records to protect his privacy.
Rejecting the request to rely on new medical documents at the review stage, the Bench observed that a party cannot fill gaps in its case through review proceedings. It held that the materials now sought to be relied upon were already within the applicant’s knowledge at the time the writ petition was heard, and therefore could not be used as a basis for review.
Reiterating the limited scope of review jurisdiction under Order XLVII of the Code of Civil Procedure, the Bench said,
“an appeal under the disguise of review should not be entertained.”
It added that the applicant had effectively sought to re-appreciate the entire case as though the Court was sitting in appeal over its own judgment.
Accordingly, the Court dismissed the review application. It declined to impose costs, noting that the applicant was a student.
Case Title: Ankita Jagannath Sonawale v. Maharashtra National Law University Through its Registrar and Others