Single Judge Has Dismissed My Writ - Should I File LPA, Review or Go to the Supreme Court? A Remedy-Selection Guide for Patna High Court Litigants

Legally reviewed and updated: 11 September 2026

Legal research by Advocate Ankit Kumar Singh.

Direct Answer: Do Not File Review Merely Because the Writ Was Dismissed

When a learned Single Judge of Patna High Court dismisses a writ petition, the next proceeding is not automatically a Civil Review and it is not automatically an LPA either.

The correct sequence is:

FIRST — IDENTIFY THE JURISDICTION EXERCISED BY THE SINGLE JUDGE.

SECOND — CHECK WHETHER AN INTRA-COURT APPEAL IS LEGALLY AVAILABLE.

THIRD — IDENTIFY WHETHER THE COMPLAINT IS APPELLATE OR TRULY REVIEWABLE.

FOURTH — CALCULATE LPA / REVIEW / SLP LIMITATION IMMEDIATELY.

The Fast Remedy Chart

Single Judge Decision First Remedy to Examine
Ordinary Article 226 civil/public-law writ dismissed Letters Patent Appeal under Clause 10, subject to exclusions.
Pure Article 227 challenge to Civil Court judicial order dismissed LPA ordinarily barred; examine review/SLP/other available remedy.
Tribunal order challenged under Articles 226/227 Examine substance of jurisdiction; LPA cannot be decided merely from the petition's label.
Writ criminal in substance Clause 10 criminal-jurisdiction exclusion may bar LPA.
Single Judge judgment has self-evident error apparent Civil Review may be appropriate.
You merely disagree with legal interpretation/evidence appreciation Ordinarily appellate issue, not review.
LPA legally unavailable Article 136 SLP may be considered.
LPA has already been decided by Division Bench Supreme Court SLP against the relevant Division Bench order/judgment may be considered.

What Exactly Is a Letters Patent Appeal?

A Letters Patent Appeal is an intra-court appeal.

In an eligible case, a judgment of one Judge of Patna High Court can be challenged before a Division Bench of the same High Court under Clause 10 of the Letters Patent constituting the High Court of Judicature at Patna.

It is therefore fundamentally different from Civil Review.

LPA: AN APPELLATE COURT EXAMINES THE SINGLE JUDGE'S DECISION.

REVIEW: THE COURT CORRECTS ONLY A NARROW REVIEWABLE DEFECT IN ITS OWN DECISION.

Current 2026 Example: State of Bihar v. Nand Kishor Singh

A particularly current illustration is State of Bihar v. Nand Kishor Singh, Letters Patent Appeal No.249 of 2024, decided by Patna High Court on 31 August 2026.

The learned Single Judge had interpreted the pension scheme in favour of the writ petitioner and directed payment of additional pension from an earlier date.

The State filed an LPA under Clause 10.

The Division Bench independently examined:

  • the governing Bihar resolution;
  • the Central Government Office Memorandum;
  • statutory pension rules;
  • Supreme Court authority;
  • the interpretation adopted by the learned Single Judge.

The Division Bench disagreed with the Single Judge.

It set aside the judgment and dismissed the writ petition.

This is exactly why an LPA should not be confused with review.

The Division Bench was exercising genuine appellate jurisdiction and could correct the Single Judge's legal interpretation.

When Is an Ordinary Article 226 Writ Commonly LPA-Capable?

A conventional civil/public-law writ can include:

  • service matters;
  • appointment and recruitment;
  • pension;
  • education disputes;
  • University decisions;
  • administrative orders;
  • Government tenders;
  • blacklisting;
  • statutory-authority decisions;
  • public-law land disputes;
  • constitutional challenges.

Where the learned Single Judge adjudicates such a case in original Article 226 jurisdiction, Clause 10 LPA should ordinarily be examined before jumping directly to Supreme Court.

But even here, special statutes and specific jurisdictional bars must be checked.

The Article 227 Trap: Not Every “CWJC” Has an LPA

The most important maintainability trap is assuming:

“The case number is CWJC, therefore LPA lies.”

That is legally unsafe.

The Court examines the jurisdiction actually exercised.

The Supreme Court in Radhey Shyam v. Chhabi Nath, (2015) 5 SCC 423, clarified that judicial orders passed by Civil Courts are not amenable to certiorari under Article 226.

They may be scrutinised in the High Court's supervisory jurisdiction under Article 227.

That classification has an important consequence for intra-court appeals.

Where the Single Judge's order is purely under Article 227 against a Civil Court judicial order:

LPA IS ORDINARILY NOT MAINTAINABLE.

Jogendrasinhji: Substance Matters More Than the Caption

In Jogendrasinhji Vijaysinghji v. State of Gujarat, (2015) 9 SCC 1, the Supreme Court examined when an intra-court appeal is available from a Single Judge's writ decision.

The Court explained that maintainability may depend upon:

  • the pleadings in the writ petition;
  • the character of the impugned order;
  • the authority or tribunal involved;
  • the nature of directions issued;
  • the constitutional jurisdiction actually exercised.

Therefore:

THE HEADING “ARTICLE 226/227” DOES NOT FINALLY DETERMINE LPA MAINTAINABILITY.

Civil Court and Tribunal Are Not the Same for This Purpose

A judicial order of a Civil Court stands on a clearer footing after Radhey Shyam:

CIVIL COURT JUDICIAL ORDER → ARTICLE 227 → NO ORDINARY INTRA-COURT APPEAL.

A tribunal is different.

Orders of tribunals or statutory adjudicatory authorities can involve Article 226 jurisdiction depending upon the nature of the challenge.

Therefore do not mechanically advise:

“Tribunal order means Article 227, so there is no LPA.”

The original writ and the Single Judge judgment must be read.

Bank of India v. Union of India: Why Tribunal Cases Need Careful Classification

In Bank of India, Zonal Office, Patna Zone v. Union of India & Ors., LPA No.1424 of 2023, decided on 1 August 2024, the underlying writ challenged an Industrial Tribunal decision.

The Division Bench considered the Tribunal record and the Single Judge decision in the LPA.

The case illustrates why tribunal matters cannot be classified solely from whether the Single Judge referred to supervisory jurisdiction at some point in the judgment.

The complete nature of the original challenge must be analysed.

Criminal Writ: Clause 10 Has Another Major Exclusion

Clause 10 excludes judgments/orders made in exercise of criminal jurisdiction.

This means that a petition does not become LPA-capable merely because counsel writes:

“Article 226 of the Constitution.”

If the proceeding is criminal in substance, the intra-court appeal may remain barred.

Ram Kishan Fauji: Look at the Nature of the Proceeding and Relief

The Supreme Court in Ram Kishan Fauji v. State of Haryana, (2017) 5 SCC 533, held that the nature of the jurisdiction and the real relief sought determine whether the Single Judge was exercising criminal jurisdiction.

The litigation concerned steps leading to criminal investigation and prosecution.

The Supreme Court held that the intra-court appeal was not maintainable merely because Article 226 had been invoked.

The practical rule is:

LOOK AT THE SEED, SUBSTANCE AND CONSEQUENCE OF THE PROCEEDING.

Typical matters requiring this scrutiny include:

  • FIR challenge;
  • criminal investigation;
  • prosecution;
  • criminal-process orders;
  • quashing-related writ jurisdiction.

So When Should I File Civil Review Instead?

Review is appropriate only where the judgment suffers from a recognised review defect.

The principal categories include:

  • error apparent on the face of the record;
  • discovery of new and important material unavailable despite due diligence;
  • another recognised sufficient reason analogous to the established review jurisdiction.

A review petition is not intended to persuade the same Court:

“Please reconsider all my arguments because I still believe I should have won.”

Satyavrat Bharti: Patna High Court's Recent Review Test

In Satyavrat Bharti v. State of Bihar, Civil Review No.279 of 2024, decided on 15 July 2025, Patna High Court reiterated the narrow character of review jurisdiction.

The Court emphasised that:

  • an allegedly erroneous decision is not automatically reviewable;
  • review is not a rehearing;
  • error apparent must be self-evident;
  • a long reasoning process to establish the alleged error ordinarily takes the matter outside the narrow review jurisdiction.

This creates a practical drafting test:

IF YOUR “REVIEW GROUND” LOOKS LIKE A FULL LPA GROUND, IT IS PROBABLY AN APPEAL ARGUMENT.

Example: Review or LPA?

Example A — Better Review Case

Single Judge writes:

“The petitioner never filed the statutory appellate order.”

But Annexure P/7 is indisputably that appellate order and the judgment's conclusion demonstrably rests on its supposed absence.

A self-evident record error may justify review analysis.

Example B — Better LPA Case

Single Judge considers Annexure P/7 but interprets it against the petitioner.

The petitioner says:

“The Single Judge misunderstood its legal effect.”

That is ordinarily appellate reasoning.

If LPA is maintainable, the Division Bench is the more natural forum.

Angad Kumar Singh: Review Exists Even in Writ Jurisdiction

In Angad Kumar Singh & Ors., Civil Review Nos.16 and 43 of 2024, decided on 11 July 2025, Patna High Court discussed review jurisdiction over Article 226 judgments.

The Court recognised that CPC provisions do not apply to writ proceedings in precisely the same manner as they apply to an ordinary civil suit.

Nevertheless, the principles underlying Section 114 CPC and Order XLVII Rule 1 guide writ review jurisdiction.

Therefore:

ARTICLE 226 JUDGMENT CAN BE REVIEWED, BUT ONLY WITHIN STRICT REVIEW PRINCIPLES.

Can I File Review First and LPA Later?

Possibly in an appropriate procedural sequence, but it should never be done mechanically.

Important questions include:

  • Is LPA maintainable?
  • Is there actually a review ground?
  • What happens to limitation?
  • Has an appellate proceeding already been instituted?
  • Would the doctrine of merger become relevant after appellate adjudication?
  • What precise order will ultimately need to be challenged?

A review petition should not be used merely as a device to gain additional time for an LPA or SLP.

Limitation should be independently calculated before deciding the sequence.

When Should the Supreme Court Be Considered?

Article 136 gives the Supreme Court discretionary power to grant special leave to appeal from judgments, decrees, determinations, sentences or orders of Courts and tribunals.

An SLP can become relevant where:

  • LPA has been dismissed on merits;
  • LPA has been allowed against you;
  • LPA is legally unavailable;
  • the Single Judge order is a pure Article 227 order not intra-court appealable;
  • the proceeding is within a Clause 10 exclusion;
  • a special statute bars another intra-court appeal;
  • a review petition has been dismissed and substantial Article 136 grounds remain.

Why “Go Directly to Supreme Court” Is Not Always the Best First Advice

Article 136 is extraordinary and discretionary.

It is not an ordinary statutory appeal automatically available merely because a litigant has lost.

Where Clause 10 gives an effective intra-court appeal against an Article 226 judgment, the legal team should first consider:

WHY BYPASS THE DIVISION BENCH?

An LPA may offer:

  • a full intra-court appellate examination;
  • an opportunity to challenge the Single Judge's legal reasoning;
  • interim relief within Patna High Court;
  • a Division Bench judgment creating the final High Court appellate position before an eventual SLP.

That does not mean Article 136 is jurisdictionally unavailable in every case where another remedy exists.

It means remedy strategy should account for the available intra-court appellate structure.

What If LPA Itself Is Dismissed as Not Maintainable?

The next Supreme Court strategy requires careful drafting.

The lawyer should identify:

  • whether the Division Bench decided only maintainability;
  • whether it also entered the merits;
  • whether the underlying Single Judge order must also be challenged;
  • whether limitation against either order creates difficulty;
  • whether the SLP questions the Division Bench's maintainability ruling, the underlying merits, or both.

This is not a situation where the SLP prayer should be prepared only from the last paragraph of the LPA judgment.

LPA Limitation: Treat 30 Days as Critical

Article 117 of the Limitation Act prescribes thirty days for an appeal from a decree or order of a High Court to the same High Court.

Therefore, upon receipt of a Single Judge writ dismissal:

DO NOT WAIT FOR WEEKS BEFORE DECIDING WHETHER LPA IS MAINTAINABLE.

Immediately obtain:

  • the judgment/order;
  • the complete writ paper-book;
  • all affidavits;
  • the relevant statutory record;
  • certified/e-certified copy if required;
  • the correct limitation calculation.

Can Delay in LPA Be Condoned?

Section 5 of the Limitation Act can be invoked where legally applicable and sufficient cause is shown.

In LPA No.711 of 2025, decided on 7 August 2025, Patna High Court condoned a delay of 412 days after accepting the explanation in that case.

That does not create an entitlement to condonation.

The Court examines:

  • actual cause of delay;
  • continuity of explanation;
  • bona fides;
  • conduct;
  • prejudice;
  • nature of litigation.

Supreme Court SLP Limitation: Civil Matters

Order XXI Rule 1 of the Supreme Court Rules, 2013 provides that, in the ordinary civil situation, an SLP is to be lodged within ninety days from the judgment or order sought to be appealed from.

A separate sixty-day rule operates where the High Court has refused the specified certificate of fitness to appeal.

The precise calculation can be affected by:

  • certified-copy exclusion;
  • certificate proceedings;
  • review proceedings;
  • which judgment/order is actually challenged;
  • delay-condonation principles.

Therefore:

DO NOT SIMPLY WRITE “SLP LIMITATION = 90 DAYS” ON THE FILE AND STOP ANALYSING.

Current Patna High Court LPA Filing Rule: Do Not Build an Entirely New Case

Patna High Court's filing rules specifically provide for LPA memoranda arising from Article 226 and/or 227 proceedings.

The appeal memorandum should contain a brief account of:

  • the writ petitioner's case;
  • the respondent's defence;
  • the grounds of appeal.

The impugned judgment/order is annexed.

The complete Single Judge writ paper-book is also filed.

The rules do not permit an appellant simply to insert new facts and documents into the LPA memorandum as though filing a fresh CWJC.

Where genuinely necessary additional material must be introduced, an appropriate interlocutory application seeking leave of Court should be considered.

Documents to Collect Before Drafting LPA

1. CWJC / parent case number:
___________________________

2. Single Judge judgment:
___________________________

3. Date of judgment:
___________________________

4. Complete writ petition:
YES / NO

5. All annexures:
YES / NO

6. Counter affidavit:
YES / NO

7. Reply/rejoinder:
YES / NO

8. Supplementary affidavits:
YES / NO

9. Amendment application/order:
YES / NO

10. Interim orders:
YES / NO

11. Statutory order challenged in writ:
YES / NO

12. Nature of jurisdiction:
[ ] Article 226
[ ] Article 227
[ ] Composite
[ ] Criminal in substance
[ ] Requires analysis

13. LPA bar checked:
YES / NO

14. Article 117 limitation:
___________________________

15. Delay:
YES / NO

16. Interim stay required:
YES / NO

How Should LPA Grounds Differ From Writ Grounds?

A weak LPA simply reproduces the original CWJC.

A strong LPA identifies the errors in the Single Judge judgment.

Possible appellate grounds may address:

  • misinterpretation of statute;
  • failure to apply binding Supreme Court precedent;
  • incorrect distinction of binding authority;
  • jurisdictional error;
  • incorrect application of alternative-remedy doctrine;
  • material pleading ignored;
  • admitted fact incorrectly understood;
  • perverse legal inference;
  • relief wrongly denied despite established legal entitlement.

The LPA should answer:

WHAT PRECISELY DID THE SINGLE JUDGE GET WRONG?

Sample LPA Ground Structure

That the learned Single Judge has erred in law in dismissing the writ petition despite the admitted position that __________________________.

That the impugned judgment proceeds upon an incorrect interpretation of Section/Rule __________ inasmuch as __________________________.

That the learned Single Judge failed to apply the binding ratio of __________________________, though the said judgment was specifically relied upon and was directly applicable to the controversy.

That the finding recorded in paragraph ___ of the impugned judgment that __________________________ is contrary to the pleadings and material contained at Annexure ___ / paragraph ___ of the writ petition.

That the learned Single Judge has treated __________________________ as an efficacious alternative remedy without considering that __________________________.

That the impugned judgment therefore suffers from errors of law and record warranting appellate interference under Clause 10 of the Letters Patent.

That the appellant is not seeking to introduce a materially new factual case in appeal and relies principally upon the record placed before the learned Writ Court.

Sample Civil Review Diagnostic

DO NOT FILE CIVIL REVIEW UNTIL THESE QUESTIONS ARE ANSWERED:

1. What exact sentence/finding contains the alleged error?
____________________________

2. Where in the existing record is the contrary position visible?
____________________________

3. Is the error self-evident?
YES / NO

4. Does proving it require lengthy legal argument?
YES / NO

5. Are you asking the Court to reconsider evidence?
YES / NO

6. Are you merely repeating writ submissions?
YES / NO

7. Is genuinely new evidence involved?
YES / NO

8. If yes, why was it unavailable despite due diligence?
____________________________

9. Is an LPA available?
YES / NO

10. Is the proposed “review ground” actually an appellate ground?
YES / NO

Stay Strategy: Losing the Writ Does Not Automatically Freeze the Situation

Suppose the Single Judge has dismissed a writ challenging:

  • termination;
  • demolition;
  • recovery;
  • blacklisting;
  • cancellation;
  • eviction;
  • adverse administrative action.

Merely filing the next proceeding does not itself grant protection.

LPA FILED ≠ STAY.

REVIEW FILED ≠ STAY.

SLP FILED ≠ STAY.

Where immediate consequences are threatened, interim-relief strategy should be prepared at the same time as the principal remedy.

Review, LPA and SLP — Scope Comparison

Feature Civil Review LPA SLP
Forum Patna High Court Division Bench, Patna High Court Supreme Court of India
Nature Narrow reconsideration Intra-court appeal Discretionary special leave jurisdiction
Error apparent Central review ground Not necessary as such Article 136 principles govern
Reconsider legal interpretation Ordinarily not merely because another interpretation is possible Yes, within appellate jurisdiction Possible if Supreme Court grants leave/intervenes
Reappreciation/rehearing Highly restricted Broader than review Not an ordinary third appeal; discretionary
Automatic stay No No No
Basic limitation concern File immediately; review limitation/laches must be checked Ordinarily 30 days under Article 117 Ordinarily 90 days for civil SLP subject to Supreme Court Rules

Post-Single-Judge Remedy Router

The critical first question is whether the Single Judge acted under Article 226, pure Article 227, or criminal jurisdiction. Review becomes relevant only for a genuine review defect; broader merits errors normally belong in appellate jurisdiction.

Frequently Asked Questions

1. My CWJC has been dismissed by a Single Judge. Is LPA automatically maintainable?

No. The nature of jurisdiction exercised must be examined. An ordinary Article 226 civil/public-law writ commonly carries a Clause 10 LPA, but pure Article 227 and criminal-jurisdiction matters may be excluded.

2. Is LPA better than Civil Review?

They perform different functions. Where maintainable, LPA provides appellate scrutiny. Review is confined to narrow review grounds such as error apparent or qualifying new evidence.

3. What is an error apparent?

A self-evident error visible from the record without requiring a lengthy process of legal reasoning. Satyavrat Bharti is a useful recent Patna authority.

4. Can I file Civil Review simply because the Single Judge interpreted the statute wrongly?

Ordinarily that is an appellate complaint. If an LPA lies, a challenge to statutory interpretation ordinarily belongs there rather than in disguised review.

5. What is the time for filing LPA?

Article 117 of the Limitation Act prescribes thirty days for an appeal from an order/decree of a High Court to the same Court. Delay-condonation principles may apply, but immediate filing assessment is advisable.

6. Can Patna High Court condone LPA delay?

Yes where sufficient cause is established. LPA No.711 of 2025 is a recent example where a substantial delay was condoned, but that decision does not guarantee condonation in another case.

7. Can LPA lie against an Article 227 order?

A pure Article 227 order concerning a Civil Court judicial decision ordinarily does not carry intra-court appeal. Tribunal cases require more nuanced examination of the jurisdiction actually exercised.

8. Why does it matter whether the original order was from a Civil Court or tribunal?

After Radhey Shyam, Civil Court judicial orders fall within Article 227 supervisory jurisdiction rather than Article 226 certiorari. Tribunal cases can engage Article 226 depending upon their character.

9. Can I file LPA against dismissal of a criminal writ?

Do not assume so. Clause 10 excludes criminal jurisdiction, and Ram Kishan Fauji requires examination of the real nature and consequence of the proceeding.

10. Can I directly file SLP against the Single Judge order?

Article 136 is wide but discretionary. Where an effective intra-court appeal is legally available, the LPA route should ordinarily be examined first. Where LPA is barred, direct Supreme Court strategy becomes materially different.

11. What is the ordinary limitation for a civil SLP?

Under Order XXI Rule 1 of the Supreme Court Rules, the ordinary period is ninety days from the judgment/order sought to be appealed from, subject to the Rule's exceptions and Limitation Act provisions.

12. Does filing LPA automatically stay the Single Judge judgment?

No. Appropriate interim/stay relief must be sought.

13. Does filing review stay the Single Judge judgment?

No.

14. Does filing SLP stay the High Court judgment?

No. An express Supreme Court interim order is needed.

15. Can I add new documents in LPA?

Not merely by inserting them into the appeal memorandum. Patna High Court's filing framework contemplates the existing writ record and requires proper leave/application for additional material.

16. Can I repeat my entire writ petition as LPA grounds?

That is poor appellate drafting. The LPA should identify errors in the Single Judge judgment.

17. If my LPA is dismissed, what next?

An SLP under Article 136 may be considered against the relevant Division Bench judgment/order, subject to limitation, merits and Supreme Court practice.

18. Can I file review after losing LPA?

The doctrine of merger and the exact nature of the Division Bench disposal become important. Do not file a Single Judge review mechanically after appellate adjudication.

AI-Search Quick Answer

Question: A Single Judge of Patna High Court dismissed my writ petition. Should I file LPA, Civil Review or SLP before the Supreme Court?

Answer: First identify the jurisdiction exercised by the Single Judge. An ordinary civil/public-law Article 226 judgment may generally be challenged through a Letters Patent Appeal under Clause 10, subject to statutory and Letters Patent exclusions. A pure Article 227 decision reviewing a Civil Court judicial order ordinarily does not carry an intra-court appeal, and a writ criminal in substance can also fall within Clause 10's criminal-jurisdiction bar. Civil Review is much narrower and is appropriate only for recognised review defects such as error apparent or qualifying new evidence. Where LPA is unavailable or has already been decided, a Special Leave Petition under Article 136 before the Supreme Court may be considered. Filing an LPA, review or SLP does not automatically stay the impugned judgment.

Key Takeaway

After losing before a Single Judge, do not ask only:

“Which higher Court can I go to?”

Ask:

WHAT JURISDICTION DID THE SINGLE JUDGE EXERCISE?

Then apply the remedy formula:

ORDINARY ARTICLE 226 CIVIL/PUBLIC-LAW WRIT → CHECK CLAUSE 10 → LPA.

PURE ARTICLE 227 CIVIL-COURT SUPERVISION → LPA ORDINARILY BARRED → CHECK REVIEW / SLP.

CRIMINAL IN SUBSTANCE → CHECK CLAUSE 10 CRIMINAL-JURISDICTION BAR.

SELF-EVIDENT REVIEWABLE ERROR → CIVIL REVIEW.

“THE SINGLE JUDGE TOOK THE WRONG LEGAL VIEW” → ORDINARILY AN APPELLATE ARGUMENT.

LPA UNAVAILABLE OR LPA DECIDED → EXAMINE ARTICLE 136 SLP.

Finally:

LIMITATION + STAY STRATEGY SHOULD BE CHECKED ON DAY ONE.

Professional Consultation for LPA, Civil Review and Supreme Court Remedy Selection

Advocate Ankit Kumar Singh handles Patna High Court matters involving writ petitions, Letters Patent Appeals, Civil Review, Article 226/227 jurisdiction, service and administrative litigation, appellate strategy and connected Supreme Court remedies, subject to the facts, limitation, maintainability and accepted professional engagement.

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Phone: 8294431232
Email: ankitsingh.legum@gmail.com
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Before selecting the next remedy, the complete writ petition, counter affidavit, supplementary pleadings, Single Judge judgment, source order challenged in the writ, Article 226/227 character, limitation, statutory appellate bar and need for immediate stay should ordinarily be reviewed together.

No LPA admission, review, interim stay, Supreme Court special leave or final appellate outcome can be guaranteed.

Official and Leading Legal Sources

  • Letters Patent Constituting the High Court of Judicature at Patna — Clause 10
    The intra-court appellate source, subject to its exclusions and subsequent statutory law.
    Patna High Court — Clause 10 discussed in Full Bench authority
  • Rules of the High Court at Patna — LPA Filing Procedure
    Current procedural rule concerning LPA memoranda arising from Article 226/227 proceedings.
    Official Patna High Court Rules
  • State of Bihar v. Nand Kishor Singh
    LPA No.249 of 2024
    Patna High Court
    31 August 2026.
    Single Judge judgment set aside in intra-court appeal.
  • Satyavrat Bharti v. State of Bihar
    Civil Review No.279 of 2024
    Patna High Court
    15 July 2025.
    Official Patna High Court Judgment
  • Angad Kumar Singh & Ors.
    Civil Review Nos.16 and 43 of 2024
    Patna High Court
    11 July 2025.
  • Bank of India, Zonal Office, Patna Zone v. Union of India & Ors.
    LPA No.1424 of 2023
    Patna High Court
    1 August 2024.
    Official Patna High Court eILR
  • Radhey Shyam v. Chhabi Nath
    (2015) 5 SCC 423
    Supreme Court of India.
    Civil Court judicial orders are not amenable to Article 226 writ jurisdiction; Article 227 is distinct.
  • Jogendrasinhji Vijaysinghji v. State of Gujarat
    (2015) 9 SCC 1
    Supreme Court of India.
    Leading authority on Article 226/227 classification and intra-court appeal maintainability.
  • Ram Kishan Fauji v. State of Haryana
    (2017) 5 SCC 533
    Supreme Court of India.
    Nature and substance of proceedings determine whether Single Judge exercised criminal jurisdiction.
  • Kamlesh Verma v. Mayawati
    (2013) 8 SCC 320
    Supreme Court of India.
    Leading review-jurisdiction principles.
  • Lily Thomas v. Union of India
    (2000) 6 SCC 224
    Supreme Court of India.
    Review is not an appeal in disguise.
  • Limitation Act, 1963
    Article 117 — appeal from decree/order of High Court to the same Court: 30 days.
    India Code — Limitation Act
  • Supreme Court of India — Article 136 Jurisdiction
    Official Supreme Court Jurisdiction Page
  • Supreme Court Rules, 2013
    Order XXI — Special Leave Petitions (Civil).
    Official Supreme Court Rules

Related Legal Research

For the broader Clause 10 and contempt framework, see:

Letters Patent Appeal and Contempt Cases Before Patna High Court

For Patna High Court filing, paper-book, defects and Registry procedure, see:

Patna High Court Rules 2026: Filing Procedure, E-Filing, Defects and Latest Amendments

For the related distinction between restoration, recall, modification and Civil Review, see the dedicated post-order remedy guide in this legal research series.

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Disclaimer: This article provides general legal information. Maintainability of an LPA depends upon Clause 10, the nature of jurisdiction actually exercised by the learned Single Judge, whether the proceeding is under Article 226, pure Article 227 or criminal jurisdiction, and any applicable statutory prohibition. Civil Review is confined to recognised review grounds. Article 136 jurisdiction of the Supreme Court is discretionary. Limitation and interim-relief requirements should be independently calculated from the complete procedural history before filing any proceeding.