Article 137: Review of judgments or orders by the Supreme Court

Leading cases

• Mohd. Arif alias Ashfaq v. Registrar, Supreme Court of India (2014)Article 21 requires that review petitions in death sentence cases be given a limited oral hearing in open court, not decided by circulation; appeals in such cases are to be heard by benches of three Judges.
• Union Carbide Corporation v. Union of India (1991)On review, the Court upheld the US $470 million Bhopal settlement and its Article 142 power to record it, but revived the quashed criminal proceedings and declared the Union of India liable to meet any shortfall in the fund.

Questions on this article

4 questions in 10 of our papers cite Article 137. Try these from the free papers:

1. 1. The remedy of a curative petition, available in rare cases even after the dismissal of a review petition by the Supreme Court, was recognised by the Supreme Court in:

   A.A.K. Gopalan v. State of Madras (1950)B.Rupa Ashok Hurra v. Ashok Hurra (2002)C.I.C. Golak Nath v. State of Punjab (1967)D.Kesavananda Bharati v. State of Kerala (1973)
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2. 2. In Sanjay Sharma @ Sanjay Bhardwaj v. Krishnadhan Khaware (15 July 2026), an application for probate filed about ten years after the testator's death had been rejected as time-barred. Setting this aside, the Supreme Court held that an application for probate is governed by:

   A.Article 65 of the Limitation Act, 1963, with twelve years counted from the death of the testatorB.Article 137 of the Limitation Act, 1963, with time running when the right to apply accruesC.Article 137 of the Limitation Act, 1963, with three years always counted from the death of the testatorD.Article 113 of the Limitation Act, 1963, with time running from when the will is first produced in court
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