Gangadhara Palo vs The Revenue Divisional Officer & Anr

The Supreme Court held that the High Court's dismissal of a review petition due to a 71-day delay was erroneous, emphasizing that a liberal approach should have been adopted in condoning the delay. The Court clarified the doctrine of merger, stating that if a special leave petition is dismissed without reasons, the judgment of the lower court remains valid for review. Consequently, the Court condoned the delay and allowed the review petition to be considered on its merits, overturning the High Court's decision.