Step 1: Background of the concept.
The Supreme Court considered whether there should be any remedy after dismissal of a review petition to prevent miscarriage of justice.
Step 2: Ruling of the Court.
In {Rupa Ashok Hurra v. Ashok Hurra}, the Court evolved the concept of a curative petition as a final constitutional safeguard.
Step 3: Conclusion.
Hence, the correct answer is (D).