except by writ of injunction, and no bill of review shall be filed after two years have elapsed from the date of such decision, order, or judgment. Former Tex. Prob. Code § 31 (current version at Tex. Estates Code § 55.251). In contrast to equitable bills of review, section 31 has been interpreted to require a showing of “substantial error” in a prior decision, order, or judgment. See, e.g., Nadolney v. Taub, 116 S.W.3d 273, 278 (Tex. App. — Houston [14th Dist.] 2003, pet. denied) (“The purpose of a section 31 bill of review is to revise and correct errors, not merely to set aside decisions, orders, or judgments rendered by the probate court.”); McDonald v. Carroll, 783 S.W.2d 286, 288 (Tex. App. — Dallas 1989, writ denied); cf. Norton v. Cheney, 138 Tex. 622, 161 S.W.2d 73, 74 (1942) (<HOLDING>). Fidelity and Valdez contend the Legislature
holding that the discovery rule does not apply to  bill of review claims to set aside probate judgments holding that the meritorious defense requirement in a bill of review proceeding violates due process where the bill of review plaintiff has no notice of the proceeding in which the default judgment was rendered holding that demand upon a bill already paid or unauthorized demand upon unpaid bill constitutes a false claim even though bill itself contains no false statement holding that standard for obtaining equitable bill of review did not apply to statutory bill of review in guardianship proceeding citing jones v parker 67 tex 76 3 sw 222 224 1886 holding that bill of review brought in wrong court constitutes collateral attack