Bombay High Court

M/S. VORA AND CO. AND ORSversusLILABEN MANIBHAI PATEL AND ORS

Decided: 8 May 2026
Disposal: Disposed Off
Bench: M M SATHAYE

Holding

A bona fide clerical mistake in a judicial order may be corrected suo motu to reflect the accurate reservation and pronouncement dates.

Summary

The applicants filed a civil revision seeking correction of a bona fide mistake in the High Court's order dated 8 May 2026. The order had been reserved on 23 December 2025, but this reservation date was omitted from the pronouncement. The Court, acting suo motu, examined whether such a clerical error could be rectified without fresh proceedings. It held that a genuine clerical mistake affecting the record can be corrected to reflect the true dates of reservation and pronouncement. Consequently, the Court directed that the order be amended to show it was reserved on 23 December 2025 and pronounced on 8 May 2026, with the remainder of the order left unchanged and the corrected version uploaded.

Issues considered

Whether a bona fide clerical mistake in a judicial order can be corrected suo motu without fresh adjudication

Subjects

correction of order
bona fide mistake
suo motu jurisdiction
civil revision
High Court of Bombay

Judgment

                                                                        2-CAC-233-2017.doc



                                  IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                          CIVIL APPELLATE JURISDICTION

                                         CIVIL APPLICATION NO. 233 of 2017
                                                         IN
                                   CIVIL REVISION APPLICATION NO. 557 OF 2010

                   M/s. Vora And Co. And Others                              ...Applicants

SNEHA              IN THE MATTER BETWEEN:
NITIN                                                                        ...Rev. Applicants
CHAVAN             Lilaben Manibhai Patel And Others
Digitally signed
by SNEHA
                             Versus
NITIN CHAVAN
Date: 2026.06.09
18:01:46 +0530
                   M/s Vora And Co. And Others                               ...Respondents

                                                   ****
                   Mr. Amol Mhatre for the Applicant.
                   Mr. Bharat Jain a/w Hrishikesh Tajane for Respondents/ Revi.
                   Applicants.
                                                   ****

                                                  CORAM :       M.M. SATHAYE, J.
                                                    DATE :      9th JUNE, 2026
                   P.C. :


                   1.             Not on board. Taken on board.
                   2.             The matter is listed suo motu for correction of a bonafide
                   mistake in the order dated 08th May 2026. Though the order was
                   reserved on 23rd December 2025 and the pronounced on 8 th May 2026,
                   it has remained to be so mentioned in the order.
                   3.             Hence, it is directed that the order dated 08 th May 2026 be
                   corrected by showing that same was reserved on 23 rd December 2025
                   and pronounced on 08th May 2026.
                   4.             Rest the order remains as it is.
                   5.             Corrected order be uploaded.


                                                                      (M.M. SATHAYE, J.)



                   Sneha Chavan                                                              1

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