Bombay High Court
Apurvakriti Infrastructure Private LimitedversusTata Projects Limited
- Decided
- Disposal
- DISMISSED
- Bench
- ARUN R PEDNEKER
Holding
The court may correct clerical and typographical errors in its orders without a fresh hearing, provided the corrections do not alter the substantive rights of the parties.
Summary
The High Court of Bombay heard applications from both parties in Commercial Arbitration Application No.23 of 2026 seeking corrections to its order dated 17 June 2026. The applicant, M/s Apurvakriti Infrastructure Pvt. Ltd., requested that several references to “G.C.C.” be changed to “Special Conditions of Contract”. The respondent, Tata Projects Limited, sought numerous textual amendments, including correction of a demand‑letter date, replacement of clause numbers, and changes from “Tender‑cum‑Work Order” to “Agreement‑cum‑Work Order”. The court examined its inherent power to rectify clerical and typographical errors in its own orders. It held that such corrections are permissible when they do not alter the substantive rights of the parties. Accordingly, the court ordered that the specified corrections be made and the revised order uploaded.
Issues considered
- What is the scope of the court's inherent jurisdiction to correct clerical or typographical errors in its own orders?
- Do the proposed amendments affect the substantive rights of the parties, thereby requiring a fresh hearing?
Subjects
- judicial correction
- clerical error
- inherent jurisdiction
- commercial arbitration
- civil procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
COMMERCIAL ARBITRATION APPLICATION NO.23 OF 2026
M/s Apurvakriti Infrastruture Pvt. Ltd. .. Applicant
BHALCHANDRA
GOPAL
DUSANE
Vs.
Digitally signed by
Tata Projects Limited & Ors. .. Respondents
BHALCHANDRA
GOPAL DUSANE
Date: 2026.06.23
11:14:14 +0530
Ms. Mayureshwari Rajan Kordaay i/by GP and Associates for Applicant.
Ms. Riya Pichaya i/b India Law LLP, Advocate for Respondent No.1.
CORAM : ARUN R. PEDNEKER, J.
DATE : 19th JUNE 2026.
P.C. :
1. Today, learned counsel appearing for both the parties moved a
praecipe for Speaking to the Minutes of the Order dated 17th June 2026.
2. Learned counsel for the Applicant submitted that in the said order
following corrections/rectification be made :
In Paragraph nos. 4, 5, 7, 11, 12, 13, 14 and 15, the word
“G.C.C.” be replaced as “Special Conditions of Contract”.
3. It is submitted by the learned counsel for the Respondent that in the
said order following corrections/rectification be made :
In Para no.3 date of Demand Letter be corrected as 21st May
2025.
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P-2 CARAP 23,2024.doc Dusane
In para 4, Clause 31.1 be replaced with Clause 31.3.
Tender-cum-Work Order be rectified as “Agreement-Cum-Work
Order”.
In Para-5, Tender document be rectified as “Work Order”.
(iv) be rectified as (vi);
Citation (2024) SCC 174 be rectified as (2024) 7 SCC 174
In Para-9A – word Board be rectified as “broad”.
Tender document be rectified as Work Order.
In Para 10 – Tender document be rectified as Work Order.
Tender-cum-Work Order be rectified as “Agreement-cum-Work
Order”.
In Para 14 – Tender document to be rectified as “Work Order”.
Tender-cum-Work Order be rectified as “Agreement-cum-Work
Order”.
3. Necessary corrections be carried out in the said order and it be
uploaded accordingly.
[ ARUN R. PEDNEKER, J. ]
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P-2 CARAP 23,2024.doc Dusane
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