Correction of Typographical Errors in Magadh Sugar and Energy Ltd Judgment: A Detailed Analysis
The Supreme Court of India recently addressed a typographical error in the judgment of M/s Magadh Sugar and Energy Ltd vs. The State of Bihar & Ors. The matter was brought before the Court through Miscellaneous Application No. 1608 of 2021 in Civil Appeal No. 5728 of 2021. The issue at hand was the correction of numerical errors in the financial figures mentioned in the original judgment dated September 24, 2021.
Such errors, though minor at first glance, can have significant implications, especially when they involve financial amounts. The petitioner argued that the incorrect mention of figures could lead to serious legal and financial consequences, thereby necessitating a correction.
Background of the Case
The case arose from a dispute involving M/s Magadh Sugar and Energy Ltd and the State of Bihar. The core issue involved financial amounts that were incorrectly recorded in the judgment, leading the petitioner to seek rectification through a miscellaneous application.
Errors Identified in the Original Judgment
In the original judgment:
- The amount of Rs. 56 crores and Rs. 67 crores mentioned in paragraph 8 needed to be corrected to Rs. 5.6 crores and Rs. 67 lakhs, respectively.
- The amount of Rs. 67 crores mentioned in paragraph 10 was actually Rs. 67 lakhs.
- The appearances of Mr. S.K. Bagaria and Mr. Saket Singh in paragraph 15 required rectification to correctly reflect their designations as ‘learned Senior Counsel’ and ‘learned Counsel’.
Petitioner’s Arguments
The petitioner, represented by Mr. Praveen Kumar, AOR, and Ms. Sunaina Kumar, emphasized the importance of correcting these errors. They argued that misinterpretations arising from incorrect figures could have substantial ramifications, particularly in financial matters.
The counsel further submitted that the errors were clerical in nature and did not affect the substantive ruling of the case. However, allowing such errors to persist in official judicial records could lead to confusion in enforcement and implementation of the judgment.
Respondent’s Arguments
The respondents, represented by Mr. Saket Singh and Mrs. Niranjana Singh, did not oppose the application. Instead, they acknowledged the need for correction and supported the petitioner’s request. The respondents emphasized that the integrity of the judgment must be maintained, and rectifying typographical errors was in the interest of justice.
Judicial Observations
The bench, consisting of Hon’ble Dr. Justice D.Y. Chandrachud and Hon’ble Mrs. Justice B.V. Nagarathna, examined the submissions and acknowledged the clerical nature of the errors.
The Court noted: “The Miscellaneous Application has been filed for correction of a typographical error in the judgment dated 24 September 2021.“
Further, the Court ruled: “The amount of Rs. 56 crores and Rs. 67 crores mentioned in paragraph 8 of the judgment shall be corrected to read as Rs. 5.6 crores and Rs. 67 lakhs respectively, and the amount of Rs. 67 crores in paragraph 10 of the judgment shall be corrected to read as Rs. 67 lakhs.“
With these corrections, the application was allowed, ensuring that the judgment accurately reflected the intended financial details.
Legal Precedents and Significance
The correction of typographical errors in judgments is not an uncommon practice. Courts have often exercised their powers to ensure that clerical mistakes do not affect the substantive rights of parties. This case reaffirms the principle that minor errors in judicial pronouncements should not result in unintended consequences.
Impact of the Judgment
- Ensuring Accuracy: The rectification prevents misinterpretation and legal disputes arising from incorrect figures.
- Maintaining Judicial Integrity: By allowing such corrections, the judiciary upholds the accuracy and reliability of its pronouncements.
- Precedent for Future Cases: This ruling reinforces the Court’s approach toward clerical corrections, ensuring that similar requests are handled efficiently in the future.
Conclusion
The Supreme Court’s decision to rectify the typographical errors in the Magadh Sugar and Energy Ltd judgment underscores the importance of precision in legal documentation. While the core ruling remained unaffected, the corrections ensured that the judgment was free from ambiguity and potential misinterpretations. The case serves as a reminder of the judiciary’s commitment to upholding the integrity of its rulings and maintaining the highest standards of accuracy in judicial records.
Petitioner Name: M/s Magadh Sugar and Energy Ltd.Respondent Name: The State of Bihar & Ors.Judgment By: Justice D.Y. Chandrachud, Justice B.V. Nagarathna.Place Of Incident: Bihar.Judgment Date: 20-10-2021.
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