Date of the Judgment: January 28, 2022
Citation: Miscellaneous Application No.1769/2021 in C.A. No.4846/2021
Judges: Hon’ble Mr. Justice L. Nageswara Rao and Hon’ble Mr. Justice B.R. Gavai.
Did you know that even a small error in a court document can require a correction by the Supreme Court? In a recent case, the Supreme Court of India addressed a clerical error in the cause title of a judgment. This case highlights the importance of accuracy in legal documents and the procedures for correcting such errors. The Supreme Court, in this miscellaneous application, rectified the cause title of its previous judgment in a service matter appeal.
Case Background
This case involves a miscellaneous application filed to correct an error in the cause title of a judgment previously delivered by the Supreme Court. The original judgment was in a Civil Appeal, and the applicant, Praveen Kumar C.P., sought a correction to the name of the respondent.
Timeline
| Date | Event |
|---|---|
| 17.08.2021 | Original judgment passed in C.A.No.4846/2021 |
| 28.01.2022 | Miscellaneous Application No.1769/2021 allowed by the Supreme Court |
Course of Proceedings
The applicant filed a miscellaneous application to correct the cause title of the judgment dated 17.08.2021 passed in C.A.No.4846/2021. The Supreme Court considered the application and passed an order to correct the error.
Legal Framework
There is no specific legal provision discussed in the judgment. The application was regarding a clerical error in the cause title of the judgment.
Arguments
The applicant argued that there was a typographical error in the cause title of the judgment dated 17.08.2021. The respondent’s name was incorrectly recorded as “KERALA PUBLIC SERVICE COMMISSION COMMISSION & ORS.” instead of the correct name, “KERALA PUBLIC SERVICE COMMISSION & ORS.”
| Applicant’s Submission | Respondent’s Submission |
|---|---|
| The cause title of the judgment dated 17.08.2021 contains a typographical error. | No specific submission recorded. |
| The respondent’s name is incorrectly recorded as “KERALA PUBLIC SERVICE COMMISSION COMMISSION & ORS.” | |
| The correct name of the respondent is “KERALA PUBLIC SERVICE COMMISSION & ORS.” |
Issues Framed by the Supreme Court
The primary issue before the Supreme Court was whether the cause title of the judgment dated 17.08.2021 in C.A.No.4846/2021 contained a typographical error that needed correction.
Treatment of the Issue by the Court
The Supreme Court acknowledged that there was a typographical error in the cause title of the judgment dated 17.08.2021. The Court allowed the miscellaneous application and ordered that the respondent’s name be corrected from “KERALA PUBLIC SERVICE COMMISSION COMMISSION & ORS.” to “KERALA PUBLIC SERVICE COMMISSION & ORS.”
| Issue | Court’s Decision |
|---|---|
| Whether the cause title of the judgment dated 17.08.2021 contained a typographical error? | Yes, the Court found that there was a typographical error. |
| Whether the correction should be allowed? | Yes, the Court allowed the correction. |
Authorities
No authorities were discussed in the judgment.
| Authority | How the Authority was used by the Court |
|---|---|
| None | None |
Judgment
| Submission of the Parties | Treatment by the Court |
|---|---|
| The applicant submitted that there was a typographical error in the cause title of the judgment. | The Court accepted the submission and allowed the application for correction. |
| Authority | How the Authority was viewed by the Court |
|---|---|
| None | None |
What weighed in the mind of the Court?
The Court’s decision was primarily based on the factual existence of a typographical error in the cause title of the judgment. The Court’s reasoning was straightforward: there was a clear error that needed correction.
| Sentiment | Percentage |
|---|---|
| Factual Accuracy | 100% |
| Category | Percentage |
|---|---|
| Fact | 100% |
| Law | 0% |
The Court did not consider any alternative interpretations as the issue was a simple clerical error. The decision was reached based on the factual inaccuracy in the cause title.
The Supreme Court corrected the name of the respondent in the cause title of the judgment dated 17.08.2021 from “KERALA PUBLIC SERVICE COMMISSION COMMISSION & ORS.” to “KERALA PUBLIC SERVICE COMMISSION & ORS.”
The Court’s reasoning was based on the simple fact that there was a clear typographical error.
There were no majority or minority opinions in this case, as it was a straightforward correction of a clerical error.
The implications of this case are primarily procedural, emphasizing the need for accuracy in court documents and the availability of mechanisms for correcting errors.
No new doctrines or legal principles were introduced in this case.
Key Takeaways
- ✓ Court documents must be accurate and free from errors.
- ✓ There are mechanisms in place to correct errors in court documents.
- ✓ Even seemingly minor errors can be addressed by the Supreme Court.
Directions
The Supreme Court directed that the cause title of the judgment dated 17.08.2021 be corrected to reflect the correct name of the respondent.
Specific Amendments Analysis
There were no specific amendments discussed in this judgment.
Development of Law
The ratio decidendi of this case is that typographical errors in court documents can be corrected through miscellaneous applications. There was no change in the previous position of law.
Conclusion
In conclusion, the Supreme Court allowed the miscellaneous application to correct a typographical error in the cause title of a previous judgment. This case underscores the importance of accuracy in legal documents and the procedures available for correcting such errors.
Source: Praveen Kumar vs. Kerala PSC