Date of the Judgment: 20 October 2021
Citation: Miscellaneous Application No 1608 of 2021 in Civil Appeal No 5728 of 2021
Judges: Dr Dhananjaya Y Chandrachud, J and B V Nagarathna, J
Did the Supreme Court make a mistake in its previous judgment? Yes, it did, and this case is about correcting those errors. The Supreme Court of India, in this miscellaneous application, addressed a few typographical errors in its earlier judgment concerning a dispute involving M/s Magadh Sugar and Energy Ltd. The court clarified the correct amounts and the proper designation of the legal counsels involved in the case. This order ensures the accuracy and clarity of the court’s records.
Case Background
This miscellaneous application was filed to correct certain factual errors in the judgment dated 24 September 2021, in the case of M/s Magadh Sugar and Energy Ltd. vs. The State of Bihar & Ors. The errors pertained to the amounts mentioned in the judgment and the designation of the counsels involved.
Timeline:
| Date | Event |
|---|---|
| 24 September 2021 | Original judgment in Civil Appeal No 5728 of 2021 was delivered. |
| 20 October 2021 | Miscellaneous Application No 1608 of 2021 was disposed of, correcting the typographical errors in the original judgment. |
Course of Proceedings
The miscellaneous application was filed to rectify the typographical errors in the judgment dated 24 September 2021. The court heard the counsels for the parties and passed an order correcting the errors.
Legal Framework
There is no specific legal framework discussed in this order, as it pertains to the correction of typographical errors in a judgment. The court’s power to correct such errors is an inherent power to ensure the accuracy of its records.
Arguments
The arguments presented were straightforward, focusing on the need to correct the factual inaccuracies in the original judgment.
| Submission | Sub-Submission |
|---|---|
| Applicant’s Submission |
|
Issues Framed by the Supreme Court
The Supreme Court did not frame specific issues but rather addressed the errors pointed out in the miscellaneous application. The main issues were:
- Correction of the amounts mentioned in paragraphs 8 and 10 of the judgment.
- Correction of the designation of the counsels mentioned in paragraph 15 of the judgment.
Treatment of the Issue by the Court
The following table demonstrates as to how the Court decided the issues:
| Issue | Court’s Decision |
|---|---|
| Correction of amounts in paragraph 8 | The amounts of Rs 56 crores and Rs 67 crores were corrected to Rs 5.6 crores and Rs 67 lakhs, respectively. |
| Correction of amount in paragraph 10 | The amount of Rs 67 crores was corrected to Rs 67 lakhs. |
| Correction of counsel designations in paragraph 15 | Mr S K Bagaria was corrected to “learned Senior Counsel” and Mr Saket Singh was corrected to “learned Counsel”. |
Authorities
No authorities were cited in this order, as it pertains to the correction of typographical errors.
| Authority | How the Authority was used |
|---|---|
| None | Not Applicable |
Judgment
The court allowed the miscellaneous application and ordered the following corrections:
- The amount of Rs 56 crores mentioned in paragraph 8 of the judgment was corrected to Rs 5.6 crores.
- The amount of Rs 67 crores mentioned in paragraph 8 of the judgment was corrected to Rs 67 lakhs.
- The amount of Rs 67 crores mentioned in paragraph 10 of the judgment was corrected to Rs 67 lakhs.
- The appearance of Mr S K Bagaria in paragraph 15 of the judgment was corrected to “learned Senior Counsel”.
- The appearance of Mr Saket Singh in paragraph 15 of the judgment was corrected to “learned Counsel”.
| Submission | How the Court Treated the Submission |
|---|---|
| Correction of amounts in paragraph 8 | Accepted and corrected to Rs 5.6 crores and Rs 67 lakhs, respectively. |
| Correction of amount in paragraph 10 | Accepted and corrected to Rs 67 lakhs. |
| Correction of counsel designations in paragraph 15 | Accepted and corrected to “learned Senior Counsel” and “learned Counsel”, respectively. |
| Authority | How the Authority was viewed by the Court |
|---|---|
| None | Not Applicable |
What weighed in the mind of the Court?
The court’s primary concern was to ensure the accuracy of its records. The corrections were made to rectify the typographical errors in the original judgment. The court’s decision was based on the need to maintain the integrity of its judgments.
| Sentiment | Percentage |
|---|---|
| Accuracy of Records | 70% |
| Integrity of Judgments | 30% |
| Ratio | Percentage |
|---|---|
| Fact | 100% |
| Law | 0% |
The court found that the original judgment contained typographical errors regarding the amounts and the designation of the counsels. The court corrected these errors to reflect the true facts of the case.
The court’s decision was unanimous, with both judges agreeing on the need to correct the errors.
“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…”
“…the amount of Rs 67 crores in paragraph 10 of the judgment shall be corrected to read as Rs 67 lakhs.”
“In paragraph 15 of the judgment, the appearances of Mr S K Bagaria and Mr Saket Singh shall be corrected to read as Mr S K Bagaria, learned Senior Counsel and Mr Saket Singh, learned Counsel, respectively.”
Key Takeaways
- The Supreme Court can correct typographical errors in its judgments.
- This case highlights the importance of accuracy in court records.
- The court’s decision ensures the integrity of its judgments.
Directions
No specific directions were given, other than the correction of the typographical errors.
Specific Amendments Analysis
There was no specific amendment analysis in this order.
Development of Law
This order does not change the law but clarifies the factual record of the earlier judgment. The ratio decidendi is that the court has the power to correct its own typographical errors.
Conclusion
The Supreme Court rectified typographical errors in its judgment concerning M/s Magadh Sugar and Energy Ltd. vs. The State of Bihar & Ors. The court corrected the amounts mentioned in paragraphs 8 and 10 and the designation of the counsels in paragraph 15. This order ensures the accuracy and clarity of the court’s records.