Limited review jurisdiction permits correction of apparent record errors, while omitted Gazette publication in winding-up proceedings was treated as an irregularity.

Review jurisdiction is confined to correcting an error apparent on the face of the record and cannot be used to reappreciate the merits. A Gujarat HC article notes that an earlier winding-up order wrongly referred to publication in the Official Gazette and Government Gazette, although the admission order had dispensed only with that publication while requiring newspaper advertisement; that clerical mistake was correctable in review. The article further states that, on a combined reading of the company court rules and the court's inherent powers, non-publication in the Official Gazette did not vitiate the proceedings and was at most an irregularity. Challenges to the restoration order and debt-related objections were treated as substantive contentions outside review.

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Issues: Whether the review application could succeed to the limited extent of correcting an apparent error in the earlier order and whether the absence of publication in the Official Gazette, or the earlier restoration order, justified reopening the winding-up order.

Analysis: Review jurisdiction is confined to correction of a mistake or error apparent on the face of the record and cannot be used for reappreciation of evidence or reassessment of the merits. The earlier order mistakenly referred to publication in the Official Gazette and Government Gazette, although the admission order had dispensed only with such publication while directing advertisement in newspapers. That mistaken reference was an apparent clerical or record error and could be corrected in review. As regards the challenge to non-publication in the Official Gazette, the Court held that the combined reading of the applicable company court rules and the inherent powers of the Court permitted dispensation of that publication, and at most the omission was an irregularity, not a vitiating illegality. The challenge to the restoration order and the debt-related objections were treated as merit-based contentions beyond the scope of review.

Conclusion: The review was allowed only to delete the erroneous references to publication in the Official Gazette and Government Gazette from the earlier order; the remaining grounds were rejected.

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