Review jurisdiction is limited to correcting apparent errors and cannot reopen merits or grant substantive modification.

Review jurisdiction was confined to correcting an obvious typographical error in the earlier order, and the percentage reference was amended from 50 per cent to 15 per cent. The request for broader modification, including a declaration that the Department was bound to purchase the property because the sale price was below market value, was rejected because pre-emptive purchase under the statutory scheme is not automatic and depends on good reason to acquire the property. The prayer to implead the Income-tax Department was also declined, as it disclosed no error apparent on the face of the record. The review power could not be used to reopen the merits or grant substantive relief.

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Issues: Whether the earlier order could be reviewed to correct a typographical mistake from 50 per cent to 15 per cent, and whether the remaining grounds seeking modification of the order and impleadment of the Income-tax Department disclosed any error apparent on the face of the record.

Analysis: The correction of the percentage stated in the earlier order was treated as an obvious typographical mistake and was amended to 15 per cent, as that portion was not the operative part of the order. The request for a further declaration that the Department was bound to purchase the property merely because the sale price was below market value was rejected, since pre-emptive purchase under the relevant statutory scheme depends on there being good reason to acquire the property and is not automatic. The request to implead the Income-tax Department was also declined because it did not disclose any apparent error in the record. The scope of review was held to be narrow and not available for reappreciation or substantive modification of the earlier decision.

Conclusion: The review was allowed only to the limited extent of correcting the typographical mistake, while the substantive prayers for further modification and impleadment were rejected.

Final Conclusion: The earlier order stood corrected only on the clerical point, and no broader review relief was granted.

Ratio Decidendi: Review jurisdiction is confined to correction of apparent mistakes and cannot be used to reopen the merits of the order or to grant substantive relief absent an error apparent on the face of the record.

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