Rectification power is limited to apparent errors; merits review is barred, though a clerical plot-description correction was allowed.

Section 20 of the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976 permits only correction of mistakes apparent on the face of the record and does not allow reappraisal of evidence, reconsideration of findings, or a merits-based review. An error requiring long-drawn reasoning or involving a debatable point is outside rectification. However, a limited inconsistency in the description of ownership of three plots was treated as a clerical or typographical mistake, so only that narrow correction was allowed while rectification on merits was refused.

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Issues: Whether the rectification power under section 20 of the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976 extends to reappraisal of evidence and reconsideration of the merits of the forfeiture appeal, and whether a limited clerical correction was nevertheless warranted in the Tribunal's earlier order.

Analysis: Section 20 was held to be confined to correcting only mistakes apparent on the face of the record. A request that requires re-examination of the evidence, reconsideration of the findings, or substitution of a different view on the same material amounts in substance to a review on merits, which is outside the scope of rectification. An error that can be established only by a long-drawn process of reasoning, or which turns on a debatable point, is not an apparent error. At the same time, the record disclosed a limited inconsistency in the description of the ownership of the three plots, amounting to a clerical or typographical mistake in the earlier order.

Conclusion: Rectification on merits was refused, but a limited clerical correction in the description of the plots was allowed.

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