Registration amendment relates back to application date where rules make the original certificate effective from that date.

Where the statutory rules made a registration certificate effective from the date of application, an amendment correcting an omitted entry in that certificate had to relate back to the same date. The authority erred in treating the request as an impermissible retrospective amendment, because the later correction merely completed an omission already covered by the original application. Refusal to give effect from the application date was therefore unsustainable, and the petitioner succeeded.

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Issues: Whether the certificate of registration and its amendment were to take effect from the date of the original application, and whether refusal to give effect from that date on the ground that retrospective amendment was impermissible was sustainable.

Analysis: The relevant rules provided that a registration certificate, when granted, becomes effective from the date of the application. The omission in the certificate was only to leave out an entry already claimed in the application, and the later request was merely to correct that omission. Once registration is operative from the date of application, the same principle applies to an amendment that fills in an omitted entry relating back to the original application. The revisional authority proceeded on an incorrect analogy by treating the request as an impermissible retrospective amendment.

Conclusion: The refusal to give effect from the date of application was unsustainable, and the petitioner succeeded.

Ratio Decidendi: Where the statutory rules make a registration certificate effective from the date of application, an amendment correcting an omission in that certificate must also relate back to that date and cannot be denied merely on the ground of retrospective effect.

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