Award correction powers are limited to clerical errors; dearness allowance need not always follow the cost of living index.

Rule 31 permits correction only of clerical mistakes or accidental slips, so it cannot be used to introduce a fresh substantive benefit into an award. On that basis, the attempted corrigendum that would have converted an integrated wage-scale increase into a separate cash increase for each workman was beyond jurisdiction and liable to be quashed. On dearness allowance, there is no universal requirement that it must always track the cost of living index; the Tribunal's balanced wage package, including basic wages, dearness allowance and house rent allowance, was treated as a matter of industrial adjudication, and the challenge to that structure failed.

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Issues: (i) Whether the Tribunal could correct the award under Rule 31 by adding words so as to make the flat increase operative as a cash increase to each workman, and (ii) whether dearness allowance had to be correlated with the cost of living index.

Issue (i): Whether the Tribunal could correct the award under Rule 31 by adding words so as to make the flat increase operative as a cash increase to each workman.

Analysis: Rule 31 permitted only correction of a clerical mistake or an error arising from an accidental slip or omission. The award as originally framed showed that the Tribunal was revising the wage structure by restructuring the scales, with the flat increase integrated into the scales themselves, and not granting a separate ad hoc increase to each individual workman. The fitment directions, the revised scale tables, and the overall financial burden assumed in the award all pointed to a single increase embedded in the scale structure. The later correction would have introduced a fresh and additional benefit beyond the conscious adjudication already completed, which lay outside the limited corrective power under Rule 31.

Conclusion: The correction order was beyond jurisdiction and was liable to be quashed.

Issue (ii): Whether dearness allowance had to be correlated with the cost of living index.

Analysis: There is no universal rule that dearness allowance must always move with the cost of living index. The Tribunal had balanced the revised basic wage structure, the existing dearness allowance and house rent allowance, and the employer's financial capacity. It found that a slab system or further modification would create an excessive burden and that the composite wage package already provided sufficient relief. In these circumstances, interference with the Tribunal's choice of method was unwarranted.

Conclusion: The challenge to the dearness allowance structure failed.

Final Conclusion: The majority held that the award could not be reopened beyond the limited correction power, and that the wage package, including the dearness allowance arrangement, called for no interference.

Ratio Decidendi: The power to correct an award for clerical mistake or accidental slip cannot be used to introduce a fresh substantive relief, and dearness allowance need not invariably be linked to the cost of living index where the overall wage structure is a balanced industrial adjudication.

Dissenting Opinion: Chinnappa Reddy J. held that the correction sought under Rule 31 was only to make explicit what had already been intended in the award, and would have sustained the corrigendum; he nevertheless agreed that the workmen's appeal on dearness allowance should fail.

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