Rectification under Rule 154 cannot grant substantive relief after merger in appeal; appellate remedy is the proper course.

Rectification under Rule 154 of the NCLT Rules is limited to clerical, arithmetical, or accidental slips and cannot be used to secure substantive relief such as an omitted dividend-related order. Where the original order has already been challenged and the appellate order has affirmed it, the original order merges in appeal and the Tribunal cannot revisit it by way of rectification or review. In that situation, the proper remedy is appeal, and Section 420(2) of the Companies Act, 2013 bars such amendment. The application was therefore held not maintainable and was dismissed.

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Issues: Whether an application under Rule 154 of the NCLT Rules, 2016 was maintainable to seek additional relief by way of rectification after the original order had already been challenged and merged in appeal.

Analysis: Rule 154 permits only correction of clerical, arithmetical, or accidental slips and omissions. The relief sought was not a correction of any such error but a substantive addition to the earlier order by granting dividend-related relief that had not been awarded. The proper remedy for such grievance was an appeal. Since the order had already been carried in appeal and the appellate order affirmed the Tribunal's order, the original order stood merged. In such circumstances, the Tribunal had no review power and could not amend the order, particularly in view of the bar under Section 420(2) of the Companies Act, 2013.

Conclusion: The application was not maintainable and was liable to be dismissed.

Final Conclusion: The Tribunal declined to entertain rectification as a substitute for review and held that no clerical or accidental error existed in the earlier order.

Ratio Decidendi: Rectification under Rule 154 is confined to clerical, arithmetical, or accidental errors and cannot be used to obtain substantive relief or review an order that has already merged in appeal.

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