Rectification of mistake requires an apparent error on record; later High Court reversal alone is not enough.

Rectification of mistake is confined to an apparent error on the record and cannot be used merely because a supporting High Court ruling was later reviewed or reversed. Where the original order rests on two independent bases, a later change in one authority does not unsettle the result if the other ground remains sufficient. Rectification on the strength of later precedent requires a binding Supreme Court declaration that the earlier view was contrary to law; a subsequent High Court decision does not meet that standard. The rectification application therefore could not be sustained.

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Issues: (i) Whether the rectification application could be entertained on the basis that the High Court decision relied upon in the original order was subsequently reviewed and reversed; (ii) Whether rectification was permissible in the absence of any decision of the Supreme Court declaring the earlier view to be contrary to law.

Issue (i): Whether the rectification application could be entertained on the basis that the High Court decision relied upon in the original order was subsequently reviewed and reversed.

Analysis: The original order was not founded solely on the High Court decision that was later reviewed. It had proceeded on two grounds, namely the earlier High Court ruling and an additional ground based on the notification and the export quality control framework. A later change in one supporting authority does not disturb the final result where the order rests on more than one independent basis.

Conclusion: The rectification application could not succeed on this ground.

Issue (ii): Whether rectification was permissible in the absence of any decision of the Supreme Court declaring the earlier view to be contrary to law.

Analysis: Rectification on the basis of a later decision is justified only where a binding declaration of law by the Supreme Court establishes that the earlier decision was contrary to law and therefore constitutes an error apparent on the record. A later High Court decision does not have the same effect for this purpose.

Conclusion: Rectification was not permissible in the absence of a Supreme Court ruling.

Final Conclusion: The rectification application failed because the original order remained supportable on an independent ground and no binding Supreme Court decision created an apparent error warranting correction.

Ratio Decidendi: Rectification of mistake can be invoked only for an apparent error on the record, and a later change in a non-binding precedent does not justify rectification where the original decision is independently sustainable on more than one ground.

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