Section 33 correction power cannot be used to make a substantive modification of an arbitral award.

Section 33 of the Arbitration and Conciliation Act, 1996 permits only correction of computational, clerical, typographical or similar errors and does not authorise substantive alteration of an arbitral award. A modification that substituted the value of gold awarded on the basis of the claimant's original claim, without any genuine clerical or arithmetical mistake, went beyond that limited power and could not be sustained. The modification order was therefore invalid, and the original award had to be restored.

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Issues: Whether an arbitral tribunal could, under Section 33 of the Arbitration and Conciliation Act, 1996, modify the award by substituting the value of the gold awarded on the basis of the claimant's original claim.

Analysis: Section 33 permits correction only of computational, clerical, typographical, or similar errors and does not authorise a substantive alteration of the award. The original award had already granted relief on the basis of the claim as made, and the later modification replaced the original valuation without any real clerical or arithmetical mistake being shown. Such a change went beyond the limited scope of Section 33 and could not be sustained by the courts below.

Conclusion: The modification order under Section 33 was invalid and the original award had to be restored.

Ratio Decidendi: The power under Section 33 of the Arbitration and Conciliation Act, 1996 is confined to correction of clerical or arithmetical errors and cannot be used to make a substantive modification of an arbitral award.

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