IBC recall or review limits: Adjudicating Authority cannot revisit its own order beyond clerical corrections, objections go to the Resolution Professional.

In personal guarantor insolvency proceedings under the IBC, the Adjudicating Authority cannot recall or review its own order except to correct clerical or arithmetical mistakes. The authority had only a limited corrective power and could not sit in appeal over its order. Because the matter had not reached final adjudication on the Resolution Professional's report and the applicant had already been given an opportunity to file objections before the Resolution Professional, no interference was warranted. The dismissal of the recall application was upheld, and the applicant was directed to pursue objections before the Resolution Professional at the appropriate stage.

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Issues: Whether the Adjudicating Authority could recall or review its order passed in proceedings under Section 95 of the Insolvency and Bankruptcy Code, 2016, and whether the dismissal of the recall application was justified.

Analysis: The recall application was directed against an order passed in the course of personal guarantor insolvency proceedings. The order under challenge had not reached final adjudication on the report of the Resolution Professional, and the applicant had already been afforded an opportunity to place a reply before the Resolution Professional. The authority below had only the limited power to correct clerical or arithmetical mistakes and not to sit in appeal over its own order or to undertake recall or review in the manner sought. Since the proceedings were still at a stage where the applicant could raise objections before the Resolution Professional, no interference was warranted.

Conclusion: The dismissal of the recall application was upheld, and the applicant was left to pursue objections before the Resolution Professional.

Ratio Decidendi: In proceedings under the Insolvency and Bankruptcy Code, the Adjudicating Authority has no power to recall or review its own order except to correct clerical or arithmetical mistakes, and objections should be pursued before the Resolution Professional at the appropriate stage.

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