Arbitration award correction limited to clerical or accidental errors; deliberate omission cannot be revised under the correction power.

Section 15(c) of the Arbitration Act, 1940 permits correction only of clerical mistakes, accidental slips or trivial omissions, not deliberate decisions affecting the substance of an award. Reading the award as a whole, the court found that the amount said to have been awarded twice was first noticed under one claim but consciously deferred and later granted under another claim. The earlier omission was therefore intentional, not inadvertent, so no clerical error or accidental slip was made out. The request to correct the award was rightly rejected.

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Issues: Whether the award disclosed a clerical mistake or an error arising from an accidental slip or omission so as to justify correction under section 15(c) of the Arbitration Act, 1940.

Analysis: The claim that the amount of Rs. 46,649 had been awarded twice was rejected on a reading of the award as a whole. The amount was noticed while dealing with one claim, but the arbitrator consciously postponed its grant and later awarded it separately under another claim. The omission at the earlier stage was therefore deliberate and not inadvertent. A correction under section 15(c) is confined to clerical errors, accidental slips, and omissions of a trivial or mechanical nature, and does not extend to matters involving the substance, reasoning, or design of the award.

Conclusion: No clerical mistake or accidental slip or omission was made out. The request to correct the award was rightly rejected.

Ratio Decidendi: Section 15(c) of the Arbitration Act, 1940 permits correction only of mechanical or inadvertent errors and not of deliberate decisions affecting the substance of the award.

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