Section 420 rectification is limited to apparent errors and cannot be used for substantive review of a concluded order.

Section 420 of the Companies Act, 2013 empowers the Tribunal to amend its own order within two years only to rectify a mistake apparent from the record. That power is limited to obvious errors and cannot be used as a substitute for review or for reappreciation of the merits of a concluded order. An application styled as rectification but seeking substantive reconsideration falls outside the provision's scope. Accordingly, an application under Section 420 seeking recall or review of an order was held not maintainable, and refusal to recall the earlier order was upheld.

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Issues: Whether an application by a party under Section 420 of the Companies Act, 2013 seeking recall or review of an order was maintainable, and whether the provision permits reconsideration on merits beyond rectification of a mistake apparent from the record.

Analysis: Section 420 confers power on the Tribunal to amend its own order within two years to rectify a mistake apparent from the record. That power is confined to obvious errors and cannot be used as a substitute for review or for reappreciation of the merits of a concluded order. The provision is not available as an independent remedy to a party seeking substantive reconsideration of an order already passed on merits, and an application styled as rectification but seeking review in substance falls outside its scope.

Conclusion: The application was not maintainable and the refusal to recall the earlier order was ; the challenge failed.

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