Rectification jurisdiction is limited to patent record errors; a different precedent or uncited prior order does not justify recall.

Rectification jurisdiction is confined to correcting a patent error apparent from the record; it cannot be used to recall an appellate order merely because a later distinction of an earlier Supreme Court ruling is relied on. The Tribunal held that an order does not become void or a nullity on that basis, and that an overlooked earlier order or a different view taken in another uncited case does not itself establish an apparent mistake. On that reasoning, no error apparent from the face of the record was shown and the rectification application was rejected.

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Issues: Whether the rectification application disclosed any error apparent from the face of the record warranting recall of the earlier order.

Analysis: The Tribunal held that reliance on a later distinction of an earlier Supreme Court decision did not make the original appellate order void or a nullity. It further noted that overlooking its own earlier order or taking a different view in another case, when that case was not cited, did not establish an apparent mistake justifying rectification.

Conclusion: No error apparent from the face of the record was made out, and the rectification application was rejected.

Ratio Decidendi: An order cannot be recalled under rectification jurisdiction merely because a different precedent or an uncited prior decision exists; only a patent error apparent from the record can justify such relief.

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