Generally an application for correction of a typographer error or omission can be entertained by way of modification/recall application, but the application intending to review a judgment can only be entertained in the shape of review – State Bank of India Vs. Sunil Kumar Gupta – DRAT Allahabad Bench

The Hon’ble Supreme Court in Cine Exhibition Pvt. Ltd. Vs. Collector, District Gwalior, 2013 SCC 698 at paragraph no. 8 has held that generally an application for correction of a typographer error or omission can be entertained by way of modification/recall application, but the application intending to review a judgment can only be entertained in the shape of review. Undisputedly, the present application has not been filed for any typographical correction, but for the purpose of reopening the case, adducing additional evidence. Thus, such recall application is liable to be dismissed on this ground alone.(p8)

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