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2026 Supreme(Online)(Del) 935

IN THE HIGH COURT OF DELHI AT NEW DELHI
Swarana Kanta Sharma, J
Satish Chand Sahrma – Appellant
Versus
State Of Nct Of Delhi – Respondent
CRL.M.C. 75/2026 | CRL.M.C. 89/2026



Advocates:
For the Appellants/Petitioners: Sachet Sharma
For the Respondents: Digam Singh Dagar, Ayush Sharma

A court has the inherent power to rectify clerical, typographical, or inadvertent errors in its own orders to ensure that the judgment accurately reflects the court's original decision and the parties' settlement.

Headnote:The application is filed to seek a modification of a prior court order dated 06.01.2026 due to a typographical omission. The court previously quashed FIRs based on a settlement between the parties but inadvertently failed to mention one of the specific FIRs in the operative portion of the order. The court, having found the error admitted due to inadvertent filing practices, clarified the record to correct the operative order. The main issue is whether a court has the inherent power to modify a clerical or typographical error in its previous order to reflect the original intent regarding the quashing of proceedings. The Court held that to secure the ends of justice and ensure that its record accurately reflects the decision to quash multiple FIRs settled between parties, it is appropriate to allow the modification of the order. The application is disposed of with the requested corrections incorporated into the previous order.

Table of Content
1. application for modification due to clerical errors in the judgment. (Para 1 , 2 , 4)
2. court's power to correct typographical omissions in operative sections of orders. (Para 3 , 5 , 6 , 7 , 8 , 9)

CRL.M.A. 580/2026 (for modification of order dated 06.01.2026)

1. By way of the present application, the applicant seeks modification of order dated 06.01.2026, passed by this Court in CRL.M.C. No. 75/2026 and CRL.M.C. 89/2026.

2. It is stated by the learned counsel for the petitioner that CRL.MC. No. 75/2026 was filed by the petitioner for quashing of FIR No. 1353/2014, registered for offence under Sections 376/506 of IPC at Police Station New Ashok Nagar, Delhi, and CRL.MC. No. 89/2026 was filed by the petitioners for quashing of FIR No. 1113/2014, registered for offence under Sections 3548/323/506/34 of IPC at Police Station New Ashok Nagar, Delhi, along with all consequential proceedings. It is stated that both the aforesaid petitions were heard together by this Court and were disposed of vide a common order dated 06.01.2026, whereby this Court was pleased to quash the FIRs in view of the settlement arrived at between the parties. It is also stated that due to an inadvertent and typographical omission, FIR No. 1353/2014, registered under Sections 376/506 of IPC at Police Station New Ashok Nagar, Delhi, which was the subject matter of CRL.MC.No. 75/2026, has been left out from being mentioned in the operative portion of the order, despite the fact that the said petition was also allowed by this Court. It is, therefore, prayed that the order dated 06.01.2026 passed in CRL.MC.No. 75/2026 & CRL.MC. No. 89/2026 be modified specifically recording that the FIR No. 1353/2014, registered for offence under Sections 376/506 IPC at Police Station New Ashok Nagar, Delhi, and all consequential proceedings emanating therefrom, stand quashed, in addition to FIR No. 1113/2014.

3. Heard.

4. In this case, clarification was sought from the Registry as to why the same PDF in both the aforesaid matters was provided by the Registry. The clarification of the Registry is set out below:

“....It is submitted that Mr. Ayush Sharma, Advocate filed two connected matters vide diary nos. 9212558/2025 and 9211718/2025 which is registered as CrIMC No.75/2026 and CrIMC No.89/2025 respectively.

It is further submitted that filing advocate inadvertently has filed same PDF in both aforesaid matters and the same are scrutinized by different scrutiny assistant.

In view of the above, the inconvenience caused to the Hon'ble Court is highly regretted and I shall be careful in future...”

5. Ordered accordingly.

6. The paragraph 3 and paragraph 9 of the order dated 06.01.21026 shall now read as under:

“....3. By way of the present petitions, the petitioners seek quashing of the FIR bearing No. 1113/2014, registered at Police Station New Ashok Nagar, Delhi, for the commission of offences punishable under Sections 323/509/506/354B/34 of the Indian Penal Code, 1860 (hereafter ‘IPC') and FIR bearing No. 1353/2014, registered under Sections 376/506 IPC at Police Station New Ashok Nagar, Delhi.

*** *** ***

9. Accordingly, FIR bearing No. 1113/2014, registered at Police Station New Ashok Nagar, Delhi, for the commission of offences punishable under Sections 323/509/506/354B/34 of IPC and FIR bearing No. 1353/2014, registered at Police Station New Ashok Nagar for the commission of offences punishable under Sections 376/506 of IPC, Delhi and all consequential proceedings emanating therefrom are quashed....”

7. No further order is required to be passed.

8. Accordingly, the present application stands disposed of.

9. The order be uploaded on the website forthwith.

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