Madhya Pradesh High Court
Administrative and Public LawCivil Procedure and Evidence

Authorities must consider rectification of bona fide name errors in mining permissions after hearing the applicant.

Shree Sawariya Stone Crusher Through Its Partner Vikram Singh Chauhan vs State Of M P Through Principal Secretary Departemnt Of Mines And Minerals

Madhya Pradesh High CourtJUDGMENT: September 11, 20262 MIN READSOURCE JUDGMENT
Authorities must consider rectification of bona fide name errors in mining permissions after hearing the applicant.. Shree Sawariya Stone Crusher Through Its Partner Vikram Singh Chauhan vs State Of M P Through Principal Secretary Departemnt Of Mines And Minerals. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner-firm applied for provisional permission (siddhantik anumati) for mining activities under the name “Shree Sawariya Stone Crusher.” However, owing to an inadvertent data-entry error in the online application, its name was recorded as “M/s Sawariya Stone Crusher.”

Source reference: paras. 1–2

The State thereafter issued the order dated 25 May 2026 granting approval in principle, but reproduced the incorrect name. The petitioner subsequently submitted an objection, affidavit, and representation dated 5 August 2026 seeking correction of the firm’s name, but the authorities did not take a decision.

Source reference: paras. 1–2, 4

The petitioner approached the High Court under Article 226 seeking correction of the name in the provisional-permission order.

Source reference: paras. 1–2, 4
02

Issues

Whether the petitioner was entitled to correction of the incorrect name recorded in the provisional-permission order where the error was allegedly inadvertent and inconsistent with the firm’s statutory registrations.

Source reference: paras. 1–2

Whether the respondent authorities were required to consider and decide the petitioner’s representation after providing it an opportunity of hearing.

Source reference: paras. 5–6
03

Law Applied

The Court exercised its jurisdiction under Article 226 of the Constitution to examine the petitioner’s grievance regarding administrative inaction and correction of an apparent clerical or data-entry error.

Source reference: para. 1

The Court applied the principle that an inadvertent mistake in an official document may be rectified by the competent authority where the error is bona fide and no other legal or factual complication is involved.

Source reference: para. 5

It also relied upon Balwant Singh v. State of M.P. & Others, W.P. No. 23143 of 2025, decided on 11 July 2025, where correction of a wrongly recorded name in mining-related documents was permitted.

Source reference: para. 3

The petitioner invoked Article 14 in challenging the alleged administrative inaction, although the Court ultimately disposed of the petition without recording a final finding on an Article 14 violation.

Source reference: para. 2
04

Reasoning

The Court found that the discrepancy between “Shree Sawariya Stone Crusher” and “M/s Sawariya Stone Crusher” appeared, prima facie, to be an inadvertent error in the online application and subsequent provisional-permission order.

Source reference: para. 5

In view of the petitioner’s assertion that its correct name was reflected in its firm registration, Income Tax registration, and other statutory permissions, and considering the analogous decision in Balwant Singh, the Court held that the request could be considered for rectification if no other complication existed.

Source reference: paras. 2–3, 5

Since the petitioner had already submitted a representation, the Court considered it appropriate to require the competent respondents to decide that representation in accordance with law, rather than itself ordering immediate alteration of the official record.

Source reference: para. 6
05

Holding

The petition was disposed of.

The respondent authorities were directed to duly consider the petitioner’s representation seeking correction of the firm’s name in the provisional-permission order, in accordance with law and after providing the petitioner an opportunity of hearing.

Source reference: para. 6

The Court did not itself direct automatic correction, leaving the final decision to the competent authority, subject to there being no other legal or factual complications.

Source reference: paras. 5–7
Madhya Pradesh High Court

Original Court PDF

Shree Sawariya Stone Crusher Through Its Partner Vikram Singh ChauhanvsState Of M P Through Principal Secretary Departemnt Of Mines And Minerals

Madhya Pradesh High Court · September 11, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment