Correction of accidental slips cannot be used to substitute a Tribunal’s reasoned decision with a party’s preferred conclusion.

The Appellate Tribunal for Electricity (APTEL) had previously passed an order on April 20, 2026, quashing the Lt. Governor of Delhi's approval (dated March 5, 2026) to conduct a CAG audit of two Delhi Discoms (Applicants/Respondents 32 and 33).

The Applicants filed IA No. 899/2026 seeking to "correct" paragraph 39 of that order, arguing it contained an accidental slip and should instead quash the DERC’s initial request for the audit rather than just the Lt. Governor’s approval.

Additionally, in IA No. 1041/2026, the Applicants sought directions for the DERC to initiate the liquidation of Regulatory Assets (RA) with carrying costs, alleging the Commission failed to comply with the Tribunal’s earlier deadline of May 11, 2026.

1. Whether the prayer to substitute the Tribunal’s conclusion regarding the CAG audit qualifies as a correction of an "accidental slip or error" under Section 152 of the CPC or Rule 30 of the APTEL Rules.

2. Whether further directions are required to compel the DERC to commence liquidation of Regulatory Assets given the expiry of the previous three-week deadline.

The Tribunal applied Section 120 of the Electricity Act, 2003, read with Section 152 of the Code of Civil Procedure (CPC), 1908, and Rule 30 of the APTEL Rules, 2007, which permit the correction of clerical or arithmetical mistakes and accidental slips in judgments.

Substantively, it relied on Section 20 of the Comptroller and Auditor General's (Duties, Powers and Conditions of Service) Act, 1971, regarding the statutory requirements for entrusting audits to the CAG.

It further exercised its supervisory jurisdiction under Section 121 of the Electricity Act to oversee the timely liquidation of regulatory assets.

Regarding IA No. 899/2026, the Tribunal found that the Applicants were not seeking to correct a clerical error but were attempting to substitute the Tribunal’s judicial "decision/conclusion" with their own preferred wording.

The Tribunal clarified that its decision to quash the Lt. Governor’s approval (and not the DERC's initiation) was "conscious, considered and reasoned," as the legal grievance only ripened upon the Lt. Governor’s communication on March 5, 2026.

Regarding IA No. 1041/2026, the Tribunal acknowledged the DERC’s "recalcitrance" in failing to meet the May 11 deadline.

However, it noted that a separate order in Review Petition No. 8 of 2026 had already extended and fixed a firm start date of June 16, 2026, for the liquidation process, rendering further directions in this specific application redundant at this stage.

IA No. 1041/2026 was disposed of without further orders, but with a specific direction that the DERC must begin the liquidation of regulatory assets by June 16, 2026.

The Applicants were granted liberty to approach the Tribunal again if the Commission fails to commence liquidation by the new stipulated date.