Madhya Pradesh High Court

Correction of clerical errors in judicial orders involving inadvertent substitution of unrelated case facts.

Kuldeep Rajawat vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: June 25, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner originally sought bail in M.Cr.C. No. 22830 of 2026. On 18.06.2026, the High Court passed an order granting bail; however, that order inadvertently recorded facts pertaining to a different case involving the NDPS Act (6.6 kg of Ganja).

Source reference: p. 1

In reality, the petitioner’s case concerned a "bail jump" arising from Crime No. 113/2020 at P.S. Endori, District Bhind, involving Sections 399, 400, and 402 of the IPC and Sections 11/13 of the MPDVPK Act.

Source reference: p. 2

The petitioner moved the present application (M.Cr.C. No. 29962 of 2026) seeking correction and modification of the clerical errors in the previous order.

Source reference: p. 1-2
02

Issues

1. Whether the typographical and clerical errors in the order dated 18.06.2026, which misstated the facts and applicable statutes of the petitioner's case, merit rectification in the interest of justice.

Source reference: p. 2, para. 2
03

Law Applied

The court exercised its inherent power to correct clerical and typographical errors in judicial records to ensure the record reflects the actual proceedings of the case.

Source reference: p. 2, para 3

Regarding the substantive bail, the court applied Section 439 of the Cr.P.C. (alternatively Section 483 of the BNSS) concerning the grant of bail, alongside the provisions of the Madhya Pradesh Dakaiti Aur Vyapharan Prabhavit Kshetra (MPDVPK) Act and the Indian Penal Code (IPC).

Source reference: p. 2, para 3
04

Reasoning

The Court acknowledged that the order dated 18.06.2026 contained significant "typographical and clerical" errors where the details of an NDPS case were erroneously substituted for the petitioner’s actual charges under the MPDVPK Act and IPC.

Source reference: p. 2

Upon reviewing the submissions, the Court found it necessary to substitute the incorrect facts with the actual circumstances: that the petitioner had previously been granted bail but failed to appear on 07.11.2023, leading to his arrest via production warrant.

Source reference: p. 2-3

The Court reasoned that since the investigation was complete and the petitioner undertook to abide by strict conditions—including weekly reporting to the police station—he was entitled to bail despite the previous "bail jump".

Source reference: p. 3-4
05

Holding

The Court allowed the petition for modification and directed that the order dated 18.06.2026 be read with the corrected facts and conditions.

Holding that the applicant is entitled to bail, the Court ordered his release on a personal bond of Rs. 50,000/- with one solvent surety. The Court imposed specific conditions, including a requirement for the applicant to mark his presence at P.S. Endori every Sunday and a warning that any future "bail jump" or involvement in similar offences would result in automatic cancellation of the bail.

Source reference: p. 3; p. 4, para 7-9
Madhya Pradesh High Court

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Kuldeep RajawatvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · June 25, 2026

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