### Executing Court May Interpret and Clarify Ambiguities to Ensure Effective Enforcement of Decrees

The Respondents filed complaints before the NCDRC under Section 21(a)(i) of the Consumer Protection Act, 1986, alleging deficiency in service and delayed possession regarding a redevelopment project.

On 08.12.2021, the NCDRC found the Appellant liable for shortage in carpet area and directed compensation at ₹24,650/- per sq. ft.

The Appellant’s subsequent appeals to the Supreme Court and Review Applications before the NCDRC were dismissed or withdrawn.

During execution, the NCDRC passed an order on 23.08.2024 specifying the exact shortage area based on the record to facilitate payment.

The Appellant challenged this execution order via Writ Petitions, which were dismissed by a Single Judge on 23.01.2026.

The Appellant then filed these Letters Patent Appeals (LPA).

Whether an execution order specifying the exact quantum of shortage in carpet area constitutes an impermissible relief beyond the scope of the original decree if the operative part of the main order was silent on the exact measurement.

Whether the Executing Court has the power to interpret or clarify ambiguities in a final order to ensure effective enforcement.

The Court applied the settled principle of law regarding the powers of an Executing Court, which empowers the court to interpret, clarify, and resolve questions relating to execution and ambiguities to ensure effective enforcement without going behind the decree or altering substantive rights.

It also considered the finality of judgments under the Consumer Protection Act, 1986, noting that issues already litigated in review/appeal stages cannot be reopened in execution proceedings.

The Court rejected the Appellant's contention that the order dated 08.12.2021 was inexecutable due to the absence of specific measurements in the operative portion.

The Court reasoned that the Appellant had already exhausted challenges against the main order through the Supreme Court, Review Applications, and previous Writ Petitions, all of which failed to set aside the finding of "shortage of area".

The Court observed that the NCDRC's order dated 23.08.2024 did not travel behind the decree but merely clarified it by specifying the exact shortage based on the Respondents’ submissions and the case record.

Since the liability was already established in the final order, the Executing Court was within its jurisdiction to resolve the administrative ambiguity (the exact square footage) to ensure the decree was not rendered a "dead letter".

The Court affirmed that an Executing Court is competent to clarify ambiguities to achieve effective enforcement.

The Impugned Order of the Single Judge was upheld, and no costs were awarded.