The Competent Authority cannot modify a Deemed Conveyance certificate via corrigendum to adjudicate substantive property area disputes.

The Respondent No. 1 society obtained an order for Unilateral Deemed Conveyance on 4 May 2017 for land admeasuring 2625.84 sq. mtrs, including a "proportionate undivided share" in common areas and Recreational Ground (RG)

In 2026, Respondent No. 1 filed a "Miscellaneous Application" seeking to quantify this proportionate RG share as exactly 463.38 sq. mtrs to facilitate redevelopment

The Competent Authority (District Deputy Registrar) allowed the application on 12 January 2026, characterizing the change as a "corrigendum" to correct a clerical/arithmetical omission

The Petitioner Society and the Developer challenged this, arguing the Authority had no jurisdiction to substantively modify the conveyance after becoming functus officio

1. Whether the Competent Authority has the jurisdiction to issue a corrigendum modifying a Certificate of Deemed Conveyance after it has been executed and registered.

2. Whether the quantification of a proportionate share in a Recreational Ground (RG) constitutes a mere clerical correction or a substantive adjudication of rights.

The court applied the provisions of Section 11 of the Maharashtra Ownership Flats (Regulation of the Promotion of Construction, Sale, Management and Transfer) Act, 1963 (MOFA) regarding deemed conveyance

It relied on the principle of functus officio, established in Surya Corporation v. Competent Authority [2025 (2) Bom CR 780] and Kuber Kartik New Link Road Premises CHSL v. Sri. Krishna Premises Co-op Society, which holds that the Competent Authority cannot review or substantively modify its own orders under the guise of an amendment

While Jaywant Ramchandra Keni v. Competent Authority allows corrigendums for "obvious errors", the court also applied the limitation that such power does not extend to effective judicial orders or merits

The Court reasoned that once the 2017 Deemed Conveyance was issued, the Authority became functus officio

While the 2017 order granted a "proportionate" share in the RG, the 2026 order attempted to fix a specific numerical value (463.38 sq. mtrs)

The Court found this was not a clerical error but a "substantive adjudication" because the parties vehemently disputed the methodology of calculation—specifically, whether the RG should be divided based on "plot area" or "utilised built-up area/TDR"

Since the calculation involved complex disputes over TDR loading and land entitlements, the Authority exceeded its limited corrective jurisdiction by "entering into the realm of dispute adjudication"

The Court distinguished between an "undisputed numerical expression" (valid corrigendum) and a "contested re-adjudication" (invalid review)

The High Court set aside the Impugned Order dated 12 January 2026, holding that the Competent Authority lacked jurisdiction to substantively modify the conveyance through a corrigendum

The Court granted liberty to Respondent No. 1 to challenge the original 2017 order to seek proper reflection of its land entitlement. The Writ Petitions were allowed with no order as to costs