Unqualified judicial record of consent is conclusive and cannot be modified through subsequent written submissions.

The Petitioner (SEPC) sought a review of the Tribunal's judgment dated 27.01.2025.

During earlier proceedings on 07.11.2024, the Petitioner’s counsel gave unqualified consent to Items 2 and 3 of an interim arrangement proposal regarding imported coal procurement indices.

These items stipulated that if no agreement was reached on coal costs, the price would not exceed the cheapest of the Argus indices (API3, API5, ICI2, and ICI3).

Subsequent to this consent, the Petitioner filed written submissions on 19.12.2024, claiming their consent was "qualified" and based on a different formula—the cheapest of (i) API3, API5, ICI2 or (ii) the average of all four indices.

The Petitioner argued that Para 37 of the final judgment erroneously relied on the 07.11.2024 recording rather than their later written "clarification".

1. Whether a party can seek review of a judgment based on a "clarification" or "qualification" of consent provided in written submissions that contradicts an unqualified consent previously recorded in judicial proceedings.

2. Whether the judgment dated 27.01.2025 suffered from an error apparent on the face of the record by adhering to the recorded proceedings of 07.11.2024 instead of the Petitioner's subsequent written submissions.

The Tribunal applied the principle of finality of judicial records as established in *State of Maharashtra v. Ramdas Shrinivas Nayak*, which holds that statements of fact recorded by Judges regarding what transpired in court are conclusive and cannot be contradicted by affidavits or statements from the Bar.

It further considered *Compack Enterprises India Private Limited v. Beant Singh*, noting that while courts may rectify clerical or arithmetical errors in consent decrees, they are slow to unilaterally modify terms unless the compromise was vitiated by fraud, mistake, or misrepresentation.

The Tribunal reasoned that the Petitioner never challenged the accuracy of the 07.11.2024 order through a rectification application while the matter was fresh, which is the only legally recognized method to correct a judicial record.

The Tribunal found that the Petitioner’s oral consent on 07.11.2024 was "unqualified" and "unconditional".

It rejected the attempt to use written submissions—filed weeks later—to "wriggle out" of a recorded concession, noting that oral arguments often involve strategic concessions not found in written briefs.

Since the Petitioner did not claim the 07.11.2024 record was factually erroneous or a result of a clerical slip, there was no "error apparent on the face of the record" to satisfy the narrow requirements of review jurisdiction.

The Review Petition was dismissed, and the Tribunal confirmed that Para 37 of the original judgment, based on the parties' consent, remained valid.

All miscellaneous applications were also dismissed.