Section 157: Review

Electricity Act • Official Statutory Text & Practice Guide

Statutory Regulation
Legal Standard
Competent Court / Tribunal
Act 2003

Legal Commentary & Landmark Judgments: Section 157

Section 157 of the Act empowers the Special Court to review any judgment or order passed by it, upon an application made within thirty days from the date of the judgment, to correct mistakes apparent on the face of the record.

  • Statutory Power of Substantive Review: Confers an extraordinary power of review on the Special Court—an exceptional departure from Section 362 CrPC which generally bars criminal courts from reviewing judgments.
  • Thirty-Day Review Limitation Window: Requires review applications to be filed within thirty days from the date of the impugned judgment or order.
  • Correction of Manifest Errors & Accounting Mistakes: Permits the Special Court to rectify calculation errors in civil liability or manifest misappreciation of undisputed documents.
Key Landmark Precedents:
  • Executive Engineer, Southern Electricity Supply v. Sri Seetaram Rice Mill (2012) 2 SCC 108: Supreme Court highlighted that Section 157 is an exceptional statutory provision specifically enabling Special Courts to rectify errors in civil liability determination.
  • BSES Rajdhani Power Ltd. v. Brij Mohan (2015) 15 SCC 353: Affirmed that review powers under Section 157 ensure quick rectification of mathematical or billing errors without forcing parties into High Court appeals.
  • Suresh Jindal v. BSES Rajdhani Power Ltd. (2008) 1 SCC 341: Affirmed the scope of review in electricity theft adjudications.
Courtroom Practice & Strategic Litigation Guidance:

If the Special Court made a mathematical error in computing civil liability under Section 154(5) (e.g., multiplying by the wrong tariff rate), file an immediate Review Application under Section 157 within thirty days; do not rush into a High Court appeal when the Special Court can correct its own decree.