Grindlays Bank Ltd vs Central Government Industrial ... on 12 December, 1980
48. The distinction between these two jurisdictions has been judicially recognized in Grindlays Bank Ltd. v. Central Government Industrial Tribunal, wherein it was explained that though a power of substantive review must arise from statute, every judicial or quasi-judicial authority nevertheless possesses inherent jurisdiction to correct procedural errors, misconceptions, or inadvertent mistakes attributable to the adjudicatory process itself. Procedural review inheres in every forumex debito justitiae and may legitimately be exercised where the earlier order suffers from procedural misconception or from a palpably erroneous order passed under a misapprehension by the authority itself.