PRINCIPLE STATEMENT

A misdirection or error in law which is apparent on the face of a judgment must be distinguished from an accidental slip or clerical mistake in a judgment; whereas the former is appealable and cannot be remedied under the 'slip rule', the latter may, in appropriate cases, be corrected under this rule.

RATIO DECIDENDI (SOURCE)

Per Iguh, JSC, in Alao v. African Continental Bank Ltd (2000) NLC-141995(SC) at p. 48; Paras. C–E.
"A misdirection or error in law which is apparent on the face of a judgment must be distinguished from an accidental slip or clerical mistake in a judgment. Whereas the former is appealable and cannot be remedied under the 'slip rule', the latter may, in appropriate cases, be corrected under this rule."
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EXPLANATION / SCOPE

Critical distinction between substantive errors and clerical mistakes: Misdirection/error in law: Wrong legal principles applied, incorrect legal reasoning, misstatement of law or fact. These are: substantive errors, must be appealed (within time limits), cannot be corrected under slip rule, and become final if not appealed. Accidental slip/clerical mistake: Typographical errors, arithmetic mistakes, obvious transcription errors. These: may be corrected under slip rule, don’t require appeal, and can be fixed after judgment delivery. “Slip rule” permits: correcting clerical errors, arithmetic mistakes, and accidental slips—NOT substantive legal errors. This serves: distinguishing ministerial mistakes (correctable) from substantive errors (requiring appeal), preventing slip rule misuse to correct substantive errors, and maintaining finality while allowing obvious mistake correction. Examples: Correctable: wrong date typed, arithmetic error in damages calculation, name misspelled. Not correctable: wrong legal principle applied, misapplication of law, incorrect finding of fact. Parties cannot: use slip rule to correct legal errors, transform appeals into slip rule applications, or avoid appeal time limits through slip rule. This principle prevents: circumventing finality through slip rule, avoiding appeal limitations, and using slip rule for substantive changes while permitting genuine clerical correction.

CASES APPLYING THIS PRINCIPLE