Jurisdiction: correction of errors under the slip rule

Under section 57 of the Arbitration Act 1996 (often replicated by institutional arbitral rules) a tribunal has the right under the “slip rule” to make corrections in respect of clerical errors or omissions. Union Marine Classification Services LLC v Government of the Union of Comoros [2015] EWHC 508 (Comm) is a rather curious case in which the arbitrator did make amendments, but his right to do so was challenged on jurisdictional grounds under section 67 of the 1996 Act rather than on the basis of serious irregularity under section 68.

Eder J was thus required to consider the correct basis for a challenge to the amendments made to an award by an arbitrator under the slip rule.