Modification of consent judgment/decree is not permissible when not vitiated by fraud, misrepresentation or a patent or obvious mistake. Application seeking modification of consent judgment/decree filed under S. 152 must be dismissed, even on considering such application as one under proviso to Or. 23 R. 3 r/w S. 151, when it did not meet the requirements of law. Further correspondence between the advocates for the parties who were experts in law showed that there was no ambiguity or lack of clarity giving rise to any misunderstanding.
[Ajanta LLP v. Casio Keisanki Kabushiki Kaisha, (2022) 5 SCC 449]