the Tribunal may alter the text of the decision or statement.

The following are examples of obvious errors in the text of a decision or statement:

(a) an obvious clerical or typographical error in the text of the decision or statement;

(b) an inconsistency between the decision and the statement of reasons for the decision.

1. The narrowness of the power to alter conferred by s 114 is reflected in both the Tribunal's practice directions and the case law.
2. The Administrative Review Tribunal (Common Procedures) Practice Direction 2024 relevantly states:

8.1 Once the Tribunal has made a decision which finally determines all outstanding issues in a matter, the Tribunal no longer has the power to make any further orders. However, if a party becomes aware of any obvious error in the text of a decision or statement of reasons, the party should bring that error to the attention of the Tribunal. > > 8.2 Where the Tribunal has given reasons for its decision in accordance with the Act, the Tribunal will not provide any further explanation of the decision.

3. The Federal Court has noted that the predecessor to s 114, s 43AA in the Administrative Appeals Tribunal Act 1975 (Cth) ('AAT Act'), permits changes to matters of expression, or inconsistency or error in calculation.[1] It does not authorise substantive changes either to the decision itself or the reasons for the making of that decision.[2]
4. The applicant has provided submissions dated 2 September 2025 setting out matters which he says are obvious errors that ought to be corrected. The applicant lists 51 matters that he says warrant correction. It would be inappropriate for me to comment on the errors alleged to have been made, as it would amount to providing further explanation for the decision. Having reviewed the submissions I am satisfied that all of the 51 matters identified are not errors of a kind that are correctable utilising s 114. They are not 'obvious errors' in the required sense and are contestable questions of fact, law and procedure. Section 114 does not confer power to make the changes the applicant seeks.
5. I have therefore declined to exercise the power in s 114 to alter the text of the decision.

[1] Comcare v Moon [2003] FCA 569; (2003) 75 ALD 160, [65].

[2] Civil Aviation Safety Authority v Central Aviation Pty Ltd [2009] FCAFC 137; (2009) 179 FCR 554, [62].