Final criminal orders cannot be reopened by civil interim orders; section 362 bars review-like challenges after conviction.

A challenge to execution of a conviction under section 630 of the Companies Act, 1956 could not be reopened on the basis of later civil suit interim orders, because those orders did not negate the concluded criminal finding in the absence of any final civil adjudication. The court reiterated that section 362 of the Code of Criminal Procedure, 1973 bars a criminal court from reviewing or reopening a final order after it is signed, save for clerical or arithmetical correction. Repeated filings and suppression of earlier adverse orders were treated as abuse of process, and the challenge to the execution orders failed.

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Issues: Whether the revision petitions challenging execution of the conviction under section 630 of the Companies Act, 1956 could be entertained on the basis of civil court interim orders and the plea that the criminal orders were liable to be reviewed or reopened.

Analysis: The petitioner had already suffered conviction under section 630 of the Companies Act, 1956, and the conviction had been affirmed in prior proceedings. The Court held that the later civil suit and interim orders did not undo the criminal finding, particularly when there was no final adjudication by the civil court on the dispute. It further held that the attempt to reopen the concluded criminal orders was barred by section 362 of the Code of Criminal Procedure, 1973, as a criminal court becomes functus officio after signing its final order except for clerical or arithmetical correction. The repeated filings, coupled with suppression of earlier adverse orders, amounted to abuse of process of court.

Conclusion: The challenge to the execution orders was rejected and the revisions were dismissed; the petitioner was not entitled to reopen the concluded criminal proceedings on the basis of civil interim orders or by invoking review-like powers.

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