Power under Art. 129 and Art. 142 can suspend advocate licences or debar advocates, subject to self-limits

SC held that it can, in exercise of its powers under Art. 129 read with Art. 142, pass orders necessary to do complete justice, which may include debarring an advocate and suspending licence for a specified period, but subject to self-imposed limits. The Court emphasized Art. 142's remedial breadth while noting it cannot be used to treat contemners as ordinary litigating parties or to routinely override statutory provisions, except to balance equities and resolve matters before the Court to achieve complete justice.

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Issues: (i) Whether a writ petition under Article 32 can be maintained to challenge a final judgment/order of the Supreme Court after dismissal of a review petition; (ii) Whether, and on what grounds and procedure, the Supreme Court can entertain a curative petition in exercise of its inherent powers to re-consider a final judgment/order after dismissal of review.

Issue (i): Whether Article 32 writ jurisdiction is maintainable to question a final judgment/order of the Supreme Court after review has been dismissed.

Analysis: The analysis examines the character of writ jurisdiction, historical and precedent authority distinguishing supervisory writs addressed to inferior courts from jurisdiction over co-ordinate or superior Benches, and appellate/review remedies prescribed by the Constitution and Court rules. It considers prior decisions holding that judicial orders of superior courts are not amenable to writs under Article 32 and addresses authorities where final judgments of highest courts were revisited on distinct grounds.

Conclusion: Article 32 cannot be invoked to challenge a final judgment/order of the Supreme Court after dismissal of the review petition.

Issue (ii): Whether the Supreme Court, in exercise of its inherent or plenary powers, can re-consider a final judgment/order after dismissal of review and, if so, the permissible grounds and procedure for such curative petitions.

Analysis: The analysis considers constitutional provisions (Articles 129, 137, 142, 145), Supreme Court Rules (Order XL Rule 1; Order XLVII Rule 6), comparative authorities and precedents where the highest courts corrected their own orders for grave defects. It evaluates competing principles of finality and the duty to prevent irremediable injustice, identifies categories of defect that justify intervention (violation of natural justice affecting a non-notified party or failure to disclose a judge's connection creating apprehension of bias), and prescribes procedural safeguards to prevent abuse, including prior circulation to a bench of senior judges and certification by a Senior Advocate; it also permits imposition of exemplary costs for vexatious petitions.

Conclusion: The Supreme Court may, in the rarest of rare cases, exercise inherent or plenary powers to entertain a curative petition after dismissal of review where (a) principles of natural justice were violated in that the petitioner was not served or not a party yet the judgment adversely affected him/her, or (b) a judge failed to disclose a connection giving rise to an apprehension of bias and the judgment adversely affects the petitioner. Such curative petitions must aver that these grounds were taken in the review petition (dismissed on circulation), must be certified by a Senior Advocate, and shall first be circulated to a Bench of the three senior-most Judges including judges who passed the judgment complained of; only on a majority view of that Bench that hearing is warranted shall the matter be listed for hearing, with power to impose costs for frivolous petitions.

Final Conclusion: Article 32 is not a vehicle to challenge final Supreme Court judgments after review is dismissed; however, a limited curative mechanism under the Court's inherent/plenary powers exists for rare, narrowly defined defects (violation of natural justice or apparent bias) subject to strict procedural safeguards to prevent abuse.

Ratio Decidendi: The Supreme Court's inherent and plenary powers permit reconsideration of a final judgment in narrowly confined, exceptional circumstances to prevent irremediable miscarriage of justicespecifically where there is a proven violation of natural justice affecting a non-notified party or nondisclosure by a judge giving rise to apprehension of biasand such recourse is subject to prescribed procedural safeguards to protect finality and prevent abuse.

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