Functus officio and qualifying service rules barred reopening a final writ and claiming pensionary relief without eligibility

A court becomes functus officio once a writ petition has been finally disposed of, so its inherent power under Section 151 CPC cannot be used to reopen the matter or grant relief on a fresh or concluded cause. On the service-law issue, pensionary entitlement depended on completion of twenty years' qualifying service before voluntary retirement, and prior military service was confined to the limited purposes permitted by the rules. As the respondent had not completed the required qualifying service, the pensionary relief granted under the impugned order was not sustainable.

---

---

Issues: Whether the High Court could grant pensionary relief in an application under Section 151 of the Code of Civil Procedure, 1908 filed in a writ petition that had already been finally dismissed, and whether the respondent was entitled to pension without completing the prescribed qualifying service.

Analysis: The earlier writ petition had been finally disposed of, leaving nothing pending before the High Court. Once a proceeding has attained finality, the court becomes functus officio and its inherent powers under Section 151 cannot be used to reopen the matter or grant relief on a fresh or concluded cause. On the merits, the governing service rule required completion of twenty years' qualifying service before voluntary retirement for pensionary entitlement. The respondent had not completed that qualifying service, and the benefit of military service had already been confined to the limited purposes recognized by the rules.

Conclusion: The High Court had no jurisdiction to entertain the application under Section 151, and the respondent was not entitled to the pensionary relief granted by the impugned order.

---