Criminal court review limits: inherent powers cannot reopen a finally disposed petition or bypass the statutory bar on review.

After a criminal petition is finally disposed of, the High Court becomes functus officio and cannot revive the matter through a later miscellaneous petition or issue fresh directions under Section 482 CrPC. The Code permits only correction of clerical or arithmetical mistakes after a final judgment or order; it does not confer a general power of review. Inherent powers cannot be used to circumvent this statutory bar or to pass orders beyond jurisdiction, especially without notice to affected parties. Fresh directions issued in these circumstances were liable to be quashed.

---

---

Issues: Whether the High Court could, after finally disposing of a criminal petition, entertain a subsequent miscellaneous petition and issue fresh directions by invoking inherent powers under the Code of Criminal Procedure.

Analysis: The Code does not confer any power of review on the criminal court after a judgment or final order has been signed, except for correction of clerical or arithmetical mistakes. Once the original petition was finally disposed of, the High Court became functus officio and could not revive the matter through a miscellaneous petition not traceable to any statutory provision. Inherent power under Section 482 is not available to do what the Code specifically prohibits, and it cannot be used as a cloak for review. Fresh directions issued without notice to affected parties and after final disposal were therefore beyond jurisdiction and amounted to an abuse of process.

Conclusion: The High Court had no jurisdiction to pass the impugned subsequent orders under Section 482, and those orders were liable to be quashed.

Ratio Decidendi: A criminal court, after signing its final judgment or order, cannot review or alter it except to correct clerical or arithmetical errors, and its inherent powers cannot be used to circumvent this statutory bar.

---