High Court lacks jurisdiction to review judgments once signed, affirms Supreme Court; Section 369 applies universally

The Supreme Court held that the High Court lacked jurisdiction to review its own judgment, emphasizing that Section 369 of the Criminal Procedure Code prohibits courts from altering judgments once signed, except for correcting clerical errors. The Court also found that the enhancement of sentences from fines to imprisonment was valid as the respondents were given proper notice. It clarified that Section 369 applies universally to all courts, including appellate jurisdictions, preventing the High Court from reviewing its judgments. The appeal was allowed, affirming the application of Section 369 and upholding the validity of the sentence enhancement.

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Issues Involved:
1. Jurisdiction of High Court to review its own judgment.
2. Validity of enhancement of sentence without proper notice.
3. Applicability of Section 369 of the Criminal Procedure Code to appellate judgments.

Issue-wise Detailed Analysis:

1. Jurisdiction of High Court to Review its Own Judgment:
The primary issue was whether the High Court had the jurisdiction to review its own judgment. The State of Orissa contended that the High Court had no such jurisdiction, while the respondents argued that Section 561A of the Criminal Procedure Code provided the High Court with inherent powers to review its own decisions. The judgment clarified that Section 369 of the Criminal Procedure Code prohibits all courts, including the High Court, from altering or reviewing their judgments once signed, except to correct clerical errors. The inherent power under Section 561A does not extend to reviewing judgments, as it is meant to prevent abuse of process and secure the ends of justice, but not to override specific prohibitions in the Code. Thus, the High Court's order to review its own judgment was deemed without jurisdiction.

2. Validity of Enhancement of Sentence Without Proper Notice:
The respondents argued that they were not given proper notice regarding the enhancement of their sentences from fines to imprisonment. The High Court had initially enhanced the sentences based on a reference from the Sessions Judge, but later reviewed its decision and reverted to fines. The Supreme Court found that the notice issued by the High Court clearly indicated that the respondents were to show cause why their sentences should not be enhanced. Therefore, the High Court's conclusion that the notice did not cover enhancement to imprisonment was not supported by the record. The Supreme Court held that the respondents were given adequate notice, and the High Court's initial enhancement of sentences was valid.

3. Applicability of Section 369 of the Criminal Procedure Code to Appellate Judgments:
The respondents contended that Section 369 applied only to trial courts and not to appellate judgments. The Supreme Court examined the provisions of Sections 369, 424, and 430 of the Criminal Procedure Code. It concluded that Section 369 is general in its application and applies to all courts, including the High Court, in both original and appellate jurisdictions. The prohibition against altering or reviewing a judgment once signed applies universally, except as provided by the Code or other laws. The Supreme Court rejected the argument that Section 369 is limited to trial courts, affirming that it also applies to appellate judgments, thereby prohibiting the High Court from reviewing its own judgments.

Conclusion:
The Supreme Court allowed the appeal, holding that the High Court had no jurisdiction to review its own judgment and that the enhancement of sentences was valid as proper notice had been given. The judgment reinforced the applicability of Section 369 to all courts, including the High Court, in both original and appellate jurisdictions, thereby prohibiting any review or alteration of judgments once signed, except for correcting clerical errors.

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