Inherent criminal court powers cannot be used to review final orders, except for clerical or arithmetical corrections.

Section 362 of the Code of Criminal Procedure bars a criminal court from reviewing or altering a signed final order, except to correct a clerical or arithmetical error. An application framed as a clarification request cannot be used to obtain substantive reconsideration of an earlier final order, including a declaration that it does not bind a party or affect possession. The saving of inherent power under Section 482 does not override this express statutory prohibition, and the exception in Section 362 operates only where some other provision of the Code or other law expressly permits alteration or review. The High Court therefore had no jurisdiction to entertain the application.

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Issues: Whether the High Court could entertain an application styled as one for clarification and, in substance, review or alter its earlier final criminal order by invoking inherent powers under the Code of Criminal Procedure.

Analysis: Section 362 of the Code of Criminal Procedure bars a court from altering or reviewing a signed judgment or final order, except to correct a clerical or arithmetical error. The relief sought was not a correction of any accidental slip, mistake in writing, or error in calculation, but a substantive declaration that the earlier restoration order did not bind the applicant and did not affect her possession. Such relief amounted to reopening the final order on merits. The saving of inherent power under Section 482 does not authorise a court to do what the Code expressly prohibits, and the saving clause in Section 362 applies only where some other provision of the Code or other law expressly permits alteration or review.

Conclusion: The High Court had no jurisdiction to entertain the application, and the refusal to do so was correct.

Ratio Decidendi: The inherent power of a criminal court cannot be used to review or alter a final order where the Code expressly prohibits such review, except for correction of clerical or arithmetical errors.

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