Inherent powers cannot recall an order when appellate or set-aside remedies exist, absent fraud on the court.

Inherent powers cannot be used to recall an order where the statute provides an express appellate or set-aside remedy, except in cases of fraud on the court or similar exceptional abuse of process. The Board held that it had no review jurisdiction after deletion of the review provision, and its inherent power was limited to preventing abuse of process or addressing fraud on the court. As the applicant had alternative remedies and no fraud was shown, the recall application was not maintainable.

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Issues: Whether the application seeking recall of the earlier order was maintainable.

Analysis: The Board held that it had no review jurisdiction after the deletion of the review provision, and that its inherent power could be exercised only to prevent abuse of process or to address fraud on the court. Since the applicant had an appellate remedy and a set-aside remedy, and the circumstances did not disclose fraud on the court, the invocation of inherent powers to recall the earlier order was not justified.

Conclusion: The application for recall was not maintainable and was dismissed.

Ratio Decidendi: Inherent powers cannot be used to recall an order where the statute provides an express appellate or set-aside remedy, except in cases of fraud on the court or similar exceptional abuse of process.

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