Inherent powers cannot override the statutory bar on review of a signed criminal judgment or final order.

Section 362 of the Code of Criminal Procedure creates an absolute bar on altering or reviewing a signed judgment or final order, except for clerical or arithmetical correction. Section 482 inherent powers cannot be used to do what the Code expressly forbids, including reopening the merits of a final order or restoring an order already set aside. The Supreme Court therefore held that the High Court lacked jurisdiction to modify its earlier final order under Section 482, and the impugned modification order was set aside.

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Issues: Whether the High Court could invoke its inherent powers under Section 482 of the Code of Criminal Procedure, 1973 to alter or review a judgment after it had been signed, notwithstanding the bar under Section 362 of the Code of Criminal Procedure, 1973.

Analysis: Section 362 creates an absolute prohibition against alteration or review of a signed judgment or final order, save for correction of clerical or arithmetical errors. The inherent power under Section 482 is only to give effect to orders under the Code, prevent abuse of process, or secure the ends of justice, and cannot be used to do what the Code expressly forbids. Once review is barred, the Court cannot resort to inherent powers to reconsider the merits and revive an order that had been set aside.

Conclusion: The High Court had no jurisdiction to alter or review its earlier final order under Section 482; the impugned order was unsustainable and was set aside.

Final Conclusion: The appeal succeeded and the order passed by the High Court on the modification application was quashed, restoring the legal position that inherent powers cannot override the statutory bar on review.

Ratio Decidendi: The inherent power of the High Court under Section 482 of the Code of Criminal Procedure, 1973 cannot be exercised to review or alter a signed judgment or final order when Section 362 of the Code of Criminal Procedure, 1973 expressly prohibits such review or alteration.

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