Inherent criminal jurisdiction cannot reopen a finally decided case; the proper remedy was appeal, not rehearing under Section 561A.

Section 561A of the Code of Criminal Procedure, 1898 preserves the High Court's inherent power to secure justice and prevent abuse of process, but it cannot be used to reopen a criminal matter already finally and lawfully decided by the same High Court in appellate or revisional jurisdiction. The proper remedy against an allegedly erroneous revisional order was an appeal to the Supreme Court, not a fresh rehearing under inherent powers. A later order in connected proceedings involving co-accused did not justify reopening the petitioner's own case, and Section 369 also barred alteration or review of a signed judgment save for clerical correction. The application was therefore not maintainable and was dismissed.

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Issues: Whether the High Court's inherent powers under Section 561A of the Code of Criminal Procedure, 1898 could be invoked to reopen and re-hear a criminal case finally decided by the High Court itself.

Analysis: Section 561A preserves the inherent power of the High Court to make orders necessary to secure the ends of justice or prevent abuse of process, but it does not authorise reopening a case that has been finally and legally decided by the High Court in exercise of its appellate or revisional jurisdiction. If the petitioner considered the earlier revisional order erroneous, the proper course was to pursue an appeal to the Supreme Court. The later order passed in the connected proceedings concerning co-accused did not provide a basis for re-hearing the petitioner's own case, which had not been dealt with in that judgment. Section 369 of the Code also prevents a court from altering or reviewing its signed judgment except to correct a clerical error.

Conclusion: The application under Section 561A was not maintainable and was rightly dismissed.

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