Section 362 CrPC limits review powers, and PMLA's overriding bail framework blocks recall or conversion of the warrant.

Section 362 CrPC bars alteration or review of a judgment or order except to correct clerical or arithmetical mistakes, so a request to convert or recall a warrant cannot be entertained as a form of modification. In proceedings under the Prevention of Money-Laundering Act, 2002, the special statute's scheme under Sections 45 and 71 gives it overriding effect, and the general bail-related provisions of the criminal procedure law cannot be used to obtain relief inconsistent with that framework. On that basis, the prayer to vary the earlier order and secure recall or conversion of the warrant was rejected.

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Issues: Whether the warrant issued under Section 70(2) of the Code of Criminal Procedure, 1973 could be converted into a bailable warrant or otherwise recalled or modified, and whether the embargo under Section 362 of the Code of Criminal Procedure, 1973 prevented such modification in proceedings arising under the Prevention of Money-Laundering Act, 2002.

Analysis: The Court noted that Section 362 of the Code of Criminal Procedure, 1973 bars alteration or review of a judgment or order save for clerical or arithmetical mistakes. It further held that the scheme of Sections 45 and 71 of the Prevention of Money-Laundering Act, 2002 gives the special statute overriding effect and that the bail-related provisions of the general criminal procedure law do not assist the petitioners in the manner sought. The request was, in substance, a prayer to vary the earlier order and to secure relief inconsistent with the statutory framework governing the proceedings.

Conclusion: The prayer for converting or recalling the warrant was rejected and the petition was dismissed.

Ratio Decidendi: An order cannot be reviewed or altered under Section 362 of the Code of Criminal Procedure, 1973 except to correct clerical or arithmetical errors, and where the special statute contains an overriding bail regime, the general procedural provisions cannot be invoked to secure a contrary result.

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