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Issues: (i) Whether the High Court can, in exercise of inherent powers, extend the time fixed in revision for payment of fine or compensation without offending the bar on alteration or review. (ii) Whether a post-revisional composition between the accused and the complainant can be accepted under inherent powers.
Issue (i): Whether the High Court can, in exercise of inherent powers, extend the time fixed in revision for payment of fine or compensation without offending the bar on alteration or review.
Analysis: The statutory scheme shows that the revisional court cannot alter or review a final judgment except to correct clerical or arithmetical errors, but the inherent power of the High Court survives to secure the ends of justice and prevent abuse of process. The Court distinguished a substantive alteration of the conviction or sentence from a limited enlargement of time for payment. It held that where the conviction and sentence remain intact and the extension is sought on genuine, pressing and exceptional grounds beyond the control of the accused, granting additional time does not amount to a prohibited review of the original revisional order.
Conclusion: Yes. In very exceptional circumstances, the High Court may extend the time for payment of fine or compensation under its inherent powers.
Issue (ii): Whether a post-revisional composition between the accused and the complainant can be accepted under inherent powers.
Analysis: Acceptance of a post-revisional composition would have the effect of undoing or altering the final revisional order itself, which is barred by the prohibition against review. The Court held that inherent powers cannot be used to achieve what the Code expressly forbids, and that such composition would effectively set aside the conviction or sentence already confirmed or modified in revision.
Conclusion: No. A post-revisional composition cannot be accepted under Section 482 of the Code of Criminal Procedure, 1973.
Final Conclusion: The reference was answered by permitting only a limited, exceptional extension of time for payment, while rejecting the use of inherent power to accept a post-revisional composition or otherwise reopen the final revisional order.
Ratio Decidendi: Inherent powers may be used to grant a narrow extension of time for payment of fine or compensation in exceptional circumstances without reviewing the substantive revisional order, but they cannot be used to accept a post-revisional composition or otherwise alter a final judgment barred by Section 362.