Final criminal revision orders cannot be reviewed under inherent powers when the Code expressly bars alteration.

Section 362 of the Code of Criminal Procedure bars a court from altering or reviewing a signed judgment or final order, except to correct clerical or arithmetical errors. The provision reflects the functus officio principle: once a matter is finally disposed of, the court cannot reopen it unless a specific statutory power permits further interference. The inherent power under Section 482 cannot be used to override this express prohibition. A summary dismissal of a revision after hearing the petitioner or counsel remains a final adjudication, and the matter cannot be revived merely because notice was not issued to the other side.

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Issues: Whether the High Court could review or alter its earlier order dismissing a criminal revision petition and entertain a fresh revision on the same matter.

Analysis: Section 362 of the Code of Criminal Procedure bars a court from altering or reviewing a signed judgment or final order, except to correct clerical or arithmetical errors. The provision embodies the principle that once a matter has been finally disposed of, the court becomes functus officio in respect of that matter unless a specific statutory provision authorises further alteration or review. The inherent power under Section 482 cannot be used to do what the Code expressly prohibits. A summary dismissal of a revision after hearing the petitioner or his counsel is still a final adjudication and not something that can be reopened merely because no notice was issued to the other side.

Conclusion: The earlier dismissal order was a final order and could not be reviewed or altered; the fresh revision was not maintainable.

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