Inherent power to expunge irrelevant judicial remarks applies only in exceptional cases without disturbing the substance of the judgment.

Section 561A of the Code of Criminal Procedure preserves the High Court's inherent power to expunge remarks in a subordinate criminal court's judgment where the passages are wholly irrelevant, unjustified, and likely to cause serious harm, and where such relief is necessary to secure the ends of justice. That power is extraordinary and must be exercised with great caution, without affecting the verdict or reasons that form the substance of the judgment. On the facts, the remarks against the medical officer's report were not shown to be wholly unjustified or likely to cause irreparable harm, so expunction was not warranted.

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Issues: Whether the High Court, in exercise of its inherent powers, can expunge irrelevant and unjustified remarks made by a subordinate criminal court against a person who was not a party or witness to the proceeding, and whether such power could be invoked on the facts of the case.

Analysis: Section 561A of the Code of Criminal Procedure preserves the High Court's inherent power to make orders necessary to secure the ends of justice. That power does not create a new jurisdiction, but it does recognise an extraordinary authority which may be exercised where no express provision affords relief and where the impugned remarks are wholly irrelevant, without foundation, and likely to cause serious harm. The inviolability of a judgment extends to its integral parts, namely the verdict and reasons, but not to alien matter unnecessarily incorporated in it. Expunction of such irrelevant passages does not amount to altering the merits of the judgment. At the same time, the power must be used with great caution and only in exceptional cases so that judicial independence is not undermined. On the facts, the remarks characterising the medical officer's report as careless were not shown to be wholly unjustified or likely to cause irreparable harm.

Conclusion: The High Court had inherent power in appropriate cases to expunge such remarks, but this was not a fit case for its exercise.

Ratio Decidendi: A High Court has inherent power under Section 561A of the Code of Criminal Procedure to expunge only those remarks in a subordinate court's judgment that are wholly irrelevant, unjustified, and harmful, and only when such relief is necessary to secure the ends of justice without affecting the substance of the judgment.

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