Inherent jurisdiction can support passport return despite the bar on review, where safeguards protect investigation availability.

Section 362 of the Code bars review or alteration of a signed judgment except for clerical correction, but it does not limit the High Court's inherent power under Section 482 to secure the ends of justice or give effect to orders under the Code. On that basis, the article explains that a High Court may direct return of a passport despite the bar on review, where the applicant undertakes to appear for interrogation, return within a fixed period, furnish enhanced bail bonds, and provide itinerary details to address concerns about availability during investigation. The relief is described as maintainable subject to those safeguards.

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Issues: Whether the High Court could exercise its inherent jurisdiction to direct return of the petitioner's passport notwithstanding the bar against review or alteration of a signed judgment.

Analysis: Section 362 of the Code prohibits review or alteration of a signed judgment except to correct clerical errors, but that restriction does not curtail the High Court's inherent powers under Section 482 of the Code. Those powers may be used to give effect to orders under the Code or to secure the ends of justice. The petitioner's undertaking to appear for interrogation, return within a fixed period, furnish enhanced bail bonds, and supply itinerary details addressed the apprehension that he might not be available during the investigation.

Conclusion: The petition was maintainable and the High Court could direct return of the passport in exercise of its inherent powers; the relief was granted in favour of the petitioner.

Final Conclusion: The order recognizes that the inherent jurisdiction of the High Court is not defeated by the limitation on review contained in Section 362, and it permits release of the passport subject to compliance with the directed safeguards.

Ratio Decidendi: Section 362 does not restrict the High Court's inherent powers under Section 482, and those powers may be exercised to secure the ends of justice despite a prior order of the trial court.

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