Inherent criminal revision powers survive finality only for exceptional intervention to prevent abuse of process and secure justice.

Section 561-A of the Code of Criminal Procedure preserves the High Court's existing inherent jurisdiction and does not create a new power. The Court ordinarily becomes functus officio after signing its criminal revision judgment, reflecting the principle of finality in criminal proceedings. However, that finality does not bar exceptional intervention where the earlier order was made without jurisdiction, involved a mandatory legal error, or rested on a misapprehension of facts. In such cases, the High Court may revoke, review, recall, alter, or rehear its earlier revisional decision only to prevent abuse of process, give effect to an order under the Code, or otherwise secure the ends of justice.

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Issues: Whether the High Court has power to revoke, review, recall or alter its own earlier decision in a criminal revision and rehear the same, and if so, in what circumstances.

Analysis: Section 561-A of the Code of Criminal Procedure preserves the High Court's inherent power and does not confer a new power, but it protects existing inherent jurisdiction where no specific provision of the Code covers the matter and where exercise of power is necessary to give effect to an order under the Code, to prevent abuse of process, or otherwise to secure the ends of justice. The principle of finality applies to criminal judgments, including revisional orders, and the Court ordinarily becomes functus officio once its criminal revision judgment is signed. Even so, the finality rule does not exclude the High Court's inherent jurisdiction in exceptional cases, particularly where the earlier order was made without jurisdiction, under a mandatory legal error, or on a misapprehension of facts, so that interference is necessary to prevent injustice.

Conclusion: The High Court does have inherent power to revoke, review, recall or alter its earlier decision in a criminal revision and to rehear the matter, but only in exceptional circumstances falling within Section 561-A of the Code of Criminal Procedure, namely to give effect to an order under the Code, prevent abuse of process, or otherwise secure the ends of justice.

Ratio Decidendi: The High Court's inherent power survives the Code only for exceptional intervention in matters not controlled by express provisions and may be used to reopen a criminal revision order solely where such action is necessary to secure justice or prevent abuse of process.

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