Final judgment cannot be reopened through a belated clarification application; inherent powers cannot be used for de facto review.

A belated application styled as one for modification or clarification cannot be used to reopen a final judgment that had already conclusively decided the constitution of the Adjudicating Authority's Bench under the Prevention of Money Laundering Act, 2002. The High Court held that the request, filed nearly eight years later, was in substance an indirect attempt at review or reversal of a concluded decision and was therefore not maintainable. It further held that inherent powers under Section 482 of the Code of Criminal Procedure, 1973 cannot be invoked to assist abuse of process or to secure a de facto review where no timely appeal or review was pursued. The application was rejected.

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Issues: Whether an application for modification or clarification of a final judgment could be entertained to revisit the earlier decision on the constitution of the Adjudicating Authority's Bench.

Analysis: The earlier judgment had conclusively decided the dispute regarding the need for a Judicial Member in the Bench constituted under the Prevention of Money Laundering Act, 2002. The present application was filed nearly eight years later and sought, in substance, reopening of that concluded adjudication. The Court held that such a request was not a permissible clarification but an indirect attempt at review or reversal of a final judgment. The Court further held that the inherent powers under Section 482 of the Code of Criminal Procedure, 1973 cannot be used to assist a litigant in abusing the process of justice or to reopen a matter that had attained finality when no timely appeal or review had been pursued.

Conclusion: The application was not maintainable and was rejected.

Ratio Decidendi: A final judgment cannot be reopened through a belated application styled as one for modification or clarification, and inherent powers cannot be invoked to secure a de facto review of a concluded decision.

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