Functus officio after final decree limits trial court power to clerical corrections, not fresh enforcement directions.

Once a decree has been passed and attains finality, the trial court becomes functus officio and cannot invoke Section 151 CPC to issue fresh directions such as police protection or mutation of katha in favour of the decree-holder. Its post-decree power is limited to correction of clerical or arithmetical mistakes within Sections 152 and 153 CPC. Orders extending beyond that narrow jurisdiction are without authority and can be interfered with in supervisory jurisdiction under Article 227 of the Constitution.

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Issues: Whether the trial court, after passing a decree which had attained finality, retained jurisdiction to entertain applications under Section 151 of the Code of Civil Procedure, 1908 and direct police protection and mutation of katha in favour of the decree-holder.

Analysis: Once the decree had been passed and had attained finality, the trial court became functus officio. Its jurisdiction thereafter was confined only to correction of clerical or arithmetical mistakes within the limited scope of Sections 152 and 153 of the Code of Civil Procedure, 1908. The impugned directions for police protection and for issuance of katha in respect of agricultural land went beyond that limited jurisdiction and could not be sustained. In the exercise of supervisory jurisdiction under Article 227 of the Constitution of India, such orders were liable to be corrected.

Conclusion: The impugned orders were without jurisdiction and were quashed; the writ petitions succeeded.

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