Functus officio limits post-judgment relief: miscellaneous applications cannot reopen final Supreme Court decisions for fresh substantive claims.

A post-disposal miscellaneous application cannot be used to seek substantive modification or fresh relief after a Supreme Court judgment has attained finality. The Court noted that its rules permit only correction of clerical, arithmetical, or accidental slips, while reopening a concluded judgment requires review or curative jurisdiction. As the application was filed after final disposal and the Court had become functus officio, the request for late payment surcharge and other ungranted reliefs was procedurally impermissible. The application was therefore held not maintainable and dismissed.

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Issues: Whether a miscellaneous application filed after final disposal of the appeals could be entertained to seek directions for late payment surcharge and other reliefs not granted in the original judgment.

Analysis: The application was directed against a judgment that had already attained finality and was not a review petition. The applicable Supreme Court Rules permit alteration only for clerical or arithmetical mistakes or accidental slips, and review or curative jurisdiction alone can reopen a concluded judgment. A post-disposal miscellaneous application cannot be used to obtain substantive modification, clarification, or a fresh relief that was not granted in the original decision. The Court held that it had become functus officio after the final judgment, and the request for late payment surcharge had already been left open in contempt proceedings, making a miscellaneous application an impermissible procedural route for the claim.

Conclusion: The application was not maintainable and was dismissed.

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