Functus officio bars post-disposal miscellaneous applications seeking fresh substantive relief after a writ petition is finally disposed.

Once a writ petition has been finally disposed of, the Court becomes functus officio and cannot entertain a miscellaneous application to revive the matter on the basis of a fresh cause of action or subsequent events. Post-disposal applications are not maintainable when they seek new substantive relief, and they are confined to limited situations such as correction of clerical or arithmetical mistakes or, in rare cases, where implementation of an executory order has become impossible due to later developments. Because the application sought protection against apprehended harm arising after disposal, it was treated as a fresh grievance outside the disposed proceedings and rejected, with liberty to seek relief before the territorial High Court under Article 226.

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Issues: Whether a miscellaneous application filed in proceedings already finally disposed of was maintainable, and whether any relief could be granted in respect of alleged subsequent threats arising after disposal of the main writ petition.

Analysis: Once the main writ petition stands finally disposed of, the Court becomes functus officio and does not retain jurisdiction to revive the proceedings through a miscellaneous application based on a fresh cause of action or subsequent events. Such post-disposal applications are not maintainable merely to seek new substantive reliefs. They may be entertained only in limited situations, such as correction of clerical or arithmetical mistakes, or in rare cases where the original order is executory in nature and subsequent developments have made implementation impossible. On the facts, the application sought protection against apprehended harm, which amounted to a fresh grievance outside the scope of the disposed proceedings. The appropriate course was to pursue relief before the territorial High Court under Article 226 of the Constitution of India.

Conclusion: The miscellaneous application was not maintainable and was rejected, with liberty to approach the appropriate forum for relief.

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