Functus officio after conviction bars Section 319 CrPC action; post-sentence order was quashed.

Once the trial court pronounces conviction and sentence, it becomes functus officio and cannot later invoke Section 319 CrPC to add another accused. The Supreme Court applied this jurisdictional principle and held that an order passed under Section 319 after conviction and sentencing is without authority. The post-sentence order was therefore quashed and set aside.

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Issues: Whether an order under Section 319 of the Code of Criminal Procedure could be passed after the trial court had already convicted and sentenced the accused.

Analysis: The governing principle applied was that once the trial court pronounces the order of sentence, it becomes functus officio. On that basis, the court lacks jurisdiction to invoke Section 319 of the Code of Criminal Procedure after conviction and sentencing of the accused.

Conclusion: The order passed under Section 319 of the Code of Criminal Procedure after conviction and sentence was without jurisdiction and was quashed and set aside, in favour of the appellants.

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