Clarification applications cannot be used to reopen final judgments; such review by another route is an abuse of process.

Miscellaneous applications styled as requests for clarification and intervention were treated as an indirect attempt to reopen an earlier judgment through review-like relief. The Supreme Court held that such recourse amounted to an abuse of process because it sought to bypass the limits on review by using miscellaneous applications, and it noted the unnecessary consumption of judicial time caused by this growing practice. The applications were dismissed with costs.

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Issues: Whether the miscellaneous applications seeking clarification and intervention were in substance an attempt to seek review of the earlier judgment, and whether they were liable to be dismissed with costs.

Analysis: The applications were found to be an indirect attempt to reopen the earlier judgment under the garb of clarification or modification. The Court held that such recourse amounted to abuse of process of law and noticed the growing tendency of seeking review through miscellaneous applications, thereby consuming judicial time unnecessarily.

Conclusion: The applications were dismissed with costs of Rs. 10,00,000 each.

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