Inherent jurisdiction cannot reopen a finally disposed revision to quash an NI Act conviction after later settlement.

After a criminal revision petition has been finally disposed of, the High Court is functus officio and cannot invoke inherent jurisdiction to quash a conviction and sentence under Section 138 of the Negotiable Instruments Act on the basis of a later settlement. The Court treated the bar on altering or reviewing a signed judgment as decisive and held that post-revisional compounding is not permissible in such circumstances. A later decision allowing quashing on its special facts was confined to that context and did not displace the earlier controlling line of precedent. The request to set aside the conviction and sentence on settlement grounds was therefore not maintainable.

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Issues: Whether, after a criminal revision petition has been finally disposed of, the inherent powers can be invoked to quash a conviction and sentence under Section 138 of the Negotiable Instruments Act, 1881 on the basis of subsequent settlement between the parties.

Analysis: The prior decisions of the Court were examined and the controlling principle was that, once a conviction is confirmed in revision and the revision stands finally disposed of, the Court becomes functus officio and cannot use inherent jurisdiction to reopen the conviction or permit post-revisional compounding. The bar under the provision prohibiting alteration or review of a signed judgment was also treated as decisive. The later decision permitting post-revisional quashing was treated as rendered on its special facts and not as overriding the earlier authoritative line of precedent. The decision relied on by the petitioners permitting composition in a disposed revision was held not to assist them.

Conclusion: The inherent jurisdiction cannot be invoked after final disposal of the revision petition to set aside the conviction and sentence; the petitioners' request for quashing on the basis of settlement is not maintainable.

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