Functus officio bars post-disposal writ modification applications that seek review, except for limited clerical corrections.

After final disposal of a writ petition, the Court becomes functus officio and cannot entertain a post-disposal interlocutory application that in substance seeks review of the final order under the guise of modification or clarification. Such an application is maintainable only in limited situations, such as correction of clerical or arithmetical mistakes or where a direction has become incapable of implementation because of subsequent events. As none of those exceptional grounds was shown, the application was held not maintainable and dismissed.

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Issues: Whether a post-disposal interlocutory application seeking modification or clarification of a final writ order was maintainable.

Analysis: The application was filed after disposal of the writ petition and sought reopening of the final order under the guise of modification or clarification. The Court held that it had become functus officio after final disposal and could not entertain an application that would in substance amount to a review. It further held that such post-disposal applications are maintainable only in rare cases involving clerical or arithmetical correction or where an executory direction has become incapable of implementation because of subsequent events, neither of which was shown here.

Conclusion: The interlocutory application was not maintainable and was dismissed.

Final Conclusion: A disposed writ proceeding cannot be reopened through a modification or clarification application that seeks review of the final order; only limited corrective applications of the recognised kind may be entertained.

Ratio Decidendi: After final disposal of a writ petition, the Court is functus officio and cannot entertain a post-disposal application that seeks substantive alteration of the final order in the guise of clarification or modification, save for limited correction of clerical or arithmetical mistakes or exceptional executory situations.

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