Functus officio bars post-disposal writ applications seeking review under the guise of clarification or rectification.

After final disposal of a writ petition, the HC becomes functus officio and cannot entertain an interlocutory application that in substance seeks review by way of modification, clarification or rectification. Such post-disposal applications are maintainable only in rare cases involving clerical or arithmetical errors, or where executory directions have become impossible to implement because of subsequent events. No such circumstances were shown, so the application was held not maintainable and was dismissed.

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Issues: Whether an interlocutory application filed after disposal of the writ petition seeking modification, clarification or rectification of the earlier order was maintainable.

Analysis: The application sought reopening of a concluded writ proceeding under the guise of clarification or rectification. The Court held that, after final disposal of the writ petition, it had become functus officio and could not entertain a post-disposal application that effectively sought review of the earlier order. It further held that such an application is maintainable only in rare cases involving correction of clerical or arithmetical errors or where executory directions have become impossible to implement because of subsequent events, neither of which was shown on the facts.

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

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