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    <title>2025 (12) TMI 1455 - KERALA HIGH COURT</title>
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    <description>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.</description>
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      <description>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.</description>
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