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Issues:
1. Whether the High Court can review its own order of dismissal in a Criminal Revision Petition. 2. Interpretation of Section 362 of the Code of Criminal Procedure regarding altering or reviewing judgments. 3. Application of the principle of functus officio in legal proceedings. 4. Consideration of the principle of equity and justice in entertaining fresh petitions on the same matter. 5. Analysis of case law on the inherent power of the High Court to alter or review its own judgment. Detailed Analysis: 1. The judgment involves a revision against an order passed by the Additional Sessions Judge, which was initially dismissed by a single Judge of the High Court but later reviewed and admitted for final hearing. The question at hand is whether the High Court can review its own order of dismissal in a Criminal Revision Petition. The matter was referred to a Bench for consideration due to its importance. 2. The interpretation of Section 362 of the Code of Criminal Procedure is crucial in this case. Section 362 prohibits courts from altering or reviewing judgments once signed, except for correcting clerical or arithmetical errors. The comparison between the old Section 369 and the new Section clarifies that alteration or review by a High Court is permissible if provided for in the law. The principle of finality of judgments is highlighted, emphasizing that a court becomes functus officio once a matter is disposed of. 3. The principle of functus officio dictates that a court cannot entertain a fresh prayer for the same relief after finally disposing of a matter unless the previous order is set aside. This principle is enshrined in Section 362 and ensures the integrity of judicial decisions. The absence of specific provisions allowing alteration or review of final orders by the High Court is noted. 4. The judgment delves into the principle of equity and justice in legal proceedings, citing case law to support the notion that once a criminal revision petition is dismissed on merits, no other petition on the same matter should be entertained. The inherent power of the High Court under Section 561-A is discussed, emphasizing limitations on altering or reviewing judgments once pronounced. 5. Case law examples are provided to illustrate the scope of the High Court's inherent powers in altering or reviewing its judgments. The judgment emphasizes that even a summary dismissal at the admission stage of a revision case constitutes a final order that cannot be altered or reviewed under Section 362 of the Code of Criminal Procedure. The revision in question is ultimately dismissed based on these legal principles.
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