Acts Discussed: Article 32 of the Constitution of India, Article 226 of the Constitution of India.

1. Filing of Miscellaneous Applications: The Court emphasized that miscellaneous applications in disposed cases are largely not maintainable, especially if the matter relates to fresh causes of action.
2. Clarification on Court’s Functionality: The Court clarified its role as functus officio post-disposal of cases, retaining jurisdiction only for rare cases involving clerical or executory issues.
3. Future Filing Protocol: The Court directed the Registry to ensure strict compliance before circulating such applications.

Background of the Case

• Para 1–4:
  • Delay condoned.
  • The petitioner sought protection during ongoing litigation and other related directions.
  • Main proceedings in W.P.(C) 429 of 2020 were disposed of on 06-08-2021 with specific directions regarding a contempt application.

Directions in W.P.(C) 429 of 2020

• Para 5–6:
  • Relief for a broader mechanism was declined under Article 32.
  • Directed expeditious disposal of Contempt Application No. 26/2016.

Petitioner’s Current Grievances

• Para 7–10:
  • Contempt application allowed; subsequent appeal by the contemnor was dismissed.
  • The petitioner raised concerns of personal threats.

Court’s Observations on Miscellaneous Applications

• Para 11–15:
  • The Court held the present miscellaneous application as not maintainable.
  • Reiterated that reopening disposed cases for subsequent events is impermissible unless the issue directly pertains to executory directions.

Legal Principles Reiterated

• Para 16–17:
  • Cited Jaipur Vidyut Vitran Nigam Ltd. v. Adani Power Rajasthan Ltd. (2024 SCC OnLine SC 313) emphasizing the limited scope for post-disposal applications.

Protocol for Registry

• Para 18–19:
  • Directed the Registry to scrutinize miscellaneous applications in disposed proceedings, ensuring compliance with specific requirements of executory necessity.

Relief for Threat Perception

• Para 20–23:
  • Liberty granted to the petitioner to approach the High Court under Article 226 for protection.

Ratio Decidendi:

1. A disposed-of matter cannot be reopened via a miscellaneous application unless it pertains to executory issues or clerical errors.
2. Jurisdiction post-disposal is strictly limited; fresh causes of action require independent proceedings.
3. Procedural safeguards must be followed by litigants and the Court Registry to ensure clarity and order.

Subjects:

Procedural Law – Maintainability of Miscellaneous Applications in Disposed Matters.
Article 32, Article 226, Miscellaneous Applications, Functus Officio, Executory Directions, Protection Orders, Contempt of Court.