Registrar General, High Court of Judicature at Madras vs. The State, represented by the Inspector of Police, Central Crime Branch, Chennai & Another
Background
Tamil Nadu had created special "Land Grabbing" courts to handle a specific category of criminal cases under a government order that was itself under challenge before the Supreme Court, which had stayed a High Court ruling striking it down, meaning the special courts' jurisdiction remained operative. In a single, already-disposed-of case before the Madras High Court concerning one complainant, the Additional Public Prosecutor later made "special mentionings" asking the same judge to also transfer hundreds of other, unrelated cases (ultimately about 864 cases) out of these Special Courts to ordinary courts, even though those cases and their parties were never before the High Court and the original case had already been closed. The Madras High Court, through its Registrar General, itself flagged concern about how to implement these orders and approached the Supreme Court.
Decision Breakdown
The Supreme Court quashed the High Court's orders directing transfer of the roughly 864 cases. It held that once the original petition (concerning only one case) was disposed of, the judge became "functus officio", having no further authority over that matter, and could not later pass sweeping orders affecting hundreds of unconnected cases based merely on informal "special mentionings" by the prosecutor, without those cases or their parties even being before the court. The Court also held the transfer orders conflicted with its own earlier interim order keeping the Special Courts' jurisdiction alive pending the outcome of the related appeal on the government order's validity. The Court cautioned that a High Court's inherent powers under Section 482 CrPC, though wide, cannot be used in such a sweeping and procedurally improper manner.
Lesson Learnt
A court's authority over a case ends once that case is finally disposed of. It cannot later use informal "mentionings" to pass sweeping orders affecting hundreds of other cases and parties who were never before it; wide inherent powers are not a substitute for due process.