Courts become functus officio post-judgment and cannot authorize post-decree impleadment or dynamic injunction extensions.

The Plaintiffs, part of the Mahindra Group, are registered owners of the well-known trademark "MAHINDRA"

They filed an infringement suit against Defendants 1–4 and 10–12, who were using the "MAHINDRA" mark and various infringing domain names to provide packing and moving services

Defendants 5–9 are intermediaries (DoT, Google, GoDaddy)

Ex-parte ad-interim injunctions were previously granted, and the intermediaries filed compliance reports confirming the blocking of the infringing websites

While the suit was ready for final disposal, the Plaintiffs sought a "dynamic injunction" to implead future mirror, redirect, or alphanumeric websites through applications to the Joint Registrar (Judicial) post-decree, without filing fresh suits

1. Whether a plaintiff is entitled to implead alleged infringers via an application post-decree without having sought such a specific prayer in the suit

2. Whether a Court can, under Section 151 of the CPC, extend a dynamic injunction to mirror/redirect websites by empowering the Joint Registrar to pass impleadment and injunction orders after the final judgment has been pronounced and the Court has become functus officio

The Court applied the doctrine of functus officio, which dictates that once a Judge renders a decision and signs the judgment under Order XX, Rule 3 of the CPC, they lack jurisdiction to revisit, amend, or reverse it, except for the correction of clerical/arithmetical errors under Section 152 or through a review under Order XLVII

It relied on Dwaraka Das v. State of M.P. and State Bank of India v. S.N. Goyal, which establish that Section 151 cannot be used to pass effective judicial orders after a judgment.

The court distinguished the dynamic injunction procedure established in UTV Software Communication Ltd. v. 1337X.To

The Court reasoned that once a final judgment is pronounced, the litigation attains finality, and the Court is denuded of its power to introduce new issues or parties

The Plaintiffs' request to empower a Joint Registrar to implead third parties and extend injunctions post-decree was deemed legally untenable because a delegate (the Joint Registrar) cannot exercise powers that the delegator (the Court) no longer possesses after becoming functus officio

Furthermore, the Court noted that interim injunctions merge into the final decree and do not exist independently for future extension by an administrative officer

While acknowledging the technological menace of mirror websites, the Court held that such "moulding of relief" cannot bypass the express prohibitions of the CPC

The Court respectfully diverged from the UTV Software precedent, noting that the specific Supreme Court rulings on functus officio were not brought to that Bench's notice

However, it rejected the prayer for liberty to implead mirror/redirect websites via the Joint Registrar post-decree, holding that such a procedure violates the doctrine of finality and the limits of the Court's jurisdiction post-judgment

The Court advised the Legislature and Central Government to amend the CPC or IT Rules to address the challenges of dynamic injunctions in the digital age