Inherent power under Section 482 CrPC cannot reopen a conviction finality affirmed by the Supreme Court.

The petitioner was convicted under Section 201 (Part II) of the IPC by the Trial Court on 21.12.2005 for causing disappearance of evidence related to the deaths of two individuals.

The High Court affirmed the conviction on 17.03.2017, and the petitioner’s Special Leave Petition (SLP) to the Supreme Court was dismissed as withdrawn on 11.05.2018.

The petitioner subsequently filed this petition under Section 482 r/w Section 362 of the Cr.P.C. and Section 7-A of the Juvenile Justice (Care and Protection of Children) Act, 2000 ("JJ Act"), claiming he was a juvenile (aged 17 years, 2 months) on the date of the incident in 2004.

A Court-ordered inquiry by the Juvenile Justice Board, Morena, confirmed the petitioner’s juvenility in a report dated 11.05.2019.

1. Whether a claim of juvenility can be entertained by the High Court under Section 482 Cr.P.C. after the conviction has attained finality through the dismissal of a Special Leave Petition by the Supreme Court.

2. Whether the mandatory provisions of Section 7-A of the JJ Act overridingly permit the reopening of a case at any stage regardless of the doctrine of finality of litigation.

The court primarily considered Section 7-A of the JJ Act, 2000, which allows a claim of juvenility to be raised at any stage, even after final disposal.

It balanced this against Section 362 of the Cr.P.C., which bars the review of a final judgment.

Section 482 of the Cr.P.C. regarding inherent powers.

The court referred to *Abuzar Hossain v. State of West Bengal*, emphasizing the need for formal adjudication of age.

*Hari Ram v. State of Rajasthan*, regarding the mandatory nature of procedural safeguards.

Crucially, it distinguished the High Court's limited inherent jurisdiction from the Supreme Court's plenary powers under Article 142 of the Constitution.

The Court acknowledged that juvenility is a jurisdictional fact that usually vitiates a sentence imposed by regular criminal courts.

However, it reasoned that because the petitioner had already approached the Supreme Court and withdrawn his SLP without raising the plea of juvenility or seeking liberty to do so, the judgment had attained "irrevocable finality".

The Court held that while Section 7-A allows the plea at any stage, it cannot be used to obliterate the doctrine of finality once the highest court of the land has seized of the matter.

It further noted that Section 482 Cr.P.C. is a procedural and corrective power, not a substitutive one; thus, the High Court cannot sit in appeal over a matter concluded by the Supreme Court, nor can it exercise the equitable "complete justice" powers reserved for the Apex Court under Article 142.

It held that judicial discipline prevents subordinate courts from reopening issues that have attained finality at the Supreme Court level.

While recognizing the statutory right to claim juvenility, the Court ruled that the petitioner’s failure to urge this plea before the Apex Court barred its collateral re-agitation under Section 482 Cr.P.C.