Trial Court Becomes Functus Officio After Final Decision, Cannot Start New Proceedings: Delhi HC in L’Oréal Fake Goods Case [Read Order]

In a recent judgment, the Delhi High Court ruled that a trial court becomes functus officio once a case is finally decided, so it cannot initiate fresh or miscellaneous proceedings on the same matter. The ruling came in a dispute involving L’Oréal SA, where the trial court had continued to issue directions even after passing a final judgment and decree.

L’Oréal SA had filed a suit against Reliable Enterprises and customs authorities, seeking a permanent injunction and destruction of counterfeit goods bearing its trademark. The trial court, on October 19, 2024, ruled in favour of L’Oréal, ordering the confiscation and destruction of the infringing goods. With this, the case was concluded, and the file was consigned to the record room.

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Despite the conclusion of the case, the trial court initiated separate miscellaneous proceedings under a new file (MISC DJ/3620/2024) and issued an order on January 17, 2025, calling upon the Revenue Secretary to submit an Action Taken Report. This action was challenged by the customs department under Article 227 of the Constitution, on the ground that the trial court had no authority to initiate new proceedings after the final decree.

The petitioner’s counsel argued that after a case is decreed, the trial court becomes functus officio and cannot take further steps unless execution proceedings are lawfully initiated. They also submitted that jurisdiction cannot be assumed or conferred by consent or participation, citing Supreme Court precedents including Harshad Chiman Lal Modi v. DLF Universal Ltd. and Dr. Jagmittar Sain Bhagat v. Director, Health Services.

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The court presided over by Justice Saurabh Banerjee observed that the trial court, having fully adjudicated the matter, had no jurisdiction to reopen or continue proceedings. The court explained that jurisdiction must be derived from statute and cannot be created through judicial assumption or procedural convenience.

The court held that the trial court's actions in initiating MISC DJ/3620/2024 and issuing further directions were without authority and amounted to judicial overreach. The court set aside the order dated January 17, 2025, along with all proceedings in the miscellaneous case, reiterating that the trial court was functus officio after the decree and could not act further on the same subject matter. The petition was allowed, and the High Court directed the lower court to refrain from proceeding in matters already adjudicated unless done through lawful execution channels.

To Read the full text of the Order CLICK HERE

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