Plain Meaning of functus officio 1. Black’s Law Dictionary, Eighth Edition (2004), defines functus officio as: - “having performed his or her office (of an officer or official body) without further authority or legal competence because the duties and functions of the original commission have been fully accomplished.” 2. P. Ramanatha Aiyar's Law Lexicon provides its meaning as: - “A term applied to something which once has had a life and power, but which has become of no virtue whatsoever. Thus, when an agent has completed the business which he was entrusted his agency is functus officio.” 3. Wharton's Law Lexicon, Fourteenth Edition, defines it as: - “a person who has discharged his duties, or whose office or authority is at an end.” 4. Trayner's Latin Maxims, Fourth Edition, explains it as: - “Having discharged his official duty. This is said of any one holding a certain appointment, when the duties of his office have been discharged. Thus a Judge, who has decided a question brought before him, is functus officio and cannot review his own decision.” 5. Corpus Juris Secundum defines it as: - “literally having discharged his duty. Having fulfilled the function, discharged the office, or accomplished the purpose, and therefore, of no further force or authority”. Hence, the plain meaning of functus officio is that when an office or a position ceases to have any functionality or when its functions are completed. Let us also understand its meaning with the help of judicial precedents of India. Judicial Precedents on the Doctrine of functus officio 1. Lalit Narain Mishra v. State of Himachal Pradesh and Others, 2016 SCC OnLine HP 2866 - In this case, the Petitioner was seeking the writ of mandamus in a matter that had already been decided by the Court. The Court denied such relief and observed that: - “19. “Functus officio” is a Latin term meaning having performed his or her office. With regard to an officer or official body, it means without further authority or legal competence because the duties and functions of the original commission have been fully accomplished.20. “Functus” means having performed and “officio” means office…..….25. In other words, the authority, which had a life and power, has lost everything on account of completion of purpose/activities/act.26. Notably, what the petitioner is seeking is virtually a writ of mandamus in a decided case, which is legally impressible.” 2. Bhupendra Kumar Dash v. State of Odisha and Others, AIR 2016 Ori 167 – In this case, it was observed that once a District Tender Committee approves a Tender, it becomes functus officio and in the same manner, when an Arbitrator pronounces its award, it becomes functus officio. 3. Smt. Tara Devi v. State of UP through Secretary, Panchayati Raj, Lucknow and Others, 2010 SCC OnLine All 3016 – In this case, it was observed that a Returning Officer who had formally declared the results of an Election becomes functus officio and has no further power left to rectify the errors in the Electoral Process. It was further observed that if this Doctrine is applied to an officer whose term has expired, it would mean that he has no official authority left to discharge any function. 4. B.M. Jain and Sons Co. P. Ltd. v. Bombay Cable Car Co. P. Ltd., 2009 SCC OnLine CLB 71 – If a Court disposes of a Petition with a certain direction, then till such direction is complied with or becomes complete, the Court continues to have jurisdiction and cannot be considered to have become functus officio. 5. V.G. Naidu v. Pahlajraj Gangaram, 2016 SCC OnLine Mad 9710 – This was a case in relation to Order XXI of the Code of Civil Procedure, 1908 relating to Execution Proceedings and the Court observed that till the time of limitation subsists, there could be any number of Execution Applications and if the statute provides power to correct certain kinds of errors, then the Doctrine of Functus Officio would be subject to such qualifications and its applicability would depend “upo