In State of Rajasthan v. Parmeshwar Ramlal Joshi, the Supreme Court quashed the Rajasthan High Court’s orders recalling its earlier directive and transferring the investigation to CBI. The complainant had filed successive petitions for CBI investigation, claiming clerical error in the High Court’s January 16, 2025 order. The Court held that criminal courts have no inherent power to review or recall judgments except to correct genuine clerical or arithmetical mistakes. Inherent jurisdiction under Section 528 BNSS (Section 482 CrPC) cannot be used to bypass statutory bars. The January 16 order was reasoned, not erroneous, and no clerical mistake existed. Filing successive petitions with identical prayers merely changed the label, not the substance, and was impermissible. The Supreme Court allowed the State’s appeals, quashed the High Court’s recall and CBI transfer orders, but permitted the complainant to pursue appropriate legal remedies challenging the original decisions.