Appropriate Legal Remedy of Assailing the Final Execution Order

When an execution proceeding is finally concluded and disposed of upon recording full satisfaction, the executing court becomes functus officio in respect of that execution petition, and any party aggrieved by the manner or factum of the execution cannot seek redress through a fresh application under Section 47 of the Code of Civil Procedure. Instead, the only course open to an aggrieved judgment-debtor or respondent is to directly assail the judicial order disposing of the execution proceeding before a superior forum in accordance with recognized appellate or revisional remedies. Bypassing the statutory hierarchy and omitting to challenge the final order that accepted the commissioner's report and recorded satisfaction disentitles the party from attempting to reopen settled execution proceedings through a collateral application. The failure of the aggrieved party to challenge the order recording full satisfaction renders that disposal final and conclusive, thereby precluding any subsequent adjudication on the alleged wrongful delivery of possession. (Ananda Chandra Panda (Dead) Through LRs. Vs The Collector, Keonjhar & Another | 2026 INSC 91)