judges court gavel closeup on a laptop

This article is written by Abhiraj Thakur, from NALSAR University of Law, Hyderabad, Raghav Agrawal from Amity Law School, Delhi, (GGSIPU), and Muskan Sharma, from GLA University, Mathura.


Electronic records given their nature have different rules as to their admissibility. Given that it is a field that is still being developed, the rules have been constantly developing and changing according to the interpretations given by the judges. Therefore a perpetual dilemma exists as to the mode and manner of admissibility of electronic evidence or records during the course of the trial. Section 65B of the Indian Evidence Act, 1872 has provision for procurement of an electronic certificate for admissibility of secondary electronic records. Two earlier conflicting judgments from the Apex Court led to confusion on the procedure of admission of electronic evidence as given under Section 65B of the Evidence Act, 1872. However, recent developments show that the Apex court has put a stop to the confusion with effect from its latest decision.

Given the importance of electronic evidence which is practically used in almost all trials, procedural uncertainty on admission would be a huge lapse in the interest of justice.

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In the latest judgment (14th July 2020) the Supreme Court’s 3 Judge Coram in Arjun Panditrao Khotkar vs. Kailas Kishanrao Gorantyal in an attempt to interpret the section and put down a stop at the uncertainty, have finally settled the correct interpretation.


Legal system is of the view itself that law cannot be stagnant and should adopt new mechanisms to understand the new parameters of crimes and wrongs happening in society, which was made clear by the case National Textile Workers’ Union vs P.R. Ramakrishnan & Others (1983). (See here)  The passing of Information technology Act (herein referred to as IT Act) paved the way for insertion of Section 65A and 65B in  Evidence Act on 17th October, 2000. The growing dependency on electronic modes of communication propelled the way to give recognition to admissibility to electronic evidence in all civil & criminal matters in India.

The first case that marked its presence in February 2004 concerning these sections was Suhas Katti’s case. (See here) In this case of Cyber Cell Chennai within 7 months of complaint by the victim on cyber bullying, the case was cracked and he was convicted. 

The IT Act was amended based on the United Nations Commission on International Trade Law (UNCITRAL). It was amended to allow admissibility of electronic evidence. 

Why e-evidence?

The human world today is digitized. Over the course of time, technology has seeped into every aspect of human life. From setting an alarm to wake up in the morning to knowing about the latest government policies, we make use of digital resources available to us. Everything, from communication to processing to documentation has gone digital. Law has not been immune to digitization. In case of India with the ever increasing e-commerce activities and e-governance initiatives from the state, the admissibility of e-evidence in the court of law has become a pertinent issue.

Indian law has for long, grappled with the issue of admissibility of e-evidence in the court of law. Instead of giving due regard to the increasing use of e-evidence around the world and incorporating it in the legal system, Indian courts have also remained sceptical of e-evidence, considering it to be of such nature that can easily be  tampered with. Today, a large variety of e-evidences are presented before courts in India every day, ranging from storage devices such as DVD or Hard Disk to mobile SMS or even a mail or website data.

E-evidence under the Evidence Act, 1872

Section 3 of the Indian Evidence Act, 1872 talks about what can constitute valid evidence in the court of law. Under clause 2 of the Section, it has been stated as “All documents produced for the inspection of the court.” It did not include an electronic form of evidence. However, witnessing the increase the presentation of electronic records before the court, Section 3 of the Act was amended in 2000. This was done to accommodate electronic records, and now the section reads as “All documents including electronic records produced for the inspection of the court.” Further, Sections 65A and 65B were introduced to make electronic evidence admissible in the court of law. An amendment was also done to Section 92 of the Information Technology Act of 2000.

Section 65B (see here) of the Indian Evidence Act (hereinafter Act) provides for the admissibility of electronic records.

It states that computer output is deemed document and admissible without further proof if it fulfils conditions of the section and no further proof of originality or production of the original shall be required thereof from it. Section 65B(4) calls for procurement of an electronic certificate from such authorized users of an electronic record, to be admissible in court. The question of the mandate of such a certificate is the focal point of debate of admissibility in this form of evidence.
Since it is not practical that servers containing evidence in electronic form be produced in court as primary evidence, Section 65B intends that mechanized copies be deemed as evidence to these records given certified by a responsible official with access and control of the computer record affirms the copy in the form of a certificate(as proof of authenticity).

Legislative Ambiguity

Though Section 3 of the Evidence Act was changed, no changes were made to the provisions under Sections 61 to 65 of the Act. Sections 61 to 65 deal with documentary evidence in the court of law. The provisions deal with documents or content of documents; no change was made to include electronic documents in that. Thus, the question that whether provisions enumerated under Sections 61 to 65 of Evidence Act would apply to electronic records baffled the Indian judiciary for a long time.

In the case of Utkal Contractors v. State of Orissa, this issue as to whether Sections 61 to 65 of the Evidence Act applies to electronic evidence was dealt with by the Supreme Court. The Supreme Court held that the intention of the legislature was clear for this omission to amend the provisions of Sections 61 to 65. It did not want it to be extended to electronic records. As a result, e-evidence is accepted only as a secondary form of evidence and not a primary form in Indian law.

Admissibility under the Evidence Act

Section 65 elaborately deals with the issue of admissibility of e-evidence. As it is only a secondary form of evidence, there are a few conditions with which e-evidence is accepted as valid evidence in Indian courts. Section 65B(1) states that anything contained in the form of an electronic record if is printed on paper or stored or has been recorded can be accepted as an admissible evidence only when it satisfies certain conditions laid down in subsequent provisions of Section 65B. These conditions can be briefly put in as:

Section 65 elaborately deals with the issue of admissibility of e-evidence. As it is only a secondary form of evidence, there are a few conditions with which e-evidence is accepted as valid evidence in Indian courts. Section 65B(1) states that anything contained in the form of an electronic record if is printed on paper or stored or has been recorded can be accepted as an admissible evidence only when it satisfies certain conditions laid down in subsequent provisions of Section 65B. These conditions can be briefly put in as:

  • Reliability of the source of electronic record

Section 65B(2) talks about the circumstances under which the computer from where electronic record has been produced can be deemed a reliable source. The computer needs to be of regular use, the one which was frequently used to store the information on the activity concerned. Also, the information derived from the computer must have been fed into it in the ordinary course of activity. Lastly, the computer must have been operating properly for the relevant period concerned.

  • Limiting the source:

When we talk about computers, several questions may arise due to the nature of the machine, such as, when many computers are connected to each other, which one is to be taken as the source of the evidence. Section 65B(3) removes such ambiguities. Among other things, it states that group or combination of computers connected over the period in question shall be considered as a single computer for the purpose of evidence. Also, if one or more computers act in a succession of each other over the period in consideration, they are also to be considered as a single computer.

  • Authorisation of the source:

The last condition that an e-evidence needs to satisfy to be admissible in courts is that of authorization or certification. Section 65B(4) states that when in any proceedings the nature of evidence is that of the electronic form, a certificate needs to be issued giving particulars of the device or anything dealing with Sub-section 2 of the Section. The certificate needs to be authorized by a person who holds a responsible official position about the particulars of the device. In most the cases, these people are IT professionals who hold certain expertise in the area of the device concerned.

Thus we see that there are many conditions which need to be fulfilled before an e-evidence can finally be accepted in the court of law. This has its advantages and disadvantages. While minimizing the possibility of falsification of evidence, many a times, it slows down the procedure making it very complex and also acts as an impediment in the course of justice.

Judicial development of e-evidence

Indian courts have, for a long time, been facing different forms of e-evidences in numerous cases and have tussled with the admissibility of it. High courts of different states have given conflicting judgments on the issue.

In the case of Ankur Chawla v. CBI, deciding on charges of corruption, the trial court had convicted the accused through a video CD, considering it to be valid evidence. However on an appeal, the Delhi high court reversed the judgment and raised suspicions over the admissibility of compact disks (CDs) as evidence in a court of law and considering the high probability of it being tampered with and faked, held it to be inadmissible in Indian courts.

About the validity of emails as evidence, in the case of Abdul Rahman Kunji v. State of West Bengal, the Calcutta High Court held that emails satisfying conditions under Section 65B to be admissible evidence in a court of law. Even intercepted phone calls recorded and presented in a CD were considered as valid evidence in the case of Jagdeo Singh v. State and Others.

Anvar P.V vs. P.K.Basheer & Ors

Supreme Court of India

Bench: R.M. Lodha, C.J.I., Kurian Joseph, and Rohinton Fali Nariman, JJ.

The use of the word “shall” and the presence of the non-obstante clause in sub-section (1) of Section 65B should make the requirements of the same mandatory and obligatory in nature. The same was to an extent re-iterated in Anvar P.V vs. P.K.Basheer & Ors (hereinafter Anvar P.V) and established by the court that “The Evidence Act does not contemplate or permit the proof of an electronic record by oral evidence if requirements under Section 65B of the Evidence Act are not complied with, as the law now stands in India.” The court relied on the maxim “Generalia Specialibus Non-Derogant” meaning the provisions of a general statute must yield to those of a special one and given Section 65B is a special law brought about by the IT act and hence it shall be governed by the procedure set in it rather than by general provisions (Sections 63 and 65).

Anvar P.V set to answer the questions posed by the judgment of State (N.C.T. Of Delhi) vs. Navjot Sandhu where electronic evidence was allowed to be admitted under general sections of secondary evidence (Sections 63 and 65) when a requirement of a certificate was not fulfilled. Coupled with some cases where a certificate was considered mandatory, the atmosphere was of uncertainty which Anvar P.V sought to clear.

The bench brought stability to the provision but that was not long-lived.

Shafi Mohammad vs. The State Of Himachal Pradesh

Supreme Court of India

Bench: Adarsh Kumar Goel and U.U. Lalit, JJ.

However the particular case of Shafhi Mohammad vs. The State of Himachal Pradesh (hereinafter Shafi Mohammad) led to uncertainty as the division bench swerved from the higher bench judgment of Anvar P.V.

The court held that the requirement of a certificate under Section 65B is not always mandatory and can be dispensed with, in the interest of justice. “The applicability of procedural requirement under Section 65B(4) of the Evidence Act of furnishing certificate is to be applied only when such electronic evidence is produced by a person who is in a position to produce such certificate being in control of the said device and not of the opposite party. In a case where electronic evidence is produced by a party who is not in possession of a device, applicability of Sections 63 and 65 of the Evidence Act cannot be held to be excluded.

In such a case, a procedure under the said Sections can certainly be invoked. If this is not so permitted, it will be a denial of justice to the person who is in possession of authentic evidence/witness but on account of the manner of proving, such document is kept out of consideration by the court in absence of certificate under Section 65B(4) of the Evidence Act, which party producing cannot possibly secure. Thus, the requirement of a certificate under Section 65B (h) is not always mandatory…”  

The Hon’ble Judges gave the reasoning that Section 65B was merely a procedural section and justified it by placing reliance on the judgment of Tomaso Bruno and Anr. v. State of Uttar Pradesh, in which a Three-Judge Bench observed that advancement of information technology and scientific temper must pervade the method of investigation.

Tukaram S. Dighole v. Manikrao Shivaji kokate (2010)(See here)

The VHS cassettes produced in question by the appellant had no further proof that they are reproduced from the original evidence and requested on the ground that since the VHS Cassettes produced are a public document under Section 74 of Evidence Act, no further authentication is required which was rejected by the tribunal.

In the case of Anvar P.V vs P.K.Basheer & Ors ( 2014) the court was of the view that the certificate mentioned under Section (65)(B)(4) is mandatory and doesn’t come with a choice. (See here) . It is a specific provision that prevails over general provisions of Section 63 and Section 65. This overruled the case of State (NCT of Delhi) v. Navjot Sandhu to the extent that certificate was now held to be mandatory. In the same case it was mentioned that oral admission on the content of the electronic evidence is not relevant unless the genuineness of electronic evidence is in question as mentioned in Section 22 of Evidence Act. The relevance of Section 45A ,role of the digital examiner under Section 79A of IT Act was also mentioned in this case. As the electronic evidence is more prone to be tampered with the rules mentioned in the Act should be given recognition. 

Sanjaysinh Ramrao Chavan vs. Dattaray Gulabrao Phalkay & Anr. (2015) (See here)

The court relied on the judgment of Anvar PV’s case and noted , “As the voice recorder is itself not subjected to analysis, there is no point in placing reliance on the translated version. Without source, there is no authenticity for the translation. Source and authenticity are the two key factors for an electronic evidence”

Tomaso Bruno and Anr. v. State of Uttar Pradesh (2015) (See here)

 The case substantiated the importance of electronic evidence and scientific mechanisms in the procedure of evidence recording.  It held Section 65A and 65B procedural and electronic evidence is admissible. 

Arjun Panditrao Khotkar vs Kailash Kushanrao Gorantyal and others (2020) (See here)

In this case a three judge bench headed by J. RF Nariman decided on the question and ambiguity on the various interpretations of Section 65(B)(4) and overruled the judgment of Shafhi Mohammad, upholding the view that certificate under this section is not one alternative among many others but a mandatory provision.

Many cases have also dealt with the necessity of such stringent conditions enumerated under clauses of Section 65B of the Evidence Act. In Dharambir v. CBI, the Delhi High Court upheld the necessity of provisions under section 65B, stating them to be for the betterment of law. The court also elaborated upon the contemporary provisions dealing with e-evidence in different countries of the world. In this regard, it is necessary to mention that in England, similar precautionary provisions as in Section 65B existed under Section 69 of The Police and Criminal Act of 1984. However, the Law Commission of England in its report among other things, reviewed Section 69 of the Act and recommended it to be unsubstantial and failing on the very grounds for which it was introduced, which was to improve the infallibility of evidence and promote justice. The Parliament of England took cognizance of the fact and Section 69 was finally repealed in the year 1999 through Section 60 of Youth Justice and Criminal Evidence Act.

The varying views surrounding section 65B of the Evidence Act have finally been settled in a recent judgment by Supreme Court. In 2014, while deciding the case of P.V Anvar v. P.K Basheer and Ors., the Supreme Court, taking a positivist line of approach held that as per the current legal framework at hand, Section 65B is very much mandatory, and the courts need to follow the procedure so enumerated in the Section. If any changes are sought for, it is the Legislature that has to take the initiative and not the courts who just follow the procedure laid down by law.

Producing Electronic Record as Primary Evidence

The court differentiated the documents produced by computer as both primary and secondary documents. The primary document would be the “original “electronic record” contained in the “computer” in which the original information is first stored and the computer output containing such information, which then may be treated as evidence of the contents of the “original” document”

The court made a provision which enabled the original computer evidence to be produced easily before the court to be admitted for the proceedings:

“Quite obviously, the requisite certificate in sub-section (4) is unnecessary if the original document itself is produced. This can be done by the owner of a laptop computer, a computer tablet or even a mobile phone, by stepping into the witness box and proving that the concerned device, on which the original information is first stored, is owned and/or operated by him.”

Producing Electronic Record as Secondary Evidence (Requirement of a certificate under Section 65B(4))

The copies of an original document are known as secondary evidence. In the case of electronic records, the court reiterated the settled proposition that the copies of Computer Output are to be taken as secondary evidence.

“….Original information contained in the “computer” itself and copies made therefrom the former being primary evidence and the latter being secondary evidence…..”

Regarding the secondary evidence, the court overruled the judgment as laid in Tomaso Bruno case that secondary evidence of the contents of a document can also be led under Section 65 of the Evidence Act to make CCTV footage admissible would be in the teeth of Anvar P.V., (supra) and cannot be said to be a correct statement of the law given how the judgment in the case was drawn without reference to a higher bench set precedent in Anvar P.V and reliance on the expressly overruled case of State v. Navjot Sandhu.

Court then also overturned the decision asset in the Shafi Mohammad Case given how it relies on cases which have been passed before the amendment of the Evidence Act which brought about section 65A and 65B and placed much reliance on the case on Tomaso Bruno (supra) which was also overturned earlier in the judgment.

Mandatory to Procure Electronic Certificate

The court considering the two decisions (Tomaso Bruno and Shafi Mohammad Case) which were found to be per incuriam and interpreting section 65B as a special provision held that the condition of procurement of an electronic certificate under Section 65B(4) is mandatory and upheld the decision of Anvar P.V.

If required, the court can summon production of documents if the certificate can’t be obtained

The court also iterated that the problem which was sought to be treated in the Shafhi Mohammad case i.e. production of a document that is not in possession of the party to the case can be solved within the given mechanism of the Evidence Act and the CPC. An application can always be made to a Judge for the production of such a certificate from the requisite person under Section 65B(4) in cases in which such a person refuses to give it.

The court allowed for the summons to be ordered against a person of authority or in possession of the ‘Computer Record’ in case of refusal or non-production of such document after the request of the party.

The court hence extended the scope of Section 165 of the Evidence Act and Order XVI of the Civil Procedure Code, 1908 (“CPC”) which deals with ‘Summoning and Attendance of Witnesses’ and similarly for CrPC to be applicable to Section 65B of the Evidence Act.

Time of Procurement of Certificate

Regarding the time of such procurement of certificate, it was stated that the requisite certificate can be directed to be produced by the learned Judge at any stage, so that information contained in electronic record form can then be admitted, and relied upon in evidence. The Hon’ble judges mentioned the importance especially in criminal cases that the accused be provided with all the evidence he so requires before the commencement of trial.

Critical Analysis

The two views which existed between the different pronouncements had their own merits and defaults. Where one was correct in law to implement stare decisis and implement the provision as to provide what was sought by the legislature (Anwar P.V), the other sought to remove the hindrance caused by the strict interpretation of the section in further interest of justice even going to the extent of disregard of well-set precedent (Shafi Md.).

Despite the judicial intent, the judgment in Shafi Mohammed Case can’t be taken as good law since procedurally it overpassed certain principles established by the common law.

  • The judgment heavily relied on the judgment of State v. Navjot Sandhu which was expressly overturned in Anvar P.V. Case. Furthermore, the majority of the judgments relied upon by the bench were passed before the amendment which brought Section 65B into the act.
  • The judge ignored the decision of the court in the Anvar PV case, didn’t even consider it and went on to deliver a judgment contrary to that laid in Anvar PV by a higher bench and hence conflicting the principle of stare decisis.
  • Another important principle which is followed in the interpretation of statutes is the maxim of Generalia Specialibus Non-Derogant which means that for the purposes of interpretation of two statutes in apparent conflict, the provisions of a general statute must yield to those of a special one. The court overruled the importance of Section 65B which is a special provision added to govern specifically electronic evidence. Applying this principle, Section 65B, a special provision shall prevail in case there is conflict over the procedure of admission of electronic records (over Section 63 which is in this regard a general provision). 
  • The judgment was bad in law since it strayed from the basic requirements of sound judgment and created confusion regarding the particular field.

Anvar P.V though a sound judgment which overturned the judgment of State v. Navjot Sandhu and finally brought clarity that Electronic Certificate under Section 65B is mandatory had its own flaws exposed during the judgment of Shafhi Mohammad.

The judgment though was procedurally sound; it ignored the reasons why the conflict arose.

In many cases, the electronic record is in the possession or under the authority of a person different from the person trying to admit the evidence. Hence the refusal to grant such a certificate by such a person abrogates the right of the accused and hinders complete justice. The accused has a right to be allowed to produce evidence in entirety. The mandate of the certificate with no other option to force the production of such records allowed the evidence in such particular cases to be insufficient. It is well within the ambit of Article 21 that a person gets to present their case with all the evidence and necessary for complete justice of the proceedings.

Anvar PV case didn’t resolve the problem which was faced by the parties though being structurally sound.

The latest judgment, in essence, observed all the cases in-depth and sorted out their shortcomings.

Firstly the confusion was cleared that certificate is mandatory which is a welcome decision.- Section 65B deals with secondary evidence in the form of electronic records. As we can see from Section 63, certain steps have been considered essential by the legislature to make secondary evidence credible for e.g. – section 63(1) calls for certified copies. Certification is one method that has been considered by the legislature to make secondary evidence credible so as to make it admissible alongside primary evidence. Hence it is not at all unreasonable in my opinion that a certificate is necessary for authentication of electronic secondary evidence otherwise there will remain no intelligible difference between primary and secondary evidence and also will be contrary to the principle of equality to treat electronically evidence above other types of evidence (physical).

Also, a bare reading of the provisions added by the amendment of the Act clearly shows the intent of the legislature to create specific provisions to govern the admission of electronic records. For e.g. Section 65A states that the contents of electronic records ‘may’ be proved in accordance with the provisions of Section 65B. It can be debated that with the use of the word ‘May’ in the provision, admission of electronic evidence under other general sections is not intended to be barred but the principle of Generalia Specialibus Non-Derogant can’t be ignored. The existence of special provision which has been exclusively added by the legislature is enough to show intent that they are meant to be governed under special provisions only. If there is a bypass to such procedural requirements then the principle i.e. special provisions prevail over general provisions gets defeated. Within Section 65B the use of the word “shall” leaves no confusion that any evidence to be admitted under Section 65B is to have a certificate to authenticate it.

Secondly, to resolve the point which was felt in the Shafhi Mohammed case i.e. that certificate production might not always be under the power of the party and hence is a hindrance in the submission of all necessary evidence and hence is conflicting with the rights of parties and the interest of justice, the court allowed for the person with so record in the possession or authorized to give such certificate be summon to court in case of noncompliance. This gives a remedy to the party which is unable to comply with the electronic certificate requirement. The effectiveness of summoning the electronic evidence is on par with the summoning of other physical evidence. It may suffer its own qualms like nonappearance but that can’t be attributed to specific default arriving out of this remedy. Delay in the admission of evidence is better than no admission at all.

The court in my humble opinion did find a middle ground between strict compliance as in mandate as given in Anvar PV and a still better verification than absolutely absolving of the provisional requirement under Shafi Mohammed.

Scuffle on Section 65(B)

A successful and uniform interpretation is still a far fetched dream as far as the admissibility of electronic evidence is concerned. Section 65(B), which talks about a computer output to be produced as an evidence of the case, which is acquired by the police held and edited to be produced in the court in some hardware or removable media, such evidence has to be the responsibility of someone in whose custody it was present. The confusing judgment given in Shafhi Mohammad v. State of Himachal Pradesh exempts a person who is producing the evidence and can easily manipulate the facts and prove to not be in the custody of said evidence. This easy pitfall in the law makes it highly susceptible.  Manipulation without liability is one of the many effects of this interpretation. In this cyber equipped world where hacking into the server and modifying the content will not bring surprise or shock to anyone the modified content can easily be presented.

Section 65(B)(4) clearly mandates the production of a certificate identifying the electronic record and the manner in which it was produced, giving the particulars of the device which produces the electronic record and a significant authority managing the device has to sign it. The purpose and statement is clear so such a wisely constructed section should not be subjected to erroneous interpretation. Yet Judiciary time and again presents such conflicting views while calling it a provision of admissibility of electronic records in Navjot Sandhu’s case to calling it in relation with mode of proof of the electronic record in Sonu v. State of Haryana. (See here)

It would be ignorance if judiciary neglects the technological aspect of production of electronic evidence as the evidence produced as a “computer output” which maybe a print out or a soft copy in technicality not original as the data stored in its original form would mark its presence in the sequence of “ones” and “zeros” not readable without its conversion by a suitable operating system of the computer, all related mediums will read the data in the similar manner. The same happens in the case of “audio” and “video” produced so needs to take responsibility of what medium he witnessed it through and what he saw and any queer device or method could be questioned by the court and held accountable in case of any manipulation.

In the Trisha defamation case (See here) in the Chennai Egmore AMM court gave due consideration to an important facet of the law that a judge cannot be a witness himself and in viewing the evidence through a removable media handed over to him without a trusted third party, the very part of law bends down.

There are many views that are affirmative or dissenting to any one judgment of the court, the scuffle may not end and continue to be back and forth if the legislature doesn’t interfere and clears the air around its legislative intent.

Breaking up of Judicial discipline 

The dilemma that we face when a two judge bench in Shafhi Mohammad’s case overrules a judgment passed by a larger bench i.e. three judges in Anvar P.V vs P.K.Basheer & Ors puts the judiciary in bad light. As it is noted , Benches of five Judges presided over by Bharucha, C.J. in Bharat Petroleum Corpn. Ltd.v. Mumbai Shramik Sangha and Pradip Chandra Parija v. Pramod Chandra Patnaik made clear that a two judge bench cannot refer to the correctness of a five judge bench by another five judge bench and for a two judge bench to refer to the correctness of a decision of three judges to a larger bench respectively. The very defeat of this idea is present in Shafhi Mohammad’s ruling.


We thus see that the mere mention of e-evidence in the statute cannot help the cause. The procedural glitches that have been induced with the inclusion of e-evidences need to be dealt at the earliest. With changing times, law too needs to keep pace with improvements in technology. While countries like England have realized and accordingly made changes in their law to improve the efficiency of e-evidences, India still is keeping the current scheme. The courts though, on occasions have dealt with the issue, but it is the Legislature that needs to come forward.

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  1. Excellent Article. Can you also through some light about the admissibility of Facebook chat when one party deletes his facebook acount and refuses about his chat whereas the other party keeps the facebook chat and want to produce it before the court. How can the other party prove it and make it a part of investigation when the charge sheet has already been filed.


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