Two (Apparently Diametrically Opposite) Views on Objections to the Mode of Proof of Documents

Saji Koduvath, Advocate, Kottayam.

Two (Diametrically Opposite) Views on Raising Objection to Mode of Proof

• First: Objection as to irregular or insufficient mode of proof of a document (such as secondary evidence) should be raised at the time while it is marked as an exhibit; and its failure amounts to waiver. Such objection cannot be allowed to be raised at any subsequent stage.
  • (Classic Decision on this view is – R.V.E. Venkatchalla Gounder v. Arulmighu Viswesaraswamy and V.P. Temple, (2003) 8 SCC 752, R.C. Lahoti, Ashok Bhan, JJ.)
• Second: Secondary evidence is NOT admissible until the non-production of the original is accounted for – that is, until the foundational facts of Section 65 are  established. The court has also an obligation to decide the question of admissibility before making it as a secondary evidence. That is, mere marking, or marking on admission, does not automatically prove its contents.
  • (Latest decision on this view is – Tharammel Peethambaran v. T. Ushakrishnan,  AIR 2026 SC 938, Pankaj Mithal, S.V.N. Bhatti, JJ.)

Crux of R.V.E. Venkatchalla Gounder v. Arulmighu Viswesaraswamy

In R.V.E. Venkatchalla Gounder v. Arulmighu Viswesaraswamy and V.P. Temple, (2003) 8 SCC 752, held as under:

• The objections as to admissibility of mode of proof (photostat) — irregular or insufficient —  should be taken before the evidence is tendered and once the document has been admitted in evidence and marked as an exhibit, cannot be allowed to be raised at any subsequent stage .
• Failure to raise a prompt and timely objection amounts to waiver of formal proof.
• This view is also found in:
  • Neeraj Dutta v. State (Govt. of Delhi) [2023] 4 SCC 731: five-Judge Bench
  • Smt. Dayamathi Bai v. K.M. Shaffi, AIR 2004 SC 4082.
  • Iqbal Basith v. N Subbalakshmi,(2021) 2 SCC 718;  
  •  PC Thomas v. PM Ismail, AIR 2010 SC 905; 2009-10 SCC 239
  • Oriental Insurance Co  v. Premlata:   2007-8 SCC 575
  • Thimmappa Rai v. Ramanna Rai,(2007) 14 SCC 63
  • Narbada Devi v. Birendra Kumar: 2003-8 SCC 745. 

Crux of Tharammel Peethambaran v. T. Ushakrishnan,  AIR 2026 SC 938

1. Secondary evidence is NOT admissible –

• until the non-production of the original is accounted for –
• that is, until the foundational facts or  the conditions of Section 65, Evidence Act are  established.
• The court relied on –
  • H. Siddiqui (D) By Lrs. v. A. Ramalingam AIR (2011) SC 1492
  • Rakesh Mohindra v. Anita Beri, (2016) 16 SCC 483.
  • Ashok Dulichand v. Madahavlal Dube and Another (1975) 4 SCC 664; 
  • Chandra v. M. Thangamuthu, (2010) 9 SCC 712.
• This view is also found in:
  • LIC v. Ram Pal Singh Bisen  [(2010) 4 SCC 491   
  • Yeshoda v. Shoba Ram   AIR 2007 SC 1721
  • State of Rajasthan v. Khemraj  [(2000) 9 SCC 241 : AIR 2000 SC 1759] ,  
  • Mal Singhvi v. Anand Purohith 1988 (Supp) SCC 604.
  • Roman Catholic Mission v. State of Madras  [AIR 1966 SC 1457].  

2. The court has an obligation to decide the question of admissibility before making it as a secondary evidence.

• That is, mere admission of a document, or
  • marking it on admission, 
• does not dispense with the requirement of proving it in accordance with the law or
• mere marking, or marking on admission, does not automatically prove its contents.

Read Similar Articles •• Secondary Evidence of Documents & Objections to Admissibility  – How &  When? •• Contents of a Document are to be Proved in Court by Producing Original or Secondary  Evidence •• Newspaper Reports are ‘Hearsay Secondary  Evidence’ •• Proof of  Documents & Objections To Admissibility – How & When? •• Admissibility, Substantive Evidence and Probative Value – General Principles •• Modes of Proof of Documents – Admission, Direct Evidence, Expert Evidence, Presumption etc. •• Best Evidence Rule in Indian Law

Law on Marking (on ‘No Objection’) – Apparently Divergent Views

• 1. MERE MARKING PROVE THE CONTENTS if no objection. E.g. Rent receipt executed by the opposite side; Photocopy of a document.
• 2. MERE MARKING WILL NOT PROVE THE CONTENTS if Truth of the facts in the document was “in issue“ or validity was very much in question.

Note: The following decisions demonstrate that these are not conflicting propositions. They reveal a common underlying principle: mere marking dispenses only with formal proof where there is no real dispute regarding the document; it does not establish disputed facts contained in the document.

Following are the often-cited cases to support the proposition –

• MERE MARKING PROVE THE CONTENTS   

Decision	Were the documents ‘marked without proper proof‘ accepted in evidence?	Reason for MARKING
Narbada Devi Gupta v. Birendra Kumar Jaiswal, 2003-8 SCC 745	Yes. The rent receipts were received in evidence. (without formal proof)	The rent receipts were ‘not disputed’ by the other side.
Kaliya v. State of Madhya Pradesh, 2013-10 SCC 758	Yes. The secondary evidence of dying declaration produced in this case was accepted by the Court.	Secondary evidence was adduced with foundational evidence (for producing copy; not original)

Cases Cited to support the Proposition –

• MERE MARKING DOES NOT PROVE THE CONTENTS

Decision	Did the proposition – Mere Marking Does Not Prove the Contents – unreservedlyapply?	Reason for NOT MARKING
Ramji Dayawala v. Invest Import: AIR 1981 SC 2085	No. Truth of contents of a letter and two telegrams were not taken. (though marked)	Truth of the facts in the document was “in issue“
M. Chandra v. M. Thangamuthu, 2010-9 SCC 712	No. Validity and Genuineness of the Photocopy (of the Caste Certificate) was not accepted (though marked)	Validity and Genuineness of the Caste Certificate was very much in question
H. Siddiqui v. A. Ramalingam, (2011) 4 SCC 240	No. Contents of the Photocopy was not received as proof (though marked)	Photocopy was shown to the witness during cross-examination alone, and Signature alone was admitted by the witness.
Tarajee Khimchand v. Yelamarti Satyam, AIR 1971 SC 1865	No. Accounts of the Plaintiff was not received as proof (though marked)	The accounts of the Plaintiff would not be proved by itself

The Common Thread

The decisions (in the two tables given above) are harmonious rather than conflicting. Mere marking of a document without objection may dispense with formal proof of its execution or mode of proof. However, where the truth, genuineness, validity, or correctness of the contents is itself in dispute, marking alone does not establish those facts. The evidentiary value of the document must still be independently proved in accordance with law.

End Notes 1

Tharammel Peethambaran v. T. Ushakrishnan,  AIR 2026 SC 938: Facts in a Nutshell

Following are the facts of the decision in Tharammel Peethambaran v. T. Ushakrishnan,  AIR 2026 SC 938:

• Plaint schedule property was alienated by the defendant.
• Plaintiff claimed it to be joint family property.
• The plaintiff challenged the authority of the defendant to alienate.
• The plaintiff contended that there was no valid Power of Attorney in favour of the defendant.
• Only a notarised photocopy of the alleged Power of Attorney was produced.
• The original document was not placed on record.
• No foundational evidence was given for leading secondary evidence.

The Trial Court decreed the suit finding that the the Power of Attorney was not proved.

The Trial Court found:

• If the procedure under Sections 65 and 66 of the Evidence Act is not followed, a photostat copy does not satisfy the requirements of secondary evidence.
• The non-marking of the original of the PoA, coupled with non-compliance with Sections 65 and 66 of the Evidence Act, would render the assertions on the document untenable.

The First Appellate Court reversed the Trial Court’s findings, accepting the PoA.

The High Court restored the findings of the Trial Court.

The Supreme Court of India accepted the views of the High Court and dismissed the Appeal.

End Notes 2

Important Findings (Tharammel Peethambaran v. T. Ushakrishnan)

• “19. The crux of the matter depends on whether Exh. B-2 can be treated as documentary evidence warranting interpretation of the clauses and the alleged contradictions with Exh. A-3 and A-4. Exh. B-2 is a photocopy, or a mechanical copy, of the purported PoA. This, therefore, implies that Exh. B-2 is, at best, secondary evidence. Secondary evidence is evidence that proves the contents of an original document through a medium that is one step removed from the source. Section 63 of the Indian Evidence Act provides an exhaustive list of what constitutes secondary evidence. This includes certified copies, copies made from the original by mechanical processes ensuring accuracy, copies compared with such copies, counterparts of documents against parties who did not execute them, and oral accounts of the contents given by a person who has seen the document.
• 20. The broad parameters summarising the procedure to be followed for introducing secondary evidence are reiterated and read thus:
• 20.1 The fundamental principle of the Indian Evidence Act is that facts have to be established by primary evidence.
  • Jagmail Singh v. Karamjit Singh, (2020) 5 SCC 178. (Para 14) 
• Section 64 mandates that documents must be proved by primary evidence, which is considered the “best evidence”.
• Primary evidence is the rule, while secondary evidence is an exception admissible only in the absence of primary evidence. A party is generally required to produce the best evidence available; so long as the superior evidence (the original) is within a party’s possession or reach, they cannot introduce inferior proof (secondary evidence).
  • Smt. J. Yashoda v. K. Shobha Rani (2007) 5 SCC 730
• 20.2 Before secondary evidence can be admitted, the party relying on it must lay a factual foundation.
• This involves two steps:
  • First, the party must prove that the original document actually existed and was executed.
  • Secondly, the party must establish valid reasons as to why the original cannot be furnished.
  • Kaliya v. State of Madhya Pradesh, (2013) 10 SCC 758
• 20.3 Secondary evidenceis inadmissible until the non-production of the original is accounted for in a manner that brings the case within the specific exceptions provided in Section 65.
  • H. Siddiqui (D) By Lrs. v. A. Ramalingam AIR (2011) SC 1492
• If the original itself is found to be inadmissible through failure of the party who files it to prove it to be valid, the same party is not entitled to introduce secondary evidence of its contents. Smt. J. Yashoda v. K. Shobha Rani (2007) 5 SCC 730
• 20.4 Section 65 of the Evidence Act is exhaustiveand states the specific circumstances under which secondary evidence is permissible.
• To introduce secondary evidence, a party must satisfy the conditions of one of the clauses (a) through (g) of Section 65.
• 20.5 Further, admitting a document as secondary evidence does not automatically prove its contents.
• The secondary evidence must be authenticated byfoundational evidence showing that the alleged copy is, in fact, atrue copyof the original. For instance, if a party wishes to introduce a photostat copy, they must explain the circumstancesunder which the copy was prepared and who possessed the original at the time the photograph was taken.
  • Ashok Dulichand v. Madahavlal Dube and Another (1975) 4 SCC 664; 
  • Chandra v. M. Thangamuthu, (2010) 9 SCC 712.
• 20.6 Mere admission of a document or making it an exhibit does not dispense with the requirement of proving it in accordance with the law. The court has an obligation to examine the probative value of the document and decide the question of admissibility before making an endorsement on the secondary evidence.
• If the foundational facts, such as the loss of the original or the explanation for its non-production, are not established, the court cannot legally allow the party to adduce secondary evidence.
  • Rakesh Mohindra v. Anita Beri, (2016) 16 SCC 483.
• 20.7 There is no requirement that an applicationmust be filed to lead secondary evidence. While a party may choose to file such an application, secondary evidence cannot be ousted solely because no application was filed. It is sufficient if the party lays the necessary factual foundation for leading secondary evidence either in the pleadings or during the course of evidence
  • Dhanpat v. Sheo Ram 2020 (16) SCC 209

Condition for Secondary Evidence# Statutory Clause  #Type of Secondary Evidence Allowed Adversary Possession                            Section 65(a)      Any secondary evidence (after notice). Written Admission                                 Section 65(b)      The written admission itself. Loss or Destruction                               Section 65(c)       Any secondary evidence. Immovable Original                               Section 65(d)      Any secondary evidence. Public Document                                     Section 65(e)      Only a certified copy. Law-Specified Document                     Section 65(f)       Only a certified copy. Voluminous Records                              Section 65(g)      Testimony of a skilled examiner.

• 21. Therefore, the introduction of secondary evidence is atwo-step process, wherein,
  • first, the party must establish the legal right to lead secondary evidence, and
  • second, they must prove the contents of the documents through that evidence.
  • The twin requirements are conjunctive.
• 22. The High Court recorded a finding which is not challenged, that the PoA produced by the 1st Defendant is a notarised photocopy, and not the original document. The 1st Defendant is obligated to follow the procedure for adducing secondary evidence, and thereafter, claim presumption, if any, available to a document so adduced in evidence. It is axiomatic that secondary evidence is permissibleonly as an exception to the requirement of adducing primary evidence.
• 23. ….. In our considered view, neither Section 33 of the Registration Act nor Section 85 of the Evidence Act would come into application if the primary requirement of adducing secondary evidence is discharged by the party relying on the document. Section 85 of the Evidence Act falls under Chapter V, titled Documentary Evidence. In the absence of an original or at least a secondary evidence, it is impermissible to apply Section 85 of the Indian Evidence Act to conclude the execution and extent of authority given by the plaintiff to the 1st defendant. No order is brought to our notice through which secondary evidence is brought on record before the Trial Court. A photocopy of a document is no evidence unless the same is proved by following the procedure set out. Relying on Exh. B-2, the First Appellate Court acted on inadmissible evidence and accepted the existence of power to alienate. Exh. B-2/photocopy is no evidence, and the incorrect reliance on no evidence has been rightly corrected by the High Court through the impugned judgment. The High Court has considered the misreading of evidence by the Appellate Court and, by applying the correct principles of law, allowed the second appeal.”

End Notes 3

Legal Findings (Tharammel Peethambaran v. T. Ushakrishnan) Summarised

• The FACTS have to be established by primary evidence.
• DOCUMENTS must be proved by primary evidence.
• Primary evidence is the rule, while secondary evidence is an exception.
• A factual foundation must be laid before admitting secondary evidence
• This involves two steps:
  • First, prove that the original document actually existed and was executed.
  • Secondly, establish valid reasons as to why the original cannot be furnished.
• Secondary evidence is inadmissible until the non-production of the original is accounted.
• Section 65 of the Evidence Act is exhaustive
• The introduction of secondary evidence is a two-step process.
  • First, the party must establish the legal right to lead secondary evidence, and
  • Second, they must prove the contents of the documents through that evidence.
  • The twin requirements are conjunctive.
• Admitting a secondary evidence does not prove its contents.
• The secondary evidence must be shown to be, in fact, a true copy.
• Section 63 provides an exhaustive list of what constitutes secondary evidence.
• Mere admission of a document as an exhibit does not dispense with proof.
• The court has an obligation to examine the probative value of the document and decide the question of admissibility before making the secondary evidence.
• If the foundational facts (loss of the original) are not established, the court cannot legally allow the party to adduce secondary evidence.
• There is no requirement that an application must be filed to lead secondary evidence.

R.V.E. Venkatchalla Gounder v. Arulmighu Viswesaraswamy: Relevant Findings

In R.V.E. Venkatchalla Gounder v. Arulmighu Viswesaraswamy and V.P. Temple, (2003) 8 SCC 752 (R.C. Lahoti, Ashok Bhan, JJ.), held as under:

• “Ordinarily an objection to the admissibility of evidence should be taken when it is tendered and not subsequently.
• The objections as to admissibility of documents in evidence may be classified into two classes:-
  • .(i) an objection that the document which is sought to be proved is itself inadmissible in evidence; and
  • (ii) where the objection does not dispute the admissibility of the document in evidence but is directed towards the mode of proof alleging the same to be irregular or insufficient.
• In the first case, merely because a document has been marked as ‘an exhibit’, an objection as to its admissibility is not excluded and is available to be raised even at a later stage or even in appeal or revision.
• In the latter case, the objection should be taken before the evidence is tendered and once the document has been admitted in evidence and marked as an exhibit, the objection that it should not have been admitted in evidence or that the mode adopted for proving the document is irregular cannot be allowed to be raised at any stage subsequent to the marking of the document as an exhibit. The later proposition is a rule of fair play. The crucial test is whether an objection, if taken at the appropriate point of time, would have enabled the party tendering the evidence to cure the defect and resort to such mode of proof as would be regular. The omission to object becomes fatal because by his failure the party entitled to object allows the party tendering the evidence to act on an assumption that the opposite party is not serious about the mode of proof. On the other hand, a prompt objection does not prejudice the party tendering the evidence, for two reasons: firstly, it enables the Court to apply its mind and pronounce its decision on the question of admissibility then and there; and secondly, in the event of finding of the Court on the mode of proof sought to be adopted going against the party tendering the evidence, the opportunity of seeking indulgence of the Court for permitting a regular mode or method of proof and thereby removing the objection raised by the opposite party, is available to the party leading the evidence. Such practice and procedure is fair to both the parties. Out of the two types of objections, referred to hereinabove, in the later case, failure to raise a prompt and timely objection amounts to waiver of the necessity for insisting on formal proof of a document, the document itself which is sought to be proved being admissible in evidence.
• In the first case, acquiescence would be no bar to raising the objection in superior Court.”
• This view is also found in
  • Neeraj Dutta v. State (Govt. of Delhi) [2023] 4 SCC 731: five-Judge Bench
  • Smt. Dayamathi Bai v. K.M. Shaffi, AIR 2004 SC 4082.
  • Iqbal Basith v. N Subbalakshmi,(2021) 2 SCC 718;  
  •  PC Thomas v. PM Ismail, AIR 2010 SC 905; 2009-10 SCC 239
  • Oriental Insurance Co  v. Premlata:   2007-8 SCC 575
  • Thimmappa Rai v. Ramanna Rai,(2007) 14 SCC 63
  • Narbada Devi v. Birendra Kumar: 2003-8 SCC 745. 

Decisive decisions on Marking Documents Without Objection

Following are the decisive decisions on marking Docuements without objection

P.C. Purushothama Reddiar v. S. Perumal,(1972) 1 SCC 9 (Three Judge Bench – A.N. Grover, K.S. Hegde, A.N. Ray, JJ.)	Admissibility of police reports without examining the Head Constables who covered those meetings. Those reports were marked without any objection.  Hence it was not open to the respondent to object to their admissibility.	Relied on Bhagat Ram v. Khetu Ram, AIR 1929 PC 110.
R.V.E. Venkatchalla Gounder v. Arulmighu Viswesaraswamy and V.P. Temple, (2003) 8 SCC 752 (R.C. Lahoti, Ashok Bhan, JJ.)	Photo copies were  admitted in evidence  without leading foundation – without objection. They cannot be held inadmissible for originals were not produced.	Relied on Padman v. Hanwanta, AIR 1915 PC 111 P.C. Purushothama Reddiar vs. S.Perumal
PC Thomas v. PM Ismail, AIR 2010 SC 905; 2009-10 SCC 239.	Non-examination and absence of “proof of acknowledgment” by the author – If no objection on ‘mode of proof’ in trial court, it will be too late (in appeal) to raise objection on the ground of mode of proof – that is, “non production of John K as a witness”.	…
Rafia Sultan v. Oil And Natural Gas Commission (I.C. Bhatt, S.B. Majmudar, JJ.), 1986 ACJ 616; 1986 Guj LH 27; 1985-2 GujLR 1315	No objection about the truth of contents of Ex. 32. The witness of the defendant accepted the contents. Therefore, too late in the day to canvass that contents of Ex. 32 were not proved.	…
Smt. Dayamathi Bai v. K.M. Shaffi, AIR 2004 SC 4082	Objection to be taken (secondary evidence) at trial before document is marked as an ‘exhibit’ and admitted to the record.	Relied on Gopal Das v. Sri Thakurji, AIR 1943 PC 83; R.V.E. Venkatchalla Gounder v. Arulmighu , (2003) 8 SCC 752
Sarkar on Evidence .	If copies of the documents are admitted without objection in the trial Court, no objection can be taken in appeal	Referred to in: Smt. Dayamathi Bai v. K.M. Shaffi, AIR 2004 SC 4082.

EFFECT OF MARKING DOCUMENTS WITHOUT OBJECTION

Effect of marking a document without formal proof on admission (or without objection) is also a subject of controversy.

Propositions Analysed

First view (a) Proof (Contents and ‘Truth of its Contents’) stands established.  It cannot be questioned afterwards. (b) Truth also: See: Rafia Sultan v. Oil And Natural Gas Commission, 1986 ACJ 616; 1985-2 GujLR 1315. (c) Admission of contents – but, does not dispense with proof of truth of its contents.	(a) RVE Venkatachala Gounder v. Arulmigu Viswesaraswami: AIR 2003  SC  4548; (b) Rafia Sultan v. Oil And Natural Gas Commission (I.C. Bhatt, S.B. Majmudar, JJ.), 1985-2 GujLR 1315: No objection about the truth of contents … before the trial Court. … It is therefore too late in the day for Miss Shah for the Commission to canvass for the first time before us in appeal. Neeraj Dutta Vs. State (Govt. of N.C.T. of Delhi) reported in [2023] 4 SCC 731: If no objection as to its mode of proof , no such objection could be allowed to be raised at any later stage. (c) Sait Tarajee Khimchand v. Yelamarti Satyam, AIR 1971 SC 1865; Nandkishore Lalbhai Mehta v. New Era Fabrics, AIR 2015 SC 3796.
Second View Even if no objection, it does not dispense with proof (as to, both, existence of the document and its truth). In such a case the document will not be taken as proved. (Note: It may not be legitimate to apply this principle literatim. A close analysis of each case is essential.)	LIC v. Ram Pal Singh Bisen: 2010-4 SCC 491 (Filing of the Inquiry Report or the evidence adduced during the domestic enquiry); H. Siddiqui v. A. Ramalingam, (2011) 4 SCC 240 (Copy of a power of attorney alone was shown to the respondent during cross-examination and he admitted his signature thereon only, and not its contents); Mal Singhvi v. Anand Purohith: 1988 (Supp) SCC 604 (date of birth).
Third view If truth is in issue, mere proof of contents, or marking without objection, is not proof of truth.	See: Narbada Devi Gupta v. Birendra Kumar Jaiswal, 2003-8 SCC 745; Ramji Dayawala Vs. Invest Import: AIR 1981 SC 2085.
Fourth view Admission of contents, and dispenses with proof and truth; but its probative value will be a matter for appreciation by court.	See: State of Bihar v. Radha Krishna Singh, AIR 1983 SC 684 (Admission and probative value – different); Rakesh Mohindra v. Anita Beri: 2015  AIR(SCW) 6271; Kaliya v. State of MP: 2013-10 SCC 758;  H. Siddiqui v. A. Ramalingam: AIR 2011 SC 1492;  Rasiklal Manikchand  v. MSS Food Products: 2012-2 SCC 196.
Fifth view Admission of contents, and dispenses with proof and truth; but Court should require (in proper cases) the party producing the document to adduce proper evidence, and to cure formal defects, invoking –               • Sec. 165 of Evidence Act               • Sec. 58 of Evidence Act               • O. XII, r. 2A Proviso, CPC and               • Sec. 294 of the CrPC.	See: Harkirat Singh v. Amrinder Singh, (2005) 13 SCC 511; Umesh Challiyil v. K.P. Rajendra, (2008) 11 SCC 740; KK Ramachandran Master v. MV Sreyamakumar, (2010) 7 SCC 428; AIR 2015 SC 3

Chapter V of the Evidence Act deals with Documentary Evidence

Sections 61 to 65 deal generally with Preliminary Aspects as to Admissibility. It can be summarised as under:

• Section 61. The contents of documents may be proved either by primary or by secondary evidence.
• Section 62. Primary evidence means the document itself
• Section 63. Secondary evidence. Secondary evidence means and includes–
  • .(1) certified copies
  • (2) copies made by mechanical processes
  • (3) copies compared with the original  
  • (4) counterparts of documents
  • (5) oral accounts
• Section 64 Documents must be proved by primary evidence.
• Section 65. Cases in which secondary evidence may be given.
  • .(a) when the original is in the possession of the person against whom…
  • (b) when the existence, condition or contents admitted in writing
  • (c) when the original has been destroyed or lost,
  • (d) when the original is not to be easily movable  
  • (e) when the original is a public document
  • (f) when a certified copy is permitted to be given in evidence
  • (g) when the originals consist of numerous accounts …

Proof on Documents- General Provisions

1. Section 91 expressly bars oral evidence to prove the terms of a contract if they are reduced to writing.

2. Sec. 22 and 144 of the Evidence Act postulate that the oral assertions as to contents of documents are not.

Modes of Proof of Documents

Modes of Proof of Documents (as to, both, ‘formal proof’ and ‘truth of the contents’) include the following:

• Admission  (Sec. 17, 21, 58, 67, 70).
• Evidence of a person who has seen – ocular evidence (Sec. 59).
• An attesting witness (Sec. 59).
• Opinion of one who is acquainted with the writing (Sec. 47).
• Admission  in judicial proceedings (Sec. 32, 33).
• Handwriting expert-opinion evidence/scientific evidence (Sec.45).
• Evidence of one in the ordinary course of his business or official duty  (Sec. 32, 34, 35 or 114).
• Invoking (specific) presumptions under Sec. 79 to 90A.
• Presumptions (general) under Sec. 114.
• Circumstantial evidence: on probability or inferences (Sec. 114).
• Court-comparison (Sec. 73).
• Facts judicially noticeable (Sec. 56 and 57).
• A fact of common-knowledge. (It does not require proof. See: Union Of India Vs. Virendra Bharti: 2011-2 ACC 886, 2010  ACJ 2353; Rakhal Chakraborty Vs. Sanjib Kumar Roy: 1998-1 GauLR 253, 1997-2 GauLT 705)

Internal evidence afforded by the contents of the document; a link in a chain of correspondence; recipient of the document. (Mobarik Ali Ahmed Vs. State of Bombay, AIR 1957 SC 857).