Adv. Saji Koduvath, Advocate, Kottayam.

Preface

• A photograph can be taken by the court as primary evidence (See: Section 57, Explanation 3 and 5 of the BSA).
• Where a photograph is itself the original photographic record, it is primary evidence. In the case of digital photographs, the Bharatiya Sakshya Adhiniyam recognises electronically stored originals under Section 57 Explanation (5).
• Reliability of a photograph depends upon the facts and circumstances, and it is left to the appreciation of the court.
• S. 63(4) Certificate is Not an Essential Prerequisite for the Admission of a Printed Photograph in Evidence,
• A printed photograph, though originating from a digital device, need not invariably be tendered as a ‘computer output’ under Section 63. Where it is proved under the ordinary law (see Section 61**) relating to photographs by a witness competent to identify and prove it, a Section 63(4) certificate is unnecessary.
  • **Section 61 BSA expressly says nothing in the Adhiniyam shall deny admissibility of an electronic or digital record merely because it is in electronic form.

Read also:

• S. 63(4) Certificate is Not an Essential Prerequisite for the Admission of a Printed Photograph in Evidence
• Photographs and Videos: Admissibility, and Proof Invoking Presumptions and ‘Silent Witness’ Theory
• Pictorial Testimony Theory and Silent Witnesses Theory in Law of Evidence
• Admissibility of Visual and Audio Evidence (Including Photographs, Cassettes, Tape-recordings, Films, CCTV Footage, CDs, e-mails, Chips, Hard-discs, Pen-drives)
• ‘STATEMENTS’ alone can be proved by ‘CERTIFICATE’ under Sec. 65B Evidence Act.

Photograph Evidence in a Nutshell

Photographs are admissible in evidence as documents.	P.  Gopalkrishnan @ Dileep v. State of Kerala, AIR 2020 SC 1; 2020-9 SCC 161
A person sees a display may give evidence (as to the Place and Persons)	Taylor v. Chief Constable of Cheshire [1987] 1 All ER 225, 84 Cr.App. Rep 191, DC.]; P. Gopalakrishnan v. State of Kerala, AIR 2020 SC 1
Persons having knowledge of a person, scene, etc., can testify photo and a video.	P.  Gopalkrishnan @ Dileep v. State of Kerala, AIR 2020 SC 1; 2020-9 SCC 161; Shoor Singh v. State of Uttarakhand, AIR 2024 SC 4551; Santhosh Madhavan @ Swami Amritha Chaithanya v. State of Kerala, 2014 Ker HC 31; Anu C.R. v. State of Kerala, 2025(7) KHC 150; 2026(6) KLT (SN) 2.
While considering a case on dowry death, the prosecution argued that a photograph was not admissible in evidence as neither the person who took the photograph nor its negative was produced in evidence. But, the court accepted the photograph as ‘no dispute was raised by the prosecution witnesses’.	Shoor Singh v. State of Uttarakhand, AIR 2024 SC 4551.
The victim killed by burning was identified by a photograph. It was held that even without noticing any translatable mark or feature of a person, it would be possible to identify him later.	Ponnappan v. State of Kerala, ILR 1994(3) Ker 370 (KT Thomas, J.)
A large number of photographs were marked and considered in this case. In para 525, it is stated – the witness “was confronted with photographs of the inscription” There were three sets of albums containing photographs taken by the State Archaeological Department pursuant to an order dated 10 January 1990 (Para 533). In para 538, the Court considered the evidence of a witness as to the “photographs placed within the structure in 1990”.	M.  Siddiq v. Mahant Suresh Das, 2020-1 SCC 1 (Ayodhya case)
A Witness can be Confronted with a Photograph of the place of occurrence During Cross-Examination Without its Prior Production	Anu C.R. v. State of Kerala, 2025(7) KHC 150; 2026(6) KLT (SN) 2
The factum of photo identification (of an accused) by PW 2, as witnessed by the officer concerned, is a relevant and admissible piece of evidence.	Rabindra Kumar Pal v.  Republic of India, 2011-2 SCC 490 (Manu Sharma v. State (NCT of Delhi), 2010-6 SCC 1, referred to).
Nothing prevented the appellant-State Government from producing the relevant photographs of the purported pucca pond existing at some spots.	State of Rajasthan v. Ultratech Cement Ltd. , 2022-12 Scale 606; 2022-13 SCR 1
A statement about the photograph made by any expert would not be admissible before examining the photographer.	Dr. Pankaj Kumudchandra Phadnis v. Union of India, (2018) 5 SCC 785
Photographs, tape-records of speeches [Ziyauddin Burhanuddin Bukhari v. Brijmohan Ramdas Mehra, (1976) 2 SCC 17] are documents.	Shamsher Singh Verma v. State of Haryana, 2016 15 SCC 485; Nilesh Dinkar Paradkar v. State of Maharashtra, 2011-4 SCC 143
Photo identification of an accused during the investigation, who was seen by the witness at the relevant time.	Umar Abdul Sakoor Sorathia v. Intelligence Officer, Narcotic  AIR 1999 SC  2562, 2000-1 SCC 138; Manu Sharma v. State (NCT of Delhi), (2010) 6 SCC 1
Inventory, photographs and the list of samples certified by the Magistrate are admissible as primary evidence. It is a substitute for the production of physical evidence of seized contraband samples.	Nisar Ahmed Bhat, v. Union Territory of Jammu and Kashmir 2024 0 Supreme(J&K) 187
The tape record corroborated his testimony, as a photograph taken without the knowledge of the person photographed can become relevant and admissible so does a tape record of a conversation unnoticed by the talkers. A contemporaneous tape record of a relevant conversation is a relevant fact and is admissible under section 8 of the Evidence Act. It is res gestae.	K. K. Velusamy v. N. Palanisamy, 2011-11 SCC 275; R.M Malkani v. State of Maharastra, AIR 1973 SC 157; Yusaf Ali lsmail Nagri v. The State of Maharashtra, 1967- 3 S.C.R. 720

Photo and Video: Relevant and Admissible

Audio/Video cassettes	Ziyauddin Burhanuddin Bukhari v. Brijmohan Ramdas Mehra, (1976) 2 SCC 17
Tape records of speeches	Tukaram S. Dighole v. Manikrao Shivaji Kokate, (2010) 4 SCC 329
Photo or video	Mohammed Rafiq v. Madhan, 2018-1 Mad LJ(CRI) 641; Moti Rabidas v. The State of Bihar, 2015-145 AIC 435; Vaman Narain Ghiya v. State of Rajasthan 2014-1 Raj Cri C 31; State of MP v. Shankarlal, ILR 2010 MP 717; P Rajagopal v. Inspector of police 2009-2 Mad LJ(Cri) 161; Santhosh Baccharam Patil v. State of Maharashtra, 2002 All MR (Cri)997, 2003 BCR (Cri) 120.
CD	Shamsher Singh Verma v. State of Haryana, (2016) 15 SCC 485
Photographs including photographs of tombstones and houses	Lyell v. Kennedy (No.3) (1884) 50 L.T. 730
Video recordings	State of Maharashtra v. Praful B.Desai, AIR 2003 SC 2053
Audio and video	State of Maharashtra v. Praful B.Desai, AIR 2003 SC 2053; Santhosh Madhavan @ Swami Amritha Chaithanya v. State :2014 KHC 31; Taylor v. Chief Constable Cheshire:1987(1) All.ER 225
Cassettes	Tukaram S.Dighole v. Manik Rao Shivaji Kokate (2010)4 SCC 329
Moving cinematograph	Senior v. Holdsworth, Ex parte Independant Television New Ltd. (1976) Q.B. 23)
Film	Rex v. Daye ((1908)2 K.B. 333, 340)
Floppies, CCTV footages, CDs, DVDs, Chips, Hard discs, Pen drives–	North West Airlines v. Union of India 2007 (214) ELT 178 (Bom.)

Introduction

Only relevant and admissible evidence can be received by a court. Unless its authenticity is admitted by the opposite party, a photograph must be duly authenticated. Authentication consists of establishing that the photograph fairly and accurately depicts the scene, object or person that it purports to represent. Such authentication need not be provided by the photographer. Any person having personal knowledge of the depicted subject matter may testify that the photograph is a true and accurate representation of what he observed.

Photograph is Primary Evidence 

A photograph is primary evidence under Section 62 of the Indian Evidence Act. (P. Rama Srinivasa Rao v. Dr.N. Ragavan, 2006 2 CTC 43 ; 2006 3 MLJ 625, R. Banumathi, J.)

Section 62 reads as under:

• “Primary evidence means the document itself produced for the inspection of the Court.”

Explanation (2) to Sec.62 reads:

• “Where a number of documents are all made by one uniform process, as in the case of printing, lithography, or photography, each is primary evidence of the contents of the rest; but, where they are all copies of a common original, they are not primary evidence of the contents of the original.”

Section 29 of the the Indian Penal Code, 1860, defines document as under:

• 29. “Document”— The word “document” denotes any matter expressed or described upon any substance by means of letters, figures, or marks, or by more than one of those means, intended to be used, or which may be used, as evidence of that matter.
• Explanation 1. ……
• Explanation 2. ……

Special Nature of Photograph

Read:

• S. 63(4) Certificate is Not an Essential Prerequisite for the Admission of a Printed Photograph in Evidence

A contemporary photograph, if objected to by the opposite party, can easily confront it by producing another photograph. It is a peculiarity of photograph-evidence.

Photograph does not fall under “STATEMENT” u/S. 63(4)

Section 63(4) is attracted only when “it is desired to give a STATEMENT“. It reads as under:

• “(4) In any proceeding where it is desired to give a STATEMENT* in evidence by virtue of this section, a CERTIFICATE ….. “

*”Desired to give a STATEMENT“; Not – “desired to give” a ‘Computer Output’

• “STATEMENT” according to BSA is – expressed in ‘oral evidence’.
• Sections: 2(1)(e) – Evidence is statements of witnesses
• 15 -19 – Admission is statement of witness
• 26 – Statement of a dead person
• 28 – Entries in bokks of acctount
• 30 – Statements in maps, plans,
• 31 – Statements in Acts Notification
• 32 – Statements in law books,
• 33 – If longer statemnts 
• 79 – Statement of accused,
• Also See Sections: 89, 94, 95, 125, 147, 148, 158, 160, 161.

The Supreme Court decision in Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal, (2020) 7 SCC 1: AIR 2020 SC 4908, established a strict interpretation. It laid down (before promulgation of Adhiniyam, 2023) that the proof by the certificate under Section 65B (Section 63, Adhiniyam) was mandatory for admitting a computer output (copy) in evidence. It held – “The drill of Section 65A and 65B alone be followed when it comes to admissibility of information contained in electronic records.”

• Therefore, even in cases where formal proof of the digital photos or videos is dispensed with (for the opposite party admits it), a certificate under Section 65B(4) was necessary.
• However, Section 61 of the Adhiniyam made a drastic legislative change to the deliberation presented by Arjun Panditrao Khotkar. By virtue of Section 61, a computer output (i.e., a copy of an electronic record) is capable of being proved by any mode of proof recognised under the Adhiniyam, and is not restricted to proof solely through the certificate.

If No Objection, S. 63(4) Certificate Not Essential

Neither (i) the production of a certificate under Section 63(4) of the Bharatiya Sakshya Adhiniyam, 2023, nor (ii) the examination of the photographer, is an indispensable requirement for proving a photograph (Computer output) where its authenticity is not objected to by the opposite party or accepted by the witness.

• Shoor Singh v. State of Uttarakhand, AIR 2024 SC 4551,
• Jagjit Singh v. State of Haryana, (2006) 11 SCC 1
• State Represented by the Inspector of Police, Chennai v. V. P.  Pandi, 2019 -1 LW(Cri) 421; 2019-1 LW(Cri) 481; 2019-2 MLJ(Cri) 129.

A photograph or a video, by its very nature, speaks for itself. Therefore, the courts in India can commence with a presumption as to the correctness of the photograph or video when its authenticity is prima facie ehed. In such an event, the onus shifts to the opposite party to rebut that presumption by placing material on record sufficient to dislodge the presumption.

• Madhavnagar Cooperative Housing Society Limited v. Joint Registrar and Member, Board of Nominees, 2020-2 GLR 1437
• Chairman, Tamil Nadu Electricity Board, Chennai v. Kogila, 2021-3 CTC 118; 2021-2 LW 28,
• Jetunben v. State of Gujarat, 2017 2 GLR 1640 (video)
• State Represented by the Inspector of Police, Chennai v. V. P.  Pandi, 2019 -1 LW(Cri) 421; 2019-1 LW(Cri) 481; 2019-2 MLJ(Cri) 129.

Photographs showing the nature and lie of the property

Courts look into photographs showing the nature and lie of the property.

• Sachithanandan S. P. v. Vicar, St. Sebastian Church, 2018-4 KHC 233; 2018-3 KLT 840.
• Annamma Mathew v. State of Kerala, 2015 0 Supreme(Ker) 577;
• Ali Akbar v. Maranchery Grama Panchayath, 2013-4 KHC 730; 2013-4 KLT 600

“Men may lie, but Photographs don’t“

In Anurag Sharma v. Manushi Sharma, 2016-10 AD(Del) 353; 2017 AIR(CC) 332; 2017 1 AIR (Del)(R) 55, it is said as under:

• “As the adage goes: men may lie but circumstances don’t; similarly would be the statement: men may lie but photographs don’t. Anurag himself has filed photographs …. and these photographs tell their own story.”
  • Also see: Vikram Singh v. State of Haryana, 2003-1 RCR(Cri) 733-
  • Rajesh Khaitan v. State of WB, 1983 CrLJ 877.

Presumption: Section 119 of the BSA (Section 114 of the Evidence Act) allows the Court to ‘presume the existence of any fact ….. regard being had to the common course of natural events‘. Indian courts have consistently held that, in cases attracting a general presumption, a mere ‘bald denial’ of the contents of a document is inadequate to rebut such presumption.

If the photograph does not fall under the head ‘electronic evidence’ and ‘computer output’, Sections 61 to 63 have no relevance.

Modes of Proof of Photographs

A photograph or video (in proper cases, their secondary evidence) can be proved through the testimony of –

• the photographer
• admission by the opposite party or witness;
• production of the original device containing the image.

They can also be proved through a ‘proper’ witness who is competent to depose by way of general evidence regarding the factual features depicted therein, such as the identity of the persons shown, the place, the time or the surrounding circumstances. They include –

• one who actually witnessed the capturing of the photograph,
• a person who saw the scene and
• one who can identify the place, though not the persons seen in the photo (or the persons and not the place).

Photographs as Evidence and Photo Identification

Photographs are received as evidence in the following cases –

• Umar Abdul Sakoor Sorathia v. Intelligence Officer, Narcotic  AIR 1999 SC  2562, 2000-1 SCC 138 (photograph used during the investigation for identification of the accused)
•  Manu Sharma v. State (NCT of Delhi), (2010) 6 SCC 1 (“The photo identification and TIP are only aids in the investigation and do not form substantive evidence. The substantive evidence is the evidence in the court on oath.)
• Rabindra Kumar Pal v. Republic of India, AIR  2011 SC 1436; 2011 2 SCC 490 (Quoted Manu Sharma v. State (NCT of Delhi), (2010) 6 SCC 1)

Pictorial Testimony Theory and Silent Witness Theory

• Pictorial Testimony Theory – Here, the personal knowledge of the witness is important. The witness testifies, seeing the photograph, that it fairly and accurately represents what he has seen or what is in his knowledge. In such a case, the photograph need not be proved through a proper witness like the photographer. In short, the testimony of the witness is more important (for the court ) than what is depicted in the photograph.
• Silent Witness Theory – Photograph Must Be Proved. The witness need not have actually seen the act of capturing by the camera. CCTV footage and dashboard cameras fall in this category. Here, the photograph speaks for itself. It must be proved that the system that produced it was reliable, as the camera was working properly and it has not been tampered with since capture.

In Santhosh Madhavan @ Swami Amritha Chaithanya v. State (2014 Ker HC 31), these two theories governing the proof and authenticity of photographs were explained.

• First, the pictorial testimony theory: It is applied when a photograph is used merely as an aid to a witness in explaining or illustrating his testimony—for example, a doctor explaining injuries with reference to a photograph, or identification of a deceased through a photograph.  In such a case, the evidence of the witness will be the primary matter rather than what is depicted in the photograph; and the photographer need not be examined in court, since the photograph is admitted merely to aid a witness in explaining his testimony.
• Secondly, under the silent witness theory or communication theory: It is invoked when the photograph itself constitutes substantive and probative evidence of what it depicts, speaking for itself (without the support of oral testimony)—for instance, an X-ray film showing a fracture, a photograph depicting the accused in a crowd holding a weapon (though the photographer did not notice him), or a photograph of the scene of occurrence of a crime. In such cases, the photographs must be proven. In such cases, if needed, it must have been shown that the camera was working properly and that the image was not tampered with since its capture.

Presumptions on Photographs and Videos

Section 119 of the Bharatiya Sakshya Adhiniyam (Section 114 of the Evidence Act) allows the Court to ‘presume the existence of any fact ….. regard being had to the common course of natural events‘.

A photograph or a video, by its very nature, speaks for itself. Therefore, the courts in India can commence with a presumption as to the correctness of the photograph or video when its authenticity is prima facie established. In such an event, the onus shifts to the opposite party to rebut that presumption by placing material on record sufficient to dislodge the presumption.

Invoking this general presumption, the courts in India have consistently held –

• ‘a mere bald denial of the contents of a video recording is insufficient‘; but, ‘there should be material to show that the video clippings are doctored or morphed’.

Photographs – In many cases a Corroborative Piece; It Can be the Best Evidence also

A photograph, being a document, ordinarily requires proof through a proper witness to establish its authenticity and relevance. However, it need not invariably be proved by examining the photographer, and may be proved through any competent witness capable of speaking to the facts depicted or the circumstances of its production. Once duly admitted, a photograph may constitute primary or substantive evidence, though in many cases it is used to corroborate other evidence.

In Tomaso Bruno v. State of Uttar Pradesh, (2015) 7 SCC 178, it is held that CCTV footage can be a ‘Best Evidence‘. The court said it as under:

• “Notwithstanding the fact that the burden lies upon the accused to establish the defence plea of alibi in the facts and circumstances of the case, in our view, prosecution in possession of the best evidence – CCTV footage ought to have produced the same. In our considered view, it is a fit case to draw an adverse inference against the prosecution under Section 114 (g) of the Evidence Act that the prosecution withheld the same as it would be unfavourable to them had it been produced.”

In short, a photograph or video, once duly admitted and properly proved, constitutes substantive evidence. Though in many cases it is relied upon as corroborative evidence, in an appropriate case it may, by itself, establish the fact in issue, independently and without the aid of other evidence.

Silent Witnesses Theory – Photograph /Video ‘Speaks for Itself‘

In State Represented by the Inspector of Police, Chennai v. V. P.  Pandi @ Attack Pandi, 2019 -1 LW(Cri) 421; 2019-1 LW(Cri) 481; 2019-2 MLJ(Cri) 129, the Madras High Court (P.N. Prakash, B. Pugalendhi) explained the “silent witness” theory, stating as under:

• “115. We may also incidentally notice the developments in the law on video and photographic evidence in the West where the “silent witness” theory is deployed to admit video and photographic evidence. The theory proceeds on the footing that photographic and video evidence are “silent witnesses” which speak for themselves. They are substantive evidence of what they portray.”

The following two foreign decisions were specifically dealt with by the High Court:

• (a) State of Nevada v. Archanian, [145 P 3d 1008 (2006)]: The Supreme Court of Nevada admitted the video evidence under the silent witness theory and held as under:
  • “There is no evidence suggesting that the composite videotape was inaccurate, that any relevant or exculpatory information had been deleted from it, or that the modifications made to it adversely affected or obscured the content.”
• (b) Her Majesty v. Jaiyhi He, [2017 ONCJ 790,]: The Ontario Court of Justice in Canada opined to the following effect:
  • The party seeking to tender a video in evidence must show two things to meet the threshold test of admissibility: (i) The video is relevant, showing the crime scene or other evidence linked to the issues at trial; and (ii) the video is authentic — that it accurately represents the events depicted.

Circumstantial Evidence be Used – No Particular Evidence or Class of Witness

In State Represented by the Inspector of Police, Chennai v. V. P.  Pandi @ Attack Pandi, 2019 -1 LW(Cri) 421; 2019-1 LW(Cri) 481; 2019-2 MLJ(Cri) 129, the Madras High Court said further as under:

• “Referring to the Alberta Court of Appeal’s decision in R. v. Bulldog (2015 ABCA 251), the Ontario Court (in Her Majesty v. Jaiyhi He, 2017 ONCJ 790), said: “Circumstantial evidence may be used to authenticate real evidence – Bulldog at para 35. There is no particular evidence or class of witness that must be called to authenticate a video provided the whole of the evidence establishes that the video in question is substantially accurate and a fair depiction.”

“Can a Digital Video only be Authenticated by an Eyewitness”?

This was the second question raised in R. v. Bulldog (2015 ABCA 251). The question was whether a digital video can only be authenticated by an eyewitness or whether a member of any class of witnesses can provide evidence of authentication.

The answer of Alberta Court of Appeal (in R. v. Bulldog) was “No.”

It held as under:

• “[20] [The appellants argue] that Nikolovski sets two preconditions to the admissibility of video recordings – specifically, proof that the video accurately depicts the facts, and that it has not been altered or changed. The appellants refer to the process of establishing these facts as ‘authentication,’ and we are content to adopt that term, since ‘authentication’ simply refers to the process of convincing the court that certain tangible evidence matches the claims made about it . . .
• [21] The second proposition, which relies on R v Doughty, 2009 ABPC 8 (CanLII) at para 37 (citing Elliot Goldstein, Visual Evidence, A Practitioner’s Manual, Vol 1 (Thomson-Carswell, 2007) at 2-19 to 2-20), is that there is an exclusive list of classes of witnesses who can authenticate a video in a manner that meets these two putative Nikolovski preconditions: (1) the camera operator; (2) an eye-witness present when the video is taken who can testify that the video accurately represents what he or she saw; (3) a person qualified to state that the representation is accurate; or (4) an expert witness.
• [22] Based on these two propositions, the appellants argue that the Crown’s evidence in this case could not authenticate the DVD. They submit (but do not really argue) that the authenticating witness was Reddick, who did not create the DVD tendered, did not know who created it, did not know whether the person who did create it used or might have used options which changed the content of the source video footage, was not an expert in the software and in the format changes entailed in copying the DVD and, accordingly, could not give the expert evidence of the effect of format changes which the appellants say is necessary to authenticate the DVD: R v Penney, 2002 NFCA 15 (CanLII), 2002 NFCA 15 at para 24, 210 Nfld& PEIR 209.
• [23]           In short, the appellants say that, absent evidence from a particular class of qualified person verifying that the video recording had not been altered or changed in the course of undergoing various format changes, the DVD was inadmissible.
• . . . . . .
• [34] It will be recalled that the appellants say that, because Reddick does not fit into any of the four categories identified by Goldstein
• [at para. 21 of the judgment and consisting of:
  • (1) the camera operator;
  • (2) an eye-witness present when the video is taken who can testify that the video accurately represents what he or she saw;
  • (3) a person qualified to state that the representation is accurate; or
  • (4) an expert witness.]
• as persons capable of authenticating video evidence, it follows that the Crown could not authenticate the video recording. We assume that the appellants also maintain that none of the other Crown witnesses would fit into those categories, although we observe that Hodge would have fallen into Goldstein’s second category as an eyewitness, had he viewed the video in court and testified that it accurately depicted what he saw. In any event, these categories are not exhaustive in the sense that, if the Crown does not call one of these four kinds of witnesses, the video recording is inadmissible. Rather, other kinds of evidence or different combinations of witnesses may be employed to satisfy a court of the video recording’s substantial accuracy and fairness.”

Person Sees a Display (in Court) may Give Evidence (as to the Place and Persons)

In Taylor v. Chief Constable of Cheshire, (1986) 1 WLR 1479 : (1987) 1 All ER 225: 84 Cr App R 191 (DC), it was held that a video recording of an incident which is in issue is admissible; and a witness who sees an incident on a display or a recording may give evidence (as to the place and persons) of what he sees in the display or a recording.

Evidence can also be given by one who can identify the place, though not acquainted with the persons seen in the photo (or the persons and not the place).

Halsbury’s Laws of England

In Halsbury’s Laws of England [Fourth Edition, 2006 reissue, Vol. 11(3) Criminal Law, Evidence and Procedure], dealing with Chapter – “Documentary and Real Evidence”, it is stated as under:

• “1471.  Audio and video recordings.–An audio recording is admissible in evidence provided that the accuracy of the recording can be proved, the recorded voices can be properly identified, and the evidence is relevant and otherwise admissible [R. v. Maqsud Ali, (1966) 1 QB 688 : 49 Cr App Rep 230 (CCA).
• For the considerations relevant to the determination of admissibility see R. v. Stevenson, (1971) 1 WLR 1 : (1971) 1 All ER 678 : 55 Cr App R 171; R. v. Robson, (1972) 1 WLR 651 : (1972) 2 All ER 699 : 56 Cr App R 450. See also R. v. Senat, (1968) 52 Cr App R 282 (CA); R. v. Bailey, (1993) 3 All ER 513 : 97 Cr App R 365 (CA).
• Where a video recording of an incident becomes available after the witness has made a statement, the witness may view the video and, if necessary, amend his statement so long as the procedure adopted is fair and the witness does not rehearse his evidence : R. v. Roberts, 1998 Crim LR 682 : 162 JP 691 (CA).] .
• However, that evidence should always be regarded with caution and assessed in the light of all the circumstances [R. v. Maqsud Ali, (1966) 1 QB 688 : 49 Cr App Rep 230 (CCA).
• As to the use of tape recordings and transcripts see R. v. Rampling, 1987 Crim LR 823 (CA); and see also Butera v. Director of Public Prosecutions, (1986) 76 ALR 45 (Aust HC).
• As to the tape recording of police interviews see para 971 et seq ante; and as to the exclusion of a tape recording under the Police and Criminal Evidence Act, 1984, Section 78 (as amended) (see para 1365 ante) as unfair evidence see R. v. H, 1987 Crim LR 4 (CC), Cf R. v. Jelen, (1989) 90 Cr App R 456 (CA) (tape recording admitted despite element of entrapment).]
• Audio and video recordings – A video recording of an incident which is in issue is admissible [Taylor v. Chief Constable of Cheshire [1987] 1 All ER 225, 84 Cr.App. Rep 191, DC.].
• There is no difference in terms of admissibility between a direct view of an incident and a view of it on a visual display unit of a camera or on a recording of what the camera has filmed. A witness who sees an incident on a display or a recording may give evidence of what he saw in the same way as a witness who had a direct view [Taylor v. Chief Constable of Cheshire [1987] 1 All ER 225, 84 Cr. App. Rep 191, DC.
• As to the admissibility of video recordings as evidence identifying the defendant, see also R. v. Fowden and White [1982] Crim. LR 588, CA; R. v. Grimer [1982] Crim. LR 674, CA; R. v. Blenkinsop [1995] 1 Cr.App. Rep 7, CA.
• A recording showing a road on which an incident had occurred was admitted in R. v. Thomas [1986] Crim. LR 682.
• As to the identification of the defendant by still photographs taken by an automatic security camera, see R. v. Dodson, R. v. Williams [1984] 1 WLR 971, 79 Cr. App. Rep 220, CA; as to identification generally see para 1455 ante; and as to the admissibility of a copy of a video recording of an incident see Kajala v. Noble (1982) 75 Cr.App. Rep 149, CA..”
• (Quoted in: P. Gopalakrishnan v. State of Kerala, AIR 2020 SC 1; Sri. Prajwal Revanna vs State By Karnataka, 2025:KHC:1747)

Witness Acquainted with a Person, Scene, etc. can Testify Photo and Video

Indian courts have accepted the “pictorial testimony” approach, under which a photograph may be authenticated by a witness having personal knowledge of the person, place, object, or scene depicted therein and who can testify that the photograph is a fair and accurate representation of what he observed.

Examination of the photographer is not an indispensable requirement in every case. The principle finds support in

• Santhosh Madhavan @ Swami Amritha Chaithanya v. State of Kerala, 2014 Ker HC 31
• P. Gopalkrishnan @ Dileep v. State of Kerala, AIR 2020 SC 1; 2020-9 SCC 161
• Shoor Singh v. State of Uttarakhand, AIR 2024 SC 4551.

Should Photographer Necessarily be Examined?

No. In Shoor Singh v. State of Uttarakhand, AIR 2024 SC 4551, the question came for consideration included the following –

• “The photograph (Ex. Kha-1) was not admissible in evidence as neither the person who took the photograph nor its negative was produced in evidence.”

The Court considered it and accepted the photograph observing as under:

• “A photograph of the deceased (Ex. Kha 1), regarding which no dispute was raised by the prosecution witnesses, showing her alone with a male stranger, had surfaced. In the statement under Section 313 CrPC, a stand was taken that this photograph had shamed her. ….”

Should there be Proof – Video not been Altered or Changed?

The appellants in R. v. Bulldog (Alberta Court of Appeal) challenged the authenticity and admissibility of the DVD. They relied on R. v. Nikolovski, [1996] 3 S.C.R. 1197.    The Court considered whether the Crown was bound to prove that the video recording had not been altered or changed. The appellants argued that R. v. Nikolovski mandated a two-fold test (i) requiring proof that the video accurately depicted the facts and (ii) proof that it had not been altered or changed. The Alberta Court of Appeal disagreed. It held (paragraphs 26 to 33):

• 1. As long as other evidence satisfied the accuracy, no evidence regarding the presence or absence of alteration was necessary.
• 2. The mere fact of alteration did not automatically render a video recording inadmissible.
• 3. The Crown’s failure to establish that the DVD was not altered was not fatal as long as the Crown had proven that the DVD was a substantially accurate and fair representation of what it purported to show.

The Alberta Court of Appeal said it as under:         

• “[26]  . . . the appellants say that Nikolovski creates a two-part test which must be met before admitting video evidence, requiring the Crown to show not only that the video recording accurately depicts the facts, but also that it has not been altered or changed. This is incorrect.
• [27]  It must first be borne in mind that Nikolovski was not a case about the admissibility of a video recording (which had been conceded), but rather about identity (specifically, whether a trier of fact could identify the accused beyond a reasonable doubt as the offender by relying solely upon that video recording). The critical passage from Nikolovski, para 28 upon which the appellants rely, is found under a heading discussing ‘Use That Can Be Made of Photographs or Videotapes,’ which clearly presupposes admissibility.
• [28]      Further, the passage itself fails to support the appellants’ contention. It reads as follows: 
• Once it is established that a videotape has not been altered or changed, and that it depicts the scene of a crime, then it becomes admissible and relevant evidence.
• This statement does not state a necessary condition for admission, but rather a sufficient condition. It does not, even implicitly, preclude admission of video recordings under other circumstances. Indeed, where an alteration enhances a video recording, its accuracy might well be served by such an alteration: R v Jamieson, [2004] OTC 369 at paras 36-37, [2004] OJ No 1780 (QL) (SCJ).
• [29] We do agree with the appellants, however, that in some cases Nikolovski has been taken as requiring the tendering party to show an absence of alteration or change: Penney; R v.MacNeil, 2008 QCCS 915 (CanLII) at para 11, [2008] QJ No 1784 (QL); R v Chevannes, 2011 ONCJ 754 (CanLII) at para 16, [2011] OJ No 5937; R v Ellard, 2004 BCSC 780 (CanLII) at para 11, [2004] BCJ No 2914. In Penney, for example, the Newfoundland and Labrador Court of Appeal (at para 17) cited Nikolovski as authority for the statement that ‘[e]vidence establishing that the video has not been altered or changed is a precondition to its admission as evidence.’ With respect, we do not read Nikolovski as stating so broad a proposition, and we see no principled reason to support it. Indeed, taken to its extreme, it could render almost any DVD left unattended next to a computer inadmissible . . .
• [30]  Other courts have taken a different view of Nikolovski, to the effect that a video recording may be admitted into evidence, even if it has been altered in some way, so long as it is shown to be a substantially accurate depiction of the event in question. In R v Brown, [1999] OTC 213, [1999] OJ No 4865 (CJ), where the Crown sought to tender at trial a security surveillance videotape and enhanced copies, the court stated (at para 3) that, when a videotape has been altered, the test for admissibility is: one of substantial accuracy . . . [T[he Crown must … prove on a balance of probabilities the substantial accuracy of the original tape and the enhancements of it to obtain the permission of the court to tender them in accordance with [Nikolovski] ….
• [31] Similarly, in R v Crawford, 2013 BCSC 2402 (CanLII) at para 48, [2013] BCJ No 2879 (emphasis added), the court said that Nikolovski should be interpreted in a ‘purposive’ manner, such that a video recording’s admissibility is not precluded, even if ‘complete accuracy’ no longer subsists, so long as ‘the alteration of the recorded event is not so substantial as to be misleading’ or ‘if the image is distorted or otherwise changed in a material way.’ What matters, said the court in Crawford, is that the video recording ‘accurately and fairly presents he information that it is to convey.’ Other courts, including this Court, said much the same thing prior to Nikolovski . . .
• [32] There is an important distinction between recordings (video or audio) and other forms of real evidence (such as a pistol or an article of clothing found at a crime scene) which supports a test of ‘substantial’ accuracy over the appellants’ preferred test of ‘not altered.’ It will be recalled that ‘authentication’ simply requires that the party tendering evidence establish (to the requisite standard of proof, which we discuss below) the claim(s) made about it. What authentication requires in any given instance therefore depends upon the claim(s) which the tendering party is making about the evidence. In the case of most real evidence, the claim is that the evidence is something – the pistol is a murder weapon, or the article of clothing is the victim’s shirt. Chain of custody, and absence of alteration will be important to establish in such cases. In the case of recordings, however, the claim will typically be not that it is something, but that it accurately represents something (a particular event). What matters with a recording, then, is not whether it was altered, but rather the degree of accuracy of its representation. So long as there is other evidence which satisfies the trier of fact of the requisite degree of accuracy, no evidence regarding the presence or absence of any change or alteration is necessary to sustain a finding of authentication.
• [33] Put simply, the mere fact of alteration does not automatically render a video recording inadmissible. It follows that the Crown’s failure to establish that this video recording was not altered should not be fatal, so long as the Crown proves that it is a substantially accurate and fair representation of what it purports to show. All this is, of course, subject to the standard framework for admission, under which a video recording may be excluded on the basis of irrelevance (Penney), where its prejudicial effect exceeds its probative value (R v Veinot, 2011 NSCA 120 (CanLII) at paras 24-27, 311 NSR (2d) 267), or where there is reasonable doubt that the video identifying the accused is a fabrication.”

“Balance of Probabilities“

In R v Penney, (2002) 163 CCC (3d) 329, the court considered the ‘falsification of evidence’ and pointed out that the members of a jury ‘can be expected to have, if not experience with, knowledge of the possibilities for manipulating the content of photographs and videotapes’, and concluded that the ‘standard by which the trial judge is to determine the question is on the balance of probabilities’.

Bald Denials are Insufficient to Discredit the Authenticity of Video Footage

The Madras High Court, in this decision (State Represented by the Inspector of Police, Chennai v. V. P.  Pandi), also observed as under:

• “113. It is true that the cameraman can zoom or minimize an image. It is also true that trick photography is possible. In Suo Motu taken up (PIL) WP Chief Secretary to the Government of Tamil Nadu v. The Government of Tamil Nadu and others (WP 3335 etc. of 2009) decided on 29.10.2009, a Division Bench of this Court (F.M. Ibrahim Kalifulla and R. Banumathi, JJ) held that bald denials are insufficient to discredit the authenticity of video footage. In her lead judgment, Banumathi, J (as she then was) has opined as under:
  • ‘349. That a bald denial of the contents of a videotape is not adequate to doubt its authenticity; there should be material to show that the video clippings are doctored or morphed’.
• The Division Bench proceeded to look into the video tape as a corroborative piece of evidence and held as under:
  • ‘350. The respondents have not disputed that the video clippings filed by the petitioners relate to the occurrence. Even though video clippings filed by the petitioners do not have the running time, we have watched the videos and looked into the photos as corroborative piece of evidence’.”

In Jagjit Singh v. State of Haryana, (2006) 11 SCC 1, the conclusion of the Speaker on CDs received from TV News channels, that ‘there is no room for doubting the authenticity and accuracy of the electronic evidence produced by the petitioner’, was accepted by the Apex Court holding as under:

• “The petitioners despite grant of opportunity had declined to watch the recorded interview. It is one thing to watch the interview, point out in what manner the recording was not genuine but instead of availing of that opportunity, the petitioners preferred to adopt the course of vague denial.”

In Umesh v. State of Karnataka, 2023-2 KarLJ 397, while dealing with a ‘trap case’, after laying down the importance of digital evidence, it is cautioned as under:

• “Qualified and trained expert should test the samples. The report should contain the procedure adopted for testing the samples. The equipments used should be duly calibrated and updated periodically. The electronic device should be tested for editing and tampering in order to establish its genuineness and authenticity.
• Digital evidence form be created for every memory card/chip used in the trap case containing the unique identification features of the memory chip/card used. The defence should be provided with a cloned copy or a mirror image of the electronic device.”

Distinct Evidentiary Position of a Section 63(4) Certificate

Once the Section 63(4) certificate accompanies the computer output (copy), the computer output becomes admissible in evidence, and it is not mandatory to examine the CCTV operator, or the person who snapped the photograph, for the purpose of its admission.

• See: Anvar P.V. v. P.K. Basheer, (2014) 10 SCC 473,
• Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal, (2020) 7 SCC 1.

The Person Who Signed Section 63/65B Certificate Need Not Be Examined: Having regard to the special features of the photographs and videos (that is, visual depictions of facts), even if the Section 63(4) certificate is not that given either by the plaintiff or by the defendant, but by another, the photograph or video can be marked in evidence through the plaintiff or the defendant.

Unless the authenticity or correctness of the certificate issued under Section 63(4) is specifically disputed, oral evidence has no role to play in proving (for the purpose of marking) that the computer output is the exact copy of the (original) electronic record. Therefore, the photographer who issued the certificate under Section 63(4) need not be examined if the correctness of the certificate is not specifically disputed.

In Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal, (2020) 7 SCC, our Apex Court further affirmed as under:

• “50. … However, in cases where either a defective certificate is given, or in cases where such certificate has been demanded and is not given by the concerned person, the Judge conducting the trial must summon the person/persons referred to in Section 65B(4) of the Evidence Act, and require that such certificate be given by such person/persons.”

Presumption on Computer Output (copy) Admitted under Sec. 63

A computer output (copy) of a CCTV footage or video, or of a photograph captured on a mobile phone, can be admitted in evidence in place of the original — if it is produced with a certificate under Section 63(4) of the BSA.

• Note: Section 63(1), BSA says about admissibility of copy — “Notwithstanding anything contained in this Adhiniyam, any information contained in an electronic record which is printed on paper, stored, recorded or copied in optical or magnetic media or semiconductor memory which is produced by a computer or any communication device or otherwise stored, recorded or copied in any electronic form (hereinafter referred to as the computer output) shall be deemed to be also a document, if the conditions mentioned in this section are satisfied in relation to the information and computer in question and shall be admissible in any proceedings, without further proof or production of the original, as evidence or any contents of the original or of any fact stated therein of which direct evidence would be admissible.”
• The opening words in the Section, “Notwithstanding anything contained in this Act,” are directed only to the statutory fiction that a computer output shall be deemed to be an electronic record (i.e., the original document). The non obstante clause is confined to this deeming provision. It should not be construed as overriding every provision of the Act relating to the proof or admissibility of electronic evidence. Its function is to support the legal fiction created by the Section, not to govern the admissibility of electronic evidence generally.

Proof by Certificate under Section 63(4)

In Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal, (2020) 7 SCC 1, it is held that in view of the non-obstante clause (“Notwithstanding anything contained in this Adhiniyam”) the Section 65B Certificate is the only Mode of Proof of a computer output (copy).

• Therefore, even in cases where formal proof of the digital photos or videos is dispensed with (for the opposite party admits it), a certificate under Section 65B(4) was necessary.
• The position is changed by Sec. 61, BSA.
• Read: “Nothing In This Adhiniyam Shall Apply To Deny The Admissibility” – New Provision (Sec. 61, BSA) to ensure that Sec. 65B (Sec. 63, BSA) is an enabling provision

Admitting a Copy in Evidence and Substantive Proof: Independent Matters

(i) Admitting a copy of a computer output (such as copy of a statement of accounts) in evidence (with a certificate under Section 63), and (ii) the formal proof (relevancy, truth, etc.) thereof at the time of trial, are two distinct and independent matters.

• The questions as to substantive proof — whether the computer output or copy is relevant, and how it should be proved — are not determined by Section 63 of the BSA. They are to be established independently, as in the case of any other class of documents.

The burden of Impeaching the Certificate is upon the Party who Disputes it

The presumption arising under Section 63—by which a computer output is deemed to be a document—is rebuttable and does not render the contents of the electronic record conclusive.

If such a challenge on the certificate is overruled by the court, it can draw a presumption as to the genuineness and authenticity of the photographs or videos contained in the computer output (copies).

S. 63 deals with Admissibility of computer output or copy, and not Proof

The questions as to substantive proof — whether the computer output or copy is relevant, and how it should be proved — are not determined by Section 63 of the BSA. They are to be established independently, as in the case of any other class of documents.

• However, the court can draw presumptions as to the genuineness and authenticity of such photographs or videos, as stated earlier.

Once Copy Admitted by S. 63 Certificate, Oral Evidence has No Place in Marking

Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal, (2020) 7 SCC 1, is an authority on the following matters –

• (i) The certificate is meant to replace the oral evidence of the device-handler or operator.
• (ii) Once the certificate is produced, oral evidence has no place (for the purpose of marking it).

However, the person who issued the certificate (operator) has to be examined if:

• the authenticity or correctness of the certificate is specifically disputed;
• allegations of fabrication, manipulation, or false certification are raised;
• the issuer’s control over the device/system is seriously questioned; or
• the court needs clarification to assess probative value, not admissibility.

Photograph Must Have Been Proved (In silent witness theory)

When a photograph is admitted merely to aid a witness in explaining his testimony (pictorial testimony theory), it need not be proved formally by examining the photographer or a competent person. 

As stated above, in silent witness theory cases, the photographs must be proved. No doubt, in the peculiar nature of a particular case, the examination of the photographer may not be insisted upon, and the photograph could be proved by another ‘proper’ witness. Formal proof of a photograph may not be necessary where the opposite party admits its genuineness or correctness.

Formal proof of a photograph and S. 63(4) Certificate are Distinct Matters

Formal proof (relevancy, truth, etc.) of a photograph or copy of a video and the requirement of the certificate under Section 63(4) are two distinct and independent matters.

• Note: 1. A photograph or a copy of a video, admitted in evidence on the strength of a certificate under Section 63(4), stands on a distinct footing (in contradistinction to a statement-of-account) by reason of the statutory presumptions that the court can invoke, it being a direct visual depiction of facts.
• 2. The certificate under Section 63(4) is accepted unless its correctness is specifically challenged. The oral evidence of the person who issued the certificate becomes relevant (for the purpose of admitting the document) only where the certificate itself is specifically and successfully challenged by the party who disputes its authenticity or correctness.
• 3. Therefore, the court is entitled to infer that a photograph or video, once duly admitted in evidence, correctly represents the scene or object as it existed at the time of recording. It is doctrinally recognised as the ‘silent witness’ theory – the document “speaks for itself”.
• 4. Accordingly, once a photograph or copy of a video is duly admitted in evidence, the court can act upon it (usually as a corroborative piece of evidence), on the basis of general evidence relating to the identity of the persons depicted, the place, the time, and the surrounding circumstances, without insisting upon any further primary or direct proof of the facts.
• 5. The presumption attached to a photograph or a video admitted in evidence being one rebuttable, the opposite party can rebut it by placing appropriate evidence to show that the photograph or video does not correctly represent the scene, object, or occurrence as it existed at the relevant point of time, or that the factual position had materially changed.

Pictorial Testimony Theory: No Enacted Law; Only Judicial Exposition

The pictorial testimony theory rests on judicial exposition rather than statutory codification. It finds only indirect support, in principle, from Section 162 (Refreshing Memory), BSA. Section 162 is to be understood as one not exhaustive in its operation.

Is photograph a Secondary Evidence

A photograph is not, by its very nature, secondary evidence. Its evidentiary character depends upon the type of matter depicted. Where a photograph shows a scene, person, place, or object, it ordinarily constitutes independent evidence of what it portrays. It becomes secondary evidence only when it is relied upon as a reproduction of another document or object whose contents are sought to be proved.

Court Decisions

P. Gopalakrishnan v. State of Kerala, AIR 2020 SC 1

In P. Gopalakrishnan v. State of Kerala, AIR 2020 SC 1, it is observed that tape records of speeches (Also in: Tukaram S. Dighole v. Manikrao Shivaji Kokate, 2010-4 SCC 329; Ziyauddin Burhanuddin Bukhari v. Brijmohan Ramdass Mehra, (1976) 2 SCC 17 ) and audio/video cassettes (See: Burhanuddin Bukhari v. Brijmohan Ramdas Mehra, 1976-2 SCC 17) including compact disc (See also: Singh Verma v. State of Haryana, 2016-15 SCC 485) were “documents” under Section 3 of the 1872 Act, which stand on no different footing than photographs and were held admissible in evidence. It is by now well established that the electronic record produced for the inspection of the Court is documentary evidence under Section 3 of the Evidence Act (Anwar PV v. PK Basheer, 2014-10 SCC 473).

Yusaf Ali lsmail Nagri v. The State of Maharashtra, 1967- 3 S.C.R. 720

• “The process of tape-recording offers an accurate method of storing and later reproducing sounds. The imprint on the magnetic tape is the direct effect of the relevant sounds. Like a photograph of a relevant incident, a contemporaneous tape record of a relevant conversation is a relevant fact and is admissible under s. 7 of the Indian Evidence Act.”

R.M Malkani v. State of Maharastra, AIR 1973 SC 157

In R.M Malkani v. State of Maharastra, AIR 1973 SC 157, summarised this case (Yusaf Ali lsmail Nagri) as under:

• “In Nagree’s case (Yusaf Ali lsmail Nagri v. The State of Maharashtra, 1967- 3 S.C.R. 720) the appellant offered bribe to Sheikh a Municipal Clerk. Sheikh informed the Police. The Police laid a trap. Sheikh called Nagree at the residence. The Police kept a tape recorder concealed in another room. The tape was kept in the custody of the police inspector  Sheikh gave evidence of the talk. The tape record corroborated his testimony, as a photograph taken without the knowledge of the person photographed can become relevant and admissible so does a tape record of a conversation unnoticed by the talkers. A contemporaneous tape record of a relevant conversation is a relevant fact and is admissible under section 8 of the Evidence Act. It is res gestae. It is also comparable to a photograph of a relevant incident. The tape recorded conversation is therefore a relevant fact and is admissible under section 7 of the Evidence Act.”

After summarising Nagree’s case (Yusaf Ali lsmail Nagri v. The State of Maharashtra, 1967- 3 S.C.R. 720), the Supreme Court said as under:

• “The Court will take care in two directions in admitting such evidence. First, the Court will find out that it is genuine and free from tampering or mutilation. Secondly, the Court may also secures scrupulous conduct and behaviour on behalf of the Police. The reason is that the Police Officer is more likely to behave properly if improperly obtained evidence is liable to be viewed with care and caution by the Judge. In every case the position of the accused, the nature of the investigation and the gravity of the offence must be judged in the light of the material facts and the Surrounding circumstances.”

K. K. Velusamy v. N. Palanisamy, 2011-11 SCC 275:

• 7. The amended definition of “evidence” in section 3 of the Evidence Act, 1872 read with the definition of “electronic record” in section 2(t) of the Information Technology Act 2000, includes a compact disc containing an electronic record of a conversation. Section 8 of Evidence Act provides that the conduct of any party, or of any agent to any party, to any suit, in reference to such suit, or in reference to any fact in issue therein or relevant thereto, is relevant, if such conduct influences or is influenced by any fact in issue or relevant fact, and whether it was previous or subsequent thereto. In R.M Malkani v. State of Maharastra, AIR 1973 SC 157, this court made it clear that electronically recorded conversation is admissible in evidence, if the conversation is relevant to the matter in issue and the voice is identified and the accuracy of the recorded conversation is proved by eliminating the possibility of erasure, addition or manipulation. This Court further held that a contemporaneous electronic recording of a relevant conversation is a relevant fact comparable to a photograph of a relevant incident and is admissible as evidence under Section 8 of the Act. There is therefore no doubt that such electronic record can be received as evidence.”

Ponnappan v. State of Kerala, ILR 1994(3) Ker 370

The Kerala High Court (KT Thomas, J.), in Ponnappan v. State of Kerala, ILR 1994(3) Ker 370, in appeal, confirmed the conviction holding that Chacko was the person who was killed. It was on a photo identification – Pictorial Testimony – so far as the witness was concerned.

The Court held as under:

• “PW I identified the person in M.O.9 photo as the person who was killed. There is no doubt that M.O.9 is the photograph of Chacko, the film representative. It was contended that since P. W.I himself admitted that he had not observed the features or facial peculiarities of the person when he was inside the car, the identification made by him with the help of the photo is not of any use. We are of the view that even without noticing any translatable mark or feature of a person it would be possible to identify him later.”

Here, the photo had been proved through competent witnesses – under the Silent Witness Theory – though the photographer was not examined.

Anu C.R. v. State of Kerala: A Witness may be Confronted with a Photograph During Cross-Examination Without its Prior Production.

The Kerala High Court, in Anu C.R. v. State of Kerala, 2025(7) KHC 150; 2025(6) KLT (SN) 2 (G. Girish, J.), allowed the defence counsel to confront a prosecution witness with a photograph of the alleged scene of occurrence and inquire whether the photograph represented the interior of the building concerned.

The Facts and Legal Principles Assume Significance

At the outset, the following facts and legal principles assume significance:

1. The court merely permitted the defence counsel to confront a prosecution witness, during cross-examination, with a photograph of the alleged place of occurrence.
2. If the photograph does not qualify as an “electronic record” or a “computer output”, the provisions contained in Sections 61 to 63 of the Bharatiya Sakshya Adhiniyam, 2023, have no application. In any case, the Court was not called upon to consider the applicability of Sections 61 to 63 of the BSA, 2023.
3. If the photograph is used solely for the purpose of confronting a witness during cross-examination, the mere fact that the witness admits its correctness does not render it liable to be marked as an exhibit. By analogy to the principle underlying Section 148, BSA (Section 145, Evidence Act), material employed only for confrontation does not become substantive evidence merely because the witness accepts its correctness.
4. However, the fact that a photograph is capable of being used merely for confronting a witness does not preclude its admission in evidence. Where the witness admits that the photograph correctly depicts the person, place or object portrayed therein, the court may admit and mark the photograph as an exhibit on the basis of such admission, particularly if it is prepared to draw the presumption contemplated under Section 119 of the BSA.
5. The Bharatiya Sakshya Adhiniyam, 2023, like the Evidence Act, 1872, contains no express provision dealing with the use of photographs for confronting a witness during cross-examination. The statutory scheme principally addresses cross-examination concerning previous statements and matters in writing (Section 147 and 148 of the BSA), leaving the admissibility and use of photographs to be governed by general principles of evidence and judicial discretion.

The Kerala High Court, in Anu C.R. v. State of Kerala, held as under:

• “i)​ The learned Additional Sessions Judge is directed to permit the counsel for the accused to confront PW2 by showing the photograph of the interior of the building which he had leased out to the accused (Annexure-A3) and to ask whether it is the photograph of the interior portion of the building which he had leased out to the accused.
• ii)​ If the witness gives an affirmative answer to the above question, the defence counsel shall be permitted to ask further questions related to it, with due regard to its relevancy, and to get the said document marked as an exhibit on the part of the accused, subject to production of that document immediately thereafter, following the formalities prescribed in that regard.
• iii)​ If the witness denied the above suggestion, or says that he is not able to say anything on the basis of the above document, the counsel for the accused need not be permitted to proceed with further questions on that document.
• iv)​ The learned Additional Sessions Judge is directed to permit the counsel for the defence to confront PW2 by showing the site plan prepared by the Village Officer and ask whether the aforesaid document was the plan of the building which he had rented out to the accused.
• v)​ If the witness gives an affirmative answer to the above question, then the defence counsel should be permitted to ask further questions on that site plan, with due regard to its relevancy, and also to admit the document as an exhibit of the prosecution, marked at the instance of the accused.
• vi)​ If the witness denies the suggestion, or says that he is not able to state anything about it, then the defence counsel need not be permitted to ask further questions on that document to that witness.”

Objections Raised Against Marking of Photograph and Site Plan

The objections raised, in Anu C.R. v. State of Kerala, against the marking of the photograph and site plan were the following:

• “The aforesaid photograph is not pertaining to the witness, or made by the witness, and it is not falling within the purview of Section 145 of the Evidence Act”.
• “The site plan prepared by the Village Officer, which formed part of the prosecution records, was also refused by the learned Additional Sessions Judge stating the reason that the aforesaid site plan is not prepared by that witness.”

Law Relied on by HC to say that Trial/Sessions Judge Went Wrong

The Three Judge Bench of the Supreme Court in Anees v. State Government of NCT (DY Chandrachud, CJI., J.B. Pardiwala, Manoj Misra, JJ.), AIR 2024 SC 2297; 2024-6 SCR 164; 2024 KHC 6256, held as under:

• “The object of the cross-examination is to impeach the accuracy, credibility and general value of the evidence given in chief; to sift the facts already stated by the witness; to detect and expose the discrepancy or to elicit the suppressed facts which will support the case of the cross-examining party.”

Legal Principles Lend Support to the Kerala High Court View

The following legal principles lend support to the view taken by the Kerala High Court:

1. Section 148, BSA

• Section 148 of the BSA (Section 145, Evidence Act) enables to contradict witnesses with his previous statements:
  • “Without such writing being shown to him”.
• Here, the materials are “shown” and asked.

2. Section 141, BSA

• Section 141(2) and (3) of the BSA [Section 136 (2) and (3), Evidence Act] reads as under:
  • “(2) If the fact proposed to be proved is one of which evidence is admissible only upon proof of some other fact, such last mentioned fact must be proved before evidence is given of the fact first mentioned, unless the party undertakes to give proof of such fact, and the Court is satisfied with such undertaking.
  • (3) If the relevancy of one alleged fact depends upon another alleged fact being first proved, the Judge may, in his discretion, either permit evidence of the first fact to be given before the second fact is proved, or require evidence to be given of the second fact before evidence is given of the first fact.”

(If the court permitted the cross-examiner to proceed, without raising objection by the court, it can be presumed that the party has ‘undertaken’ to give proof of such fact, “and the Court is satisfied with such undertaking”.)

Summary and Conclusion

The use of a photograph during cross-examination does not invariably amount to proving the photograph in evidence. Nor does it necessarily involve the doctrine of refreshing memory embodied in Section 162 of the BSA. A photograph may be shown to a witness merely for the purpose of identification, clarification, testing the accuracy of his testimony, or confronting him with a particular factual situation. In such cases, the photograph functions only as an aid in the examination of the witness and not as substantive evidence.

However, where the witness admits that the photograph correctly depicts the person, place or object portrayed therein, and the Court is prepared to draw the presumption contemplated under Section 119, BSA, the photograph may be admitted in evidence and marked as an exhibit on the basis of such admission.

End Notes

State Represented by the Inspector of Police, Chennai v. V. P. Pandi @ Attack Pandi, 2019-2 CTC 391; 2019-3 CTC 391; 2019-2 MLJ(Cri) 129,

The Madras High Court held as under:

• “115. We may also incidentally notice the developments in the law on video and photographic evidence in the West where the “silent witness” theory is deployed to admit video and photographic evidence. The theory proceeds on the footing that photographic and video evidence are “silent witnesses” which speak for themselves. They are substantive evidence of what they portray. Two examples may be noticed.
• (a) State of Nevada v. Archanian, [145 P 3d 1008 (2006)] was a murder case before the Supreme Court of Nevada, where, a key piece of evidence was the digital video recorded by the store’s surveillance system. The accused attacked the authenticity of the video footage on the ground that the VHS tape given to the police video technician was not the original and that the technician had isolated the relevant camera view and highlighted certain portions of the video. It was this composite videotape that was shown to the jury. In the trial, the prosecution acknowledged that they had no way of knowing whether the images were accurately transferred from the original digital recording to the VHS version but testified that they appeared to be the same. The Supreme Court of Nevada admitted the video evidence under the silent witness theory and held as under:
  • “There is no evidence suggesting that the composite videotape was inaccurate, that any relevant or exculpatory information had been deleted from it, or that the modifications made to it adversely affected or obscured the content.”
• (b) More recently, in Her Majesty v. Jaiyhi He, [2017 ONCJ 790] Kenkel, J. of the Ontario Court of Justice in Canada formulated a test, very similar to our own and that has been alluded to by us in para 105 (supra). The Court opined:
  • “The party seeking to tender a video in evidence must show two things to meet the threshold test of admissibility:
  • They must prove the video is relevant, showing the crime scene or other evidence linked to the issues at trial.
  • They must prove the video is authentic – that it accurately represents the events depicted.”
• Referring to the Alberta Court of Appeal’s decision in R. v. Bulldog (2015 ABCA 251), the Ontario Court said:
  • “Circumstantial evidence may be used to authenticate real evidence – Bulldog at para 35. There is no particular evidence or class of witness that must be called to authenticate a video provided the whole of the evidence establishes that the video in question is substantially accurate and a fair depiction.”
• The Ontario Court has held that in a given case, whether the two part test (supra) is satisfied or not, would have to be decided on a balance of probabilities. The Court found that the testimony of the police officer was in sync with the narrative contained in the video, thereby establishing its authenticity on a balance of probabilities. The Ontario Court further observed:
  • “7. While the circumstantial evidence is sufficient, in this case, there is further direct evidence that independently shows the video is accurate. The surveillance video is in sync with all of the other evidence at trial. The officers’ testimony as to the scene when they arrived, the times the various officers arrived, their actions, the position of the accused, the departure of other parties, the arrival of the ambulance is all consistent with this video. The two police in-car videos are also consistent with this surveillance video.”
• We have referred to these decisions in order to reiterate that a pragmatic and purposive interpretation of the law governing the admission of electronic evidence is consistent with the development of the law in international jurisdictions as well.
• 116. We, therefore, unhesitatingly hold that the photos and videos in M.Os.45,49,50,51,52 and 53 were taken contemporaneously when the attack was taking place and have not been doctored and can be read in evidence.”

Examination of the Photographer Necessary

Though a photograph is found to be primary evidence and admissible in evidence, in P. Rama Srinivasa Rao v. Dr. N. Ragavan, 2006 2 CTC 43; 2006 3 MLJ 625, R. Banumathi, J., held that it cannot be marked during cross-examination; for it can be marked only through the person who took the photograph.

Examination of the Photographer may not be insisted (In silent witness theory)

As stated above, in silent witness theory cases, photographs or videos are required to be proved. However, such proof need not necessarily be by way of formal proof through the examination of the photographer or the person who captured the image.

The Kerala High Court, in Anu C.R. v. State of Kerala, 2025(7) KHC 150; 2025(6) KLT (SN) 2 (G. Girish, J.), allowed the defence counsel to confront a prosecution witness with a photograph of the alleged scene of occurrence and inquire whether the photograph represented the interior of the building concerned.

Definition of document

Section 2(1)(d) of the Bh. Sak. Adhiniyam defines ‘document’ as under:

• (d) “document” means any matter expressed or described or otherwise recorded upon any substance by means of letters, figures or marks or any other means or by more than one of those means, intended to be used, or which may be used, for the purpose of recording that matter and includes electronic and digital records.
• Illustrations.
• (i) A writing is a document.
  
  (ii) Words printed, lithographed or photographed are documents.
  
  (iii) A map or plan is a document.
  
  (iv) An inscription on a metal plate or stone is a document.
  
  (v) A caricature is a document.
  
  (vi) An electronic record on emails, server logs, documents on computers, laptop or smartphone, messages, websites, locational evidence and voice mail messages stored on digital devices are documents.”

‘Document’ takes in photographs of words as could be seen from the illustration.

By virtue of Section 65B of the Indian Evidence Act, any information contained in an electronic record which is printed on a paper, stored, recorded or copied in optical or magnetic media produced by a computer (computer output) shall be ‘deemed to be also a document’.

Besides the Evidence Act, the term ‘document’ has been defined in the General Clauses Act, 1897, and the Indian Penal Code, 1860.  

Section 3(18), General Clauses Act defines document as under:

• “document shall include any matter written, expressed or described upon any substance by means of letters, figures or marks, or by more than one of those means which is intended to be used, or which may be used, for the purpose or recording that matter;”

Section 29, Indian Penal Code explains –

• “The word “document” denotes any matter expressed or described upon any substance by means of letters, figures, or marks, or by more than one of those means, intended to be used, or which may be used, as evidence of that matter.”

In Explanation 1, it is stated:

• “It is immaterial by what means or upon what substance the letters, figures or marks are formed, or whether the evidence is intended for, or may be used in a court of justice, or not.”

Going by the definitions, ‘document ‘ includes not only all materials or substances upon which thoughts of a man are represented by writing or any other species of conventional mark or symbol, but also records of information of some sort (Santhosh Madhavan @ Swami Amritha Chaithanya v. State, 2014 KerHC 31).

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Civil Suits: Procedure & Principles

Book No, 1 – Civil Procedure Code

• Time City Infrastructure and Housing Ltd v. State of UP: Non-Compliance in taking Postal Steps – Court Should Vacate the Ad-Interim Injunction Order
• “Due Process of Law” in Civil Suits
• Can a suit be Rejected (Order VII rule 11 CPC) on the Ground of Res Judicata?
• Operation Asha  v. Shelly Batra, a Landmark Judgment on Sec. 92 CPC– Critical Appreciation
• If a Sharer Dies & the LRs are Not Impleaded – Partition Suit as a Whole Abates. But the Court SHOULD Direct Either Side to Take Steps to Bring in the Legal Heirs
• Order IX Rule 9 CPC: Earlier Suit for Injunction; Subsequent Suit for Recovery & Injunction – No Bar
• H. Anjanappa v. A. Prabhakar: An ‘Aggrieved’ Stranger or a ‘Prejudicially Affected’ Third-Party (also) Can File Appeal with the ‘Leave of the Court’.
• Replication, Rejoinder and Amendment of Pleadings
• Can a Suit be Withdrawn in Appeal, on the Ground that Appeal is Continuation of the Suit?
• Does Registration of a Document give Notice to the Whole World?
• Suit under Sec. 6, Specific Relief Act – Is it a ‘Summary Suit’ under Order XXXVII CPC?
• Is it Mandatory to Lift the Attachment on Dismissal of the Suit? Will the Attachment Orders Get Revived on Restoration of Suit?
• Will Interlocutory Orders and Applications Get Revived on Restoration of Suit?
• Can an ‘Ex-parte’ Defendant Cross Examine Plaintiff’s Witness?
• Proof on ‘Truth of Contents’ of Documents, in Indian Evidence Act
• Civil Rights and Jurisdiction of Civil Courts
• Res Judicata and Constructive Res Judicata
• Res Judicata and Judicial Precedent
• No Res judicata on Finding on Title in an Injunction Suit
• Res Judicata: ‘Same issue’ must have been ‘Adjudicated’ in the former suit
• Order II, Rule 2 CPC – Not to Vex Defendants Twice
• A Land Mark Decision on Order II rule 2, CPC – Cuddalore Powergen Corporation Ltd. v. Chemplast Cuddalore Vinyls Ltd., Neutral Citation: 2025 INSC 73
• Order I rule 8, CPC (Representative Suit) When and How? Whether Order I rule 8 Decree is Enforceable in Execution?
• Pleadings Should be Specific; Why?
• Pleadings in Defamation Suits
• Previous Owner is Not a Necessary Party in a Recovery Suit
• UNDUE INFLUENCE and PLEADINGS thereof in Indian Law
• PLEADINGS IN ELECTION MATTERS
• Declaration and Injunction
• Law on Summons to Defendants and Witnesses
• Notice to Produce Documents in Civil Cases
• Production of Documents: Order 11, Rule 14 & Rule 12
• Sec. 91 CPC and Suits Against Wrongful Acts
• Remedies Under Sec. 92 CPC
• Mandatory Injunction – Law and Principles
• INJUNCTION is a ‘Possessory Remedy’ in Indian Law
• Interrogatories: When Court Allows, When Rejects?
• Decree in OI R8 CPC-Suit & Eo-Nomine Parties
• Pecuniary & Subject-Matter Jurisdiction of Civil Courts
• Transfer of Property with Conditions & Contingent Interests
• Doctrine of Substantial Representation in a Suit by or against an Association
• Who are Necessary Parties, Proper Parties and Pro Forma Parties in Suits
• What is Partnership, in Law? How to Sue a Firm?
• ‘Legal Representatives’, Not ‘Legal Heirs’ to be Impleaded on Death of Plaintiff/Defendant
• Powers and Duties of Commissioners to Make Local Investigations, Under CPC
• Burden of Proof – Initial Burden and Shifting Onus
• Burden on Plaintiff to Prove Title; Weakness of Defence Will Not Entitle a Decree
• Is it Mandatory to Set Aside the Commission Report – Where a Second Commissioner is Appointed?
• Can a Commission be Appointed to Find Out the Physical Possession of a Property?
• Withholding Evidence and Adverse Inference
• Pendente Lite Transferee Cannot Resist or Obstruct Execution of a Decree
• Family Settlement or Family Arrangement in Law
• ‘Possessory Title’ in Indian Law
• Will Findings of a Civil Court Outweigh Findings of a Criminal Court?
• Relevancy of Civil Case Judgments in Criminal Cases
• Waiver and Promissory Estoppel
• Can a Christian Adopt? Will an adopted child get share in the property of adoptive parents?
• Principles of Equity in Indian Law
• Thangam v.  Navamani Ammal: Did the Supreme Court lay down – Written Statements which deal with each allegation specifically, but not “para-wise”, are vitiated?
• No Criminal Case on a Dispute Essentially Civil in Nature.
• Doctrine of Substantial Representation in Suits
• Order I rule 8, CPC (Representative Suit) When and How? Whether Order I rule 8 Decree is Enforceable in Execution?
• Appointment of Guardian for Persons Suffering from Disability or Illness: Inadequacy of Law – Shame to Law Making Institutions
• Can Documents be Marked In Cross Examination, If Witness Admits Them?

Principles and Procedure

• Relevancy of a Civil Case Judgment in Criminal Cases: Does a Civil Court Judgment Bind a Criminal Court?
• When can (i) a ‘Victim’ File an Appeal in a Criminal Case and  (ii) an ‘Aggrieved Person’ File an Appeal in a Civil Case?
• Asian Paints Limited v. Ram Babu, 2025 INSC 828 – ‘Victim’ Can File an Appeal in a Criminal Case
• BURDEN of PROOF: Initial Burden and Shifting the Onus in Indian and English Law
• H. Anjanappa v. A. Prabhakar: An ‘Aggrieved’ Stranger or a ‘Prejudicially Affected’ Third-Party (also) Can File Appeal with the ‘Leave of the Court’.
• Our Courts Apply Different ‘STANDADARDS of Proof’
• Ratio Decidendi (alone) Forms a Precedent, Not a Final Order
• BNSS – Major Changes from CrPC
• Bharatiya Nyaya Sanhita, 2023: Important Changes from the Indian Penal Code
• Substantive Rights and Mistakes & Procedural Defects in Judicial Proceedings
• Can Documents be Marked In Cross Examination, If Witness Admits Them?
• Will Boundaries of Properties (Always) Preferred Over Survey Number, Extent, Side Measurements, etc.?
• All Illegal Agreements are Void; but All Void Agreements are Not Illegal
• Doctrines on Ultra Vires, Rule of Law, Judicial Review, Nullification of Mandamus, and Removing the BASIS of the Judgment
• Can an ‘Ex-parte’ Defendant Cross Examine Plaintiff’s Witness?
• Will – Probate and Letters of Administration
• Appreciation of Evidence by Court and ‘Preponderance of Probabilities’ & ‘Probative Value of Evidence
• Effect of Not Cross-Examining a Witness & Effect of Not Facing Complete Cross-Examination by the Witness
• Suggestions & Admissions by Counsel, in Cross Examination to Witnesses
• Admission by itself Cannot Confer Title
• Best Evidence Rule in Indian Law
• Declaration and Injunction
• Pleadings Should be Specific; Why?
• Does Alternate Remedy Bar Civil Suits and Writ Petitions?
• Void, Voidable, Ab Initio Void, and Sham Transactions
• If a Document is Per Se Illegal, or Void Ab Initio, it Need Not be Set Aside
• Can Courts Award Interest on Equitable Grounds?
• Natural Justice – Not an Unruly Horse
• Krishnadatt Awasthy v. State Of M.P, 29 January, 2025 – Law on Natural Justice Revisited
• ‘Sound-mind’ and ‘Unsound-Mind’
• Prescriptive Rights – Inchoate until the Title thereof is Upheld by a Competent Court
• ‘Title’ and ‘Ownership’ in Indian Law
• Can a Party to Suit Examine Opposite Party, as of Right?
• Forfeiture of Earnest Money and Reasonable Compensation
• Doctrine of ‘Right to be Forgotten’ in Indian Law
• Proof on ‘Truth of Contents’ of Documents, in Indian Evidence Act
• Cheating and Breach of Contract: Distinction – Fraudulent Intention at the time of Promise.
• Declaration of Title & Recovery of Possession: Art. 65, not Art. 58, Limitation Act Governs
• What is COGNIZANCE and Application of Mind by a Magistrate?
• Shri Mukund Bhavan Trust v. Shrimant Chhatrapati Udayan Raje Pratapsinh Maharaj Bhonsle: Rejection of Plaint on ‘Bar of Limitation’ on Plea of Fraud.
• Pradeep Nirankarnath Sharma v. The State of Gujarat: The Police have No Discretion to conduct a Preliminary Inquiry Before Registering an FIR in Cognizable Offences

PROPERTY LAW

Title, ownership and Possession

• ‘Nemo Dat Quod Non Habet’
• Section 27, Limitation Act Gives-Rise to a Substantive Right so as to Seek Declaration and Recovery
• Sale Deeds Without Consideration – Void
• Tenancy at Sufferance in Indian Law
• “Due Process of Law” in Civil Suits
• Revenue Settlement Registers of Travancore in 1910, Basic Record of Land matters
• Govt. of AP v. Thummala Krishna Rao, AIR 1982 SC 1081, 1982 (2) SCC 134, Misread by High Courts

Recovery of Possession: 

• Recovery of Possession Based on Title and on Earlier Possession
• Declaration of Title & Recovery of Possession: Art. 65, not Art. 58, Limitation Act Governs
• Title and Ownership and Possessory Title in Indian Law
• Does Registration of a Document give Notice to the Whole World?
• Admission by itself Cannot Confer Title
• POSSESSION is a Substantive Right in Indian Law
• 22nd Law Commission  Report on ‘Law on Adverse Possession’
• Adverse Possession Against Government
• Government of Kerala v. Joseph – Law on Adverse Possession Against Government
• Should the Government Prove Title in Recovery Suits
• How to Plead Adverse Possession? Adverse Possession: An Evolving Concept
• Adverse Possession: Burden to Plead Sabotaged
• Does ‘Abandonment’ Give rise to a Recognised Right in Indian Law?
• When ‘Possession Follows Title’; ‘Title Follows Possession’?
• Ultimate Ownership of All Property Vests in State; It is an Incident of Sovereignty.
• ‘Mutation’ by Revenue Authorities & Survey will not Confer ‘Title’
• Preemption is a Very Weak Right; For, Property Right is a Constitutional & Human Right
• Transfer of Property with Conditions & Contingent Interests
• Family Settlement or Family Arrangement in Law
• INJUNCTION is a ‘Possessory Remedy’ in Indian Law
• ‘Possessory Title’ in Indian Law
• Kesar Bai v. Genda Lal – Does Something Remain Untold?
• Grant in Law
• Termination of Tenancy (& Grant) by Forfeiture (for Claiming Title)
• Survey under Survey Act – Raises a Presumption on Boundary; though Not Confer Title
• SUIT on TITLE: Landlord can Recover Property on GENERAL TITLE (though Tenancy Not Proved) if Defendant Falsely Claimed Independent Title
• Even the Rightful Owner is NOT entitled to Eject a Trespasser, by Force
• Ryotwari System in Madras

Adverse Possession

• What is Adverse Possession in Indian Law?
• Neelam Gupta v. Rajendra Kumar Gupta (October 14, 2024) – Supreme Court Denied the Tenant’s Claim of Adverse Possession
• Adverse Possession: How to Plead Adverse Possession? Adverse Possession: An Evolving Concept
• Adverse Possession Against Government
• Govt. of AP v. Thummala Krishna Rao, AIR 1982 SC 1081, 1982 (2) SCC 134, Misread by High Courts
• Adverse Possession: Burden to Plead Sabotaged
• Does ‘Abandonment’ Give rise to a Recognised Right in Indian Law?
• When ‘Possession Follows Title’; ‘Title Follows Possession’?
• Government of Kerala v. Joseph – Law on Adverse Possession Against Government
• Should the Government Prove Title in Recovery Suits
• ‘Possessory Title’ in Indian Law
• Admission by itself Cannot Confer Title
• Ouster and Dispossession in Adverse Possession
• Declaration of Title & Recovery of Possession: Art. 65, not Art. 58, Limitation Act Governs
• Mallavva v. Kalsammanavara Kalamma, 2024 INSC 1021, Composite Suit (Cancellation & Recovery) – Substantive Relief Determines Limitation  
• The Laws of ‘Doctrine of Election’ and ‘Doctrine of Waiver’

Land Laws/ Transfer of Property Act

• Bona Fide Purchaser for Value Deserves Stronger Equity than a Prior Contract Holder
• Travancore Royal Pattom Proclamations of 1040 (1865 AD) and 1061 (1886 AD), And 1922 Devaswom Proclamation
• Revenue Settlement Registers of Travancore in 1910, Basic Record of Land matters
• Tenancy at Sufferance in Indian Law
• Freehold Property in Law
• What is Patta or Pattayam?
• Does ‘Pandaravaka Pattom’ in Kerala Denote Full-Ownership?
• Transfer of Property with Conditions & Contingent Interests
• Previous Owner is Not a Necessary Party in a Recovery Suit
• Recovery of Possession Based on Title and on Earlier Possession
• Vested Remainder and Contingent Remainder
• Vested interest and Contingent Interest
• Ultimate Ownership of All Property Vests in State; It is an Incident of Sovereignty.
• Land Acquired Cannot be Returned – Even if it is Not Used for the Purpose Acquired
• ‘Mutation’ by Revenue Authorities & Survey will not Confer ‘Title’
• FERA, 1973 And Transfer of Immovable Property by a Foreigner
• Marumakkathayam – A System of Law and Way of Life Prevailed in Kerala
• Land Tenures, and History of Land Derivation, in Kerala
• Glen Leven Estate v. State of Kerala: Not Correctly Decided?
• Sale Deeds Without Consideration – Void
• If a Document is Per Se Illegal, or Void Ab Initio, it Need Not be Set Aside
• Law on SUCCESSION CERTIFICATE and LEGAL HEIRSHIP CERTIFICATE
• Sec. 7 Easements Act – Natural Advantages Arising from the Situation of Land & Natural Flow of Water
• Grant in Law
• Should the Government Prove Title in Recovery Suits
• Title of the Government Property in India: Government is the Ultimate Owner of Every Property; Hence, Government Need Not Prove Title.
• Survey under Survey Act – Raises a Presumption on Boundary; though Not Confer Title

Land Reform Laws

• Plantation-Tenants Not Approached The Land Tribunal are Ineligible for Plantation-Exemption-Orders from the Land Board
• Acquisition of (Exempted) Plantation Property: Should the Govt. Pay Full Land Value to Land Owners?
• Relevant provisions of Kerala Land Reforms Act in a Nutshell
• Land Tenures, and History of Land Derivation, in Kerala
• Should the Government Prove Title in Recovery Suits
• ‘Janmam’ Right is FREEHOLD Interest and ‘Estate’ in Constitution – By Royal Proclamation of 1899, The Travancore Sircar became Janmi of Poonjar Raja’s Land
• Government is the OWNER of (Leasehold) Plantation Lands in Kerala.
• Title of the Government Property in India: Government is the Ultimate Owner of Every Property; Hence, Government Need Not Prove Title.
• Glen Leven Estate v. State of Kerala: Not Correctly Decided?
• Law on Acquisition of Private Plantation Land in Kerala
• Plantation Exemption in Kerala Land Reforms Act–in a Nutshell
• Kerala Land Reforms Act – Provisions on Plantation-Tenancy and Land-Tenancy
• Grant in Law
• Balanoor Plantations & Industries Ltd. v. State of Kerala – Based on the Principle: LT to fix Tenancy’; TLB to Fix Plantation Exemption.  
• 1910 Settlement Register of Travancore – Basic Record of Land Matters

Power of attorney

• M.S. Ananthamurthy v. J. Manjula: Mere Word ‘Irrevocable’ Does Not Make a POWER OF ATTORNEY Irrevocable
• Can a Power of Attorney file a Civil Suit? Is there any bar by virtue of Manisha Mahendra Gala v. Shalini Bhagwan Avatramani, 2024-6 SCC 130?
• No Adjudication If Power of Attorney is Sufficiently Stamped
• Notary Attested Power-of-Attorney Sufficient for Registration
• Notary-Attested Documents and Presumptions
• Permission when a Power of Attorney Holder Files Suit
• If Power of Attorney himself Executes the Document, S. 33 Registration Act will NOT be attracted
• Should a Power of Attorney for Sale must have been Registered –
• Is Registered Power of Attorney Necessary for Registration of a Deed? No.

Evidence Act – General

• Newspaper Reports are ‘Hearsay Secondary Evidence’
• Major Changes in the Evidence Act by Bhartiya Sakshya Adhiniyam, 2023
• Sec. 27 Recovery/Discovery in Evidence Act and Bhartiya Sakshya Adhiniyam, 2023
• Evidence in Court – General Principles
• Expert Evidence and Appreciation of Evidence
• Handwriting Expert Evidence: Relevant, But Merely an Opinion
• How to Contradict a Witness under Sec. 145, Evidence Act
• Withholding Evidence and Adverse Inference
• Best Evidence Rule in Indian Law
• What is Collateral Purpose?
• Burden of Proof – Initial Burden and Shifting Onus
• Appreciation of Evidence by Court and ‘Preponderance of Probabilities’ & ‘Probative Value of Evidence
• Effect of Not Cross-Examining a Witness & Effect of Not Facing Complete Cross Examination by the Witness
• Suggestions & Admissions by Counsel, in Cross Examination to Witnesses
• Proof of Documents – Admission, Expert Evidence, Presumption etc.
• Public Documents: Proof and Presumption
• Admission by itself Cannot Confer Title
• How to Prove a Will, in Court?Is Presumption enough to Prove a Registered Will?
• Significance of Scientific Evidence in Judicial Process
• Polygraphy, Narco Analysis and Brain Mapping Tests
• What is Section 27 Evidence Act – Recovery or Discovery?
• How ‘Discovery’ under Section 27, Evidence Act, Proved?
• Pictorial Testimony Theory and Silent Witnesses Theory
• Sec. 35 Evidence Act: Presumption of Truth and Probative Value
• Proof on ‘Truth of Contents’ of Documents, in Indian Evidence Act

Sec. 65B

• Hash Value Certificate – Mandatory or Directory
• Sakshya Adhiniyam (Literally) Mandates Hashing the Original. But the Established Jurisprudence Requires Hashing the Copy.
• Sec. 27 Recovery/Discovery in Evidence Act and Bhartiya Sakshya Adhiniyam, 2023
• Sec. 65B (Electronic Records) and Bhartiya Sakshya Adhiniyam, 2023
• Sec. 65B, Evidence Act: Arjun Paditrao Criticised.
• Sec. 65B Evidence Act Simplified
• ‘STATEMENTS’ alone can be proved by ‘CERTIFICATE’ u/s. 65B
• Sec. 65B,  Evidence Act: Certificate forms
• Certificate is Required Only for ‘Computer Output’; Not for ‘Electronic Records’: Arjun Panditrao Explored.
• How to Prove ‘Whatsap Messages’, ‘Facebook’ and ‘Website’ in Courts?

Admission, Relevancy and Proof

• ‘Admission’ in Indian Law
• Relevancy, Admissibility and Proof of Documents
• Handwriting Expert Evidence: Relevant, But Merely an Opinion
• Admission of Documents in Evidence on ‘Admission’
• Admission by itself Cannot Confer Title
• Judicial Admissions in Pleadings: Admissible Proprio Vigore Against the Maker
• Document Exhibited in the Writ Petition as ‘True Copy’ – Can it be Used in a Civil Suit as ‘Admission’?
• Modes of Proof of Documents
• Proof of Documents & Objections To Admissibility – How & When?
• Should Objection to Marking Documents be Raised When it is Admitted; Is it Enough to Challenge them in Cross-Examination?
• Burden of Proof – Initial Burden and Shifting Onus
• Burden on Plaintiff to Prove Title; Weakness of Defence Will Not Entitle a Decree
• Appreciation of Evidence by Court and ‘Preponderance of Probabilities’ & ‘Probative Value of Evidence
• Production, Admissibility & Proof Of Documents
• Proof of Documents – Admission, Expert Evidence, Presumption etc.
• Marking Documents Without Objection – Do Contents Proved
• Can Documents be Marked In Cross Examination, If Witness Admits Them?
• Substantive Documents, and Documents used for Refreshing Memory and Contradicting 
• Oral Evidence on Contents of Document, Irrelevant
• Proof on ‘Truth of Contents’ of Documents, in Indian Evidence Act
• Relevancy of Civil Case Judgments in Criminal Cases
• Prem Raj v.  Poonamma Menon (SC), April 2, 2024 – An Odd Decision on ‘Civil Court Judgment does not Bind Criminal Court’

Law on Documents

• Public Documents: Proof and Presumption
• Public Documents Admissible Without Formal Proof
• Admitted Documents – Can the Court Refrain from Marking, for no Formal Proof?
• Does Registration of a Document give Notice to the Whole World?
• Production, Admissibility & Proof Of Documents
• Relevancy, Admissibility and Proof of Documents
• Admission of Documents in Evidence on ‘Admission’
• Effect of Marking Documents Without Objection – Do Contents Stand Proved?
• Time Limit for Registration of Documents
• Registration of Documents Executed out of India
• How to Prove a Will, in Court?Is Presumption enough to Prove a Registered Will?
• Are RTI Documents Admissible in Evidence as ‘Public Documents’?
• Oral Evidence on Contents of Document, Irrelevant
• Proof of Documents & Objections To Admissibility – How & When?
• Notary-Attested Documents and Presumptions
• What is Collateral Purpose?
• No Application Needed for Filing or Admitting Copy
• Presumptions on Documents and Truth of Contents
• Presumptions on Registered Documents & Truth of Contents
• Notice to Produce Documents in Civil Cases
• Production of Documents: Order 11, Rule 14 & Rule 12
• Modes of Proof of Documents
• Secondary Evidence of Documents & Objections to Admissibility – How & When?
• Should Objection to Marking Documents be Raised When it is Admitted; Is it Enough to Challenge them in Cross-Examination?
• 30 Years Old Documents and Presumption of Truth of Contents, under Sec. 90 Evidence Act
• Unstamped & Unregistered Documents and Collateral Purpose
• Adjudication as to Proper Stamp under Stamp Act
• Marking Documents Without Objection – Do Contents Proved
• Cancellation of Sale Deeds and Settlement Deeds & Powers of Sub-Registrar in cancelling Deeds
• Cancellation, Avoidance or Declaration of a Void or Voidable Deed
• If a Document is Per Se Illegal, or Void Ab Initio, it Need Not be Set Aside
• Can the True Owner Seek Cancellation of a Deed, Executed by a Stranger to the Property
• Substantive Documents, and Documents used for Refreshing Memory and Contradicting 
• How to Contradict a Witness under Sec. 145, Evidence Act
• Visual and Audio Evidence (Including Photographs, Cassettes, Tape-recordings, Films, CCTV Footage, CDs, e-mails, Chips, Hard-discs, Pen-drives)
• Photograph Evidence, Its Admissibility and Photo-Identification in Court Cases
• Pictorial Testimony Theory and Silent Witnesses Theory
• No Adjudication Needed If Power of Attorney is Sufficiently Stamped
• Can an Unregistered Sale Agreement be Used for Specific Performance
• Impounding of Documents – When Produced; Cannot Wait Till it is Exhibited
• Sec. 35 Evidence Act: Presumption of Truth and Probative Value
• How to Prove Resolutions of a Company; Are Minutes Necessary?

Documents – Proof and Presumption

• Handwriting Expert Evidence: Relevant, But Merely an Opinion
• Public Documents: Proof and Presumption
• Can the Court Refuse to Mark a (Relevant and Admissible) Document, for (i) there is No Formal Proof or (ii) it is a Photocopy?
• Photograph Evidence, Its Admissibility and Photo-Identification in Court Cases
• Marking of Photocopy and Law on Marking Documents on Admission (Without Formal Proof)
• Proof of Documents – Admission, Expert Evidence, Presumption etc.
• Proof on ‘Truth of Contents’ of Documents, in Indian Evidence Act
• Modes of Proof of Documents
• ‘Admission’ in Indian Law
• Marking Documents Without Objection – Do Contents Proved
• Proof on ‘Truth of Contents’ of Documents, in Indian Evidence Act
• Admitted Documents – Can the Court Refrain from Marking, for no Formal Proof?
• Admission of Documents in Evidence on ‘Admission’
• Effect of Marking Documents Without Objection – Do Contents Stand Proved?
• Proof of Documents & Objections To Admissibility – How & When?
• Should Objection to Marking Documents be Raised When it is Admitted; Is it Enough to Challenge them in Cross-Examination?
• Presumptions on Documents and Truth of Contents
• Presumptions on Registered Documents & Truth of Contents
• Secondary Evidence of Documents & Objections to Admissibility – How & When?
• 30 Years Old Documents and Presumption of Truth of Contents, under Sec. 90 Evidence Act

Interpretation

• Interpretation of Documents – Literal Rule, Mischief Rule and Golden Rule
• Golden Rule of Interpretation is Not the Application of Plain Meaning of the Words
• Interpretation of Wills
• Appreciation of Evidence by Court and ‘Preponderance of Probabilities’ & ‘Probative Value of Evidence

Contract Act

• Can Filing a Suit Amount to Notice of Termination of Contract
• Godrej Projects Development Limited v. Anil Karlekar, 2025 INSC 143 – Supreme Court Missed to State Something
• ‘Sound-mind’ and ‘Unsound-Mind’ in Indian Civil Laws
• Forfeiture of Earnest Money and Reasonable Compensation
• Who has to fix Damages in Tort and Contract?
• UNDUE INFLUENCE and PLEADINGS thereof in Indian Law
• All Illegal Agreements are Void; but All Void Agreements are Not Illegal
• If a Document is Per Se Illegal, or Void Ab Initio, it Need Not be Set Aside
• Can an Unregistered Sale Agreement be Used for Specific Performance
• Cheating and Breach of Contract: Distinction – Fraudulent Intention at the time of Promise.

Law on Damages

• Law on Damages
• Who has to fix Damages in Tort and Contract?
• Law on Damages in Defamation Cases
• Pleadings in Defamation Suits
• Godrej Projects Development Limited v. Anil Karlekar, 2025 INSC 143 – Supreme Court Missed to State Something

Easement

• Easement Simplified
• What is Easement? Does Right of Easement Allow to ‘Enjoy’ Servient Land After Making Improvements Therein ?
• “Implied Grant” in Law of Easements
• Implied Grant: A Valid Mode of Creation of Easement under Indian Law
• “Title Thereto” in the Definition of ‘Prescriptive Easement’ in Sec. 15 of the Indian Easements Act, 1882
• Prescriptive Rights – Inchoate until the Title thereof is Upheld by a Competent Court
• Will Easement of Necessity Ripen into a Prescriptive Easement?
• What is “period ending within two years next before the institution of the suit” in Easement by Prescription?
• Is the Basis of Every Easement, Theoretically, a Grant
• Extent of Easement (Width of Way) in Easement of Necessity, Quasi Easement and Implied Grant
• Easement of Necessity and Prescriptive Easement are Mutually Destructive; But, Easement of Necessity and Implied Grant Can be Claimed Alternatively
• Can Easement of Necessity and of Grant be Claimed in a Suit (Alternatively)?
• Can an Easement-Way be Altered by the Owner of the Land?
• Village Pathways and Right to Bury are not Easements.
• Custom & Customary Easements in Indian Law
• ‘Additional Burden Loses Lateral Support’ – Incorrect Proposition
• Grant in Law
• Right of Private Way Beyond (Other Than) Easement
• Easement – Should Date of Beginning of 20 Years be pleaded?
• What is Easement, in law? Right of Easement Simplified
• One Year Interruption or Obstruction will not affect Prescriptive Easement
• Should the Plaintiff Schedule Servient Heritage in a Suit Claiming Perspective Easement?
• Necessary Parties in Suits on Easement
• Easement by Prescription – Grant or ‘Acquiring’ by “Hostile Act”
• Sec. 7 Easements Act – Natural Advantages Arising from the Situation of Land & Natural Flow of Water
• Licence and Irrevocable Licence: Section 60 Easements Act Applies only to ‘Bare Licences’ and Not to ‘Contractual Licences’

Stamp Act & Registration

• Sub-Registrar has no Authority to Ascertain whether the Vendor has Title
• Title Enquiry by the Sub Registrar is Illegal
• Cancellation of Sale Deeds and Settlement Deeds & Powers of Sub-Registrar in Cancelling Deeds
• Time-Limit For Adjudication of Unstamped Documents, before Collector
• Time Limit for Registration of Documents
• Presumptions on Registered Documents & Truth of Contents
• Registration of Documents Executed out of India
• LAW ON INSUFFICIENTLY STAMPED DOCUMENTS 
• Adjudication as to Proper Stamp under Stamp Act
• Unstamped & Unregistered Documents and Collateral Purpose
• Can an Unregistered Sale Agreement be Used for Specific Performance
• Impounding of Documents, When Produced; Cannot Wait Till it is Exhibited
• No Adjudication Needed If Power of Attorney is Sufficiently Stamped
• Notary Attested Power-of-Attorney Sufficient for Registration
• What is Torrens System

Divorce/Marriage

• Presumption of Valid Marriage – If lived together for Long Spell
• Validity of Foreign Divorce Decrees in India
• Is ‘Irretrievable Brake-down of Marriage’, a Valid Ground for Divorce in India?
• Foreign Divorce Judgment against Christians having Indian Domicile

Negotiable Instruments Act

• Presumptions Regarding Consideration in Cheque Cases under the NI Act
• An Inchoate Cheque (Signed Blank Cheque or Incomplete Cheque) Cannot be Enforced Through a Court of Law Invoking Presumptions under the NI Act
• Does Cheque-Case under Sec. 138, NI Act Lie Against a Trust?
• Sec. 138 NI Act (Cheque) Cases: Presumption of Consideration u/s. 118
• Even if ‘Signed-Blank-Cheque’, No Burden on Complainant to Prove Consideration; Rebuttal can be by a Probable Defence
• “Otherwise Through an Account” in Section 142, NI Act
• Where to file Cheque Bounce Cases (Jurisdiction of Court – to file NI Act Complaint)?
• Cheque Dishonour Case against a Company, Firm or Society
• What is ‘Cognizance’ in Law
• What is COGNIZANCE and Application of Mind by a Magistrate?

Criminal

• Pradeep Nirankarnath Sharma v. The State of Gujarat: The police have no discretion to conduct a preliminary inquiry before registering an FIR in cognizable offences

Arbitration

• Seesaw of Supreme Court in NN Global Mercantile v. Indo Unique Flame
• N.N. Global Mercantile (P) Ltd. v. Indo Unique Flame Ltd. and Ground Realities of Indian Situation
• What are Non-Arbitrable Disputes? When a Dispute is Not Referred to Arbitration in spite of Arbitration Clause
• Termination or Nullity of Contract Will Not Cease Efficacy of the Arbitration Clause
• No Valid Arbitration Agreement ‘Exists’ – Can Arbitration Clause be Invoked?

Will

• Witnesses to the Will Need Not See the Execution of the Will
• Interpretation of Wills
• Interpretation of Inconsistent Clauses in a Will
• Will – Probate and Letters of Administration
• Executors of Will – Duties & their Removal
• How to Prove a Will, in Court?Is Presumption enough to Prove a Registered Will?
• How to Write a Will? Requirements of a Valid Will
• When Execution of a Will is ‘Admitted’ by the Opposite Side, Should it be ‘Proved’?
• A Witness to Hindu-Will will not Lose Benefit

Book No. 2: A Handbook on Constitutional Issues

• Judicial & Legislative Activism in India: Principles and Instances
• Can Legislature Overpower Court Decisions by an Enactment?
• Separation of Powers: Who Wins the Race – Legislature or Judiciary?
• Kesavananda Bharati Case: Never Ending Controversy
• Mullaperiyar Dam: Disputes and Adjudication of Legal Issues
• Article 370: Is There Little Chance for Supreme Court Interference
• Maratha Backward Community Reservation: SC Fixed Limit at 50%.
• Polygraphy, Narco Analysis and Brain Mapping Tests
• CAA Challenge: Divergent Views
• FERA, 1973 And Transfer of Immovable Property by a Foreigner
• Doctrine of ‘Right to be Forgotten’ in Indian Law
• Doctrines on Ultra Vires and Removing the BASIS of the Judgment, in ED Director’s Tenure Extension Case (Dr. Jaya Thakur v. Union of India)
• Dr. Jaya Thakur v. Union of India – Mandamus (Given in a Case) Cannot be Annulled by Changing the Law
• Art. 370 – Turns the Constitution on Its Head

Religious issues

• Secularism and Art. 25 & 26 of the Indian Constitution
• Secularism & Freedom of Religion in Indian Panorama
• ‘Ban on Muslim Women to Enter Mosques, Unconstitutional’
• No Reservation to Muslim and Christian SCs/STs (Dalits) Why?
• Parsi Women – Excommunication for Marrying Outside
• Knanaya Endogamy & Constitution of India
• Sabarimala Review Petitions & Reference to 9-Judge Bench
• SABARIMALA REVIEW and Conflict in Findings between Shirur Mutt Case & Durgah Committee Case
• Ayodhya Disputes: M. Siddiq case –Pragmatic Verdict

Book No. 3: Common Law of CLUBS and SOCIETIES in India

• General
  • General Features
  • Bye Laws Fundamental
  • Effect of Registration of Societies and Incorporation of Clubs
  • Societies and Branches
• Property & Trust
  • Vesting of Property in Societies and Clubs
  • Incidents of Trust in Clubs and Societies
  • Juristic Personality of Societies and Clubs
  • Legal Personality of Trustees and Office Bearers
• Suits
  • Suits and Criminal Complaints By and Against a Company
  • Suits By or Against Societies, Clubs
  • Court’s Jurisdiction to Interfere in the Internal Affairs
  • How to Sue Societies, Clubs and Companies
  • Members of a Charitable Society which Runs a College are Tractable to Prevention of Corruption Act
• Amendment and Dissolution
  • Amendment of Bye laws of Societies and Clubs
  • Dissolution of Societies and Clubs
• Rights and Management
  • Rights & Liabilities of Members of Clubs and Societies
  • Individual Membership Rights in Societies & Clubs
  • Management – Powers of General Body and Governing Body
  • Expulsion of Members & Removal of Office-Bearers
  • Law on Meetings: An Overview
  • How to Prove Resolutions of a Company; Are Minutes Necessary?
• Election
  • Election & Challenge in Societies and Clubs
  • Court Interference in Election Process
• State Actions
  • State-Interference in Affairs of Societies & Clubs

Book No. 4: Common Law of TRUSTS in India

• General Principles
  • What is Trust in Law?
  • Classification of Trusts
  • Public & Private Trusts in India.
  • Trust is ‘An Obligation’; Not a Legal Entity
  • Indian Law Does Not Accept Salmond, as to Dual Ownership
  • Lucknow Nagar Nigam v. Kohli Brothers Colour Lab, 2024-2 SCR 847
• Dedication and Vesting
  • Dedication of Property in Public Trusts
  • Vesting of Property in Trusts
  • Incidents of Trust in Clubs and Societies
  • What is Munambam Wakf Land Issue? If there is No Permanent Dedication, there will be No Wakf.
• Trustees and Management
  • Trustees and Administration of Public Trusts
  • Alienation of Public Trust Property
  • Extinction, Discharge, Revocation, etc. of Public Trusts
  • Charitable and Religious Trusts Act, 1920: Provisions as regards opinion, advice or direction of the Court.
• Breach of Trust
  • Breach of Trust and Removal of Trustees
• Suits by or against Trusts
  • Suits By or Against Trusts and Trustees
  • Remedies Under Sec. 92 CPC
  • Operation Asha  v. Shelly Batra, a Landmark Judgment on Sec. 92, CPC – Critical Appreciation
  • Does Cheque-Case under Sec. 138, NI Act Lie Against a Trust?
• Law on Hindu Religious Endowments
  • Philosophy of Idol Worship
  • Is an Idol a Perpetual Minor?
  • Hindu Temples & Law of Trusts
  • Law of Mutts and Other Hindu Endowments
  • Shebaits & Mahants and Law of Trustees
• Temples, Gurudwaras, Churches and Mosques – General
  • Legal Personality of Temples, Gurudwaras, Churches and Mosques
• Constitutional Principles
  • Secularism and Art. 25 & 26 of the Indian Constitution
  • Secularism & Freedom of Religion in Indian Panorama
  • ‘Muslim Women: Ban to Enter Mosques, Is it Unconstitutional
  • Parsi Women Excommunication, Unconstitutional.
  • Knanaya Endogamy & Constitution of India
  • State & Court – Protectors of All Charities
• Ayodhya and Sabarimala Disputes
  • Ayodhya Disputes: M. Siddiq case – Pragmatic Verdict
  • Sabarimala Review Petitions & Reference to 9-Judge Bench
  • SABARIMALA REVIEW and Conflict in Findings between Shirur Mutt Case & Durgah Committee Case
• General
  • Public Trusts and (State) Endowments/Trusts Acts
  • Public Trusts and Indian Trusts Act – An Overview
  • Business by Charitable Trusts & Institutions