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Checking relevance for ARJUN PANDITRAO KHOTKAR VS KAILASH KUSHANRAO GORANTYAL...
ARJUN PANDITRAO KHOTKAR VS KAILASH KUSHANRAO GORANTYAL - 2020 4 Supreme 405 : The evidentiary value of a video without a Section 65B certificate is not automatically excluded if there is ''''substantial compliance'''' with the requirements of Section 65B of the Indian Evidence Act, 1872. In the case analyzed, the High Court admitted video recordings (VCDs) into evidence despite the absence of a formal written certificate under Section 65B(4), because the court found that the conditions of Section 65B were substantially fulfilled through the sworn testimony of a competent officer (Smt. Mutha), who confirmed the regular use of video cameras, proper recording practices, and the authenticity of the records. The court held that the substantive evidence on oath from the responsible official constituted compliance with Section 65B, thereby rendering the electronic record admissible. Thus, the absence of a formal certificate does not necessarily bar admissibility if the court finds that the statutory requirements have been met through other credible evidence, particularly when the party seeking admission has made all reasonable efforts to obtain the certificate and the opposing party obstructs its production.Checking relevance for Arjun Panditrao Khotkar VS Kailash Kushanrao Gorantyal...
Arjun Panditrao Khotkar VS Kailash Kushanrao Gorantyal - 2019 0 Supreme(SC) 2202 : The evidentiary value of a video without a Section 65-B certificate is significantly limited. According to the Supreme Court in Anvar P.V. vs. P.K. Basheer (2014) 10 SCC 473, an electronic record such as a video, when offered as secondary evidence, cannot be admitted in evidence unless the requirements of Section 65-B of the Indian Evidence Act are satisfied. This includes the production of a certificate under Section 65-B(4), which must be issued by a person in a responsible position regarding the operation of the device or management of the relevant activities. However, the Court in Shafhi Mohammad vs. State of Himachal Pradesh (2018) 2 SCC 801 clarified that the requirement of such a certificate is not always mandatory—specifically, when the electronic evidence is produced by a party who is not in possession of the device from which the record was generated. In such cases, the court may admit the evidence under Sections 63 and 65 of the Evidence Act, provided the authenticity and relevance are established. Thus, while the absence of a Section 65-B certificate generally renders a video inadmissible as secondary evidence, the court retains discretion to admit it if the party producing it cannot obtain the certificate due to lack of control over the device, and the evidence is otherwise authentic and relevant.Checking relevance for Sundar @ Sundarrajan VS State by Inspector of Police...
Sundar @ Sundarrajan VS State by Inspector of Police - 2023 2 Supreme 671 : Under Section 65B of the Indian Evidence Act, 1872, a certificate is mandatory for the admissibility of electronic records as secondary evidence. Without a Section 65B certificate, electronic evidence such as video recordings (including CCTV footage) cannot be admitted in court. The Supreme Court has held in Anvar P.V. v. P.K. Basheer and reaffirmed in Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal that the requirements of Section 65B must be strictly satisfied for electronic evidence to be admissible. The certificate under Section 65B(4) is essential, and without it, secondary evidence of electronic records—including video recordings—is inadmissible. While the original electronic record may be produced as primary evidence without a certificate, if the video is presented as secondary evidence (e.g., a printout, copy, or recorded version), the absence of a Section 65B certificate renders it inadmissible. Therefore, the evidentiary value of a video without a Section 65B certificate is zero in terms of legal admissibility.Checking relevance for Mohd. Arif @ Ashfaq VS State (NCT of Delhi)...
Checking relevance for Kailas S/o Bajirao Pawar VS State of Maharashtra...
Kailas S/o Bajirao Pawar VS State of Maharashtra - 2025 0 Supreme(SC) 1687 : Under Section 65B of the Indian Evidence Act, 1872, a certificate is required to authenticate electronic records such as video evidence. The document confirms that the video recording (Exh. No.32) was admitted into evidence because it was accompanied by a valid Section 65B certificate issued by the witness (Santosh, SW No.2), who verified the technical and legal authenticity of the recording, including details about the camera used (Sony model 450 H.D.) and the process of recording. The court held that once such a certificate is properly issued and the video is authenticated, it is admissible as evidence. However, the absence of a Section 65B certificate would render the video inadmissible, as procedural compliance with Section 65B is mandatory for electronic evidence to have evidentiary value. Therefore, without a Section 65B certificate, the video lacks legal probative value and cannot be relied upon in court.Checking relevance for Kamal Patel VS Ram Kishore Dogne...
Kamal Patel VS Ram Kishore Dogne - 2016 0 Supreme(MP) 996 : Under Section 65-B of the Indian Evidence Act, electronic records such as video recordings on compact discs (CDs/VCDs) are inadmissible in evidence unless they are accompanied by a certificate under Section 65-B(4). This certificate must be signed by a person in a responsible official position and must verify the authenticity, source, and integrity of the electronic record. Without such a certificate, the video cannot be admitted as evidence, regardless of its content or potential relevance. The Supreme Court has held that the absence of a Section 65-B certificate renders secondary evidence of electronic records inadmissible, even if the record is otherwise authentic or produced from a reliable source. Therefore, the evidentiary value of a video without a Section 65-B certificate is zero in a court of law under Indian evidence law.
