How to Obtain Hash Value of Printout Under BSA 63 Certificate

In today's digital age, electronic records and their printouts play a crucial role in legal proceedings across India. But how do you ensure that a simple printout of a digital document is admissible as evidence? A key requirement often arises: obtaining the hash value under a BSA 63 Certificate. If you're wondering how to obtain hash value of printout under BSA 63 CERTIFICATE, this guide breaks it down based on legal precedents and practices.

The Bharatiya Sakshya Adhiniyam, 2023 (BSA), particularly Section 63(4)(c), mandates a certificate for printouts of electronic records to prove their authenticity and integrity. Hash values—digital fingerprints generated via algorithms like SHA-256—verify that the printout matches the original electronic file without tampering. While courts emphasize this for admissibility, the process blends technical steps with legal formalities. Note: This is general information; consult a legal professional for case-specific advice.

Understanding BSA Section 63 and Hash Values

Section 63 of the BSA governs the admissibility of electronic records, replacing the older Section 65B of the Indian Evidence Act, 1872. A certificate under Section 63(4)(c) is typically required when producing printouts or copies of electronic records in court. This certificate must be issued by a person in control of the device or data, attesting to the record's accuracy and integrity. ARJUN PANDITRAO KHOTKAR VS KAILASH KUSHANRAO GORANTYAL - 2020 4 Supreme 405

Hash values are central here, acting as cryptographic proof. As noted in legal analyses, the process of verifying electronic evidence involves ensuring the integrity and source, often through cryptographic hash functions, which generate hash values as part of the digital signature or checksum process. Arjun Panditrao Khotkar VS Kailash Kushanrao Gorantyal - 2019 0 Supreme(SC) 2202

Without a proper hash value and certificate, printouts risk rejection. Courts have clarified that electronic records are more susceptible to tampering, and therefore, safeguards such as certificates are essential. Arjun Panditrao Khotkar VS Kailash Kushanrao Gorantyal - 2019 0 Supreme(SC) 2202

Why Hash Values Matter for Printouts

• Uniqueness: A hash value uniquely represents the digital content; even minor changes alter it.
• Evidentiary Value: Courts accept hash-verified records as secondary evidence. XXXX VS State Of Kerala - 2023 0 Supreme(Ker) 888
• Tamper-Proofing: Matches between original file hash and printout-derived hash confirm integrity.

Step-by-Step Process to Obtain Hash Value

Although statutes don't prescribe exact technical steps, standard practices derived from case law and expert procedures include:

1. Secure the Original Electronic File: Start with the digital source (e.g., PDF, image) used for printing. Avoid alterations post-printing.

2. Generate the Hash Value:

3. Use tools like EnCase, FTK Imager, or open-source options (e.g., sha256sum on Linux, certutil on Windows).

4. Example: For a file document.pdf, compute SHA-256 hash. In one case, a witness computed the hash of a pen drive as C05DBC91EB8F631A04F8CE027D4AD227 using EnCase v.4 in write-protection mode, confirming no errors. Ranjan Daimari @ D. R. Nabla @ Lasdum @ Loudum, S/o- Late Stephen Daimari VS Mathu Ram Brahma @ Mudai, S/O Sri Rasama Brahma - 2022 Supreme(Gau) 684

5. Handle the Printout:

6. Print from the verified digital file.

7. To derive hash from printout: Scan the printout at high resolution to recreate a digital version, then hash it. However, courts prefer hashing the original electronic record.

8. Prepare the Section 63(4)(c) Certificate:

9. The certificate must state: The record is produced from a device under the deponent's control; it's a fair reproduction; and include the hash value for integrity.

10. Sign by a responsible person (e.g., IT head, device owner). If unavailable, seek court directions. Arjun Panditrao Khotkar VS Kailash Kushanrao Gorantyal - 2019 0 Supreme(SC) 2202

11. File in Court with Hash Report:

12. Submit the printout, original file (on CD/DVD), hash value, and certificate.
13. Courts often grant time extensions for hash reports, as in applications under Section 151 CPC. SARVATRA TECHNOLOGIES PVT LTD vs BHARAT SANCHAR NIGAM LIMITED - 2025 Supreme(Online)(DEL) 469ALLIED BLENDERS AND DISTILLERS LIMITED vs TILAKNAGAR INDUSTRIES LIMITED & ORS. - 2024 Supreme(Online)(DEL) 32875

In practice: For the said purpose the Respondent may make a proper copy of the data from the mobile phones on a CD/Pen Drive and a hash value may be added to preserve the integrity of the data. RAKESH KUMAR GUPTA Vs DIRECTORATE OF REVENUE INTELLIGENCE - 2025 Supreme(Online)(Del) 3109

Real-World Case Examples

Indian courts routinely apply these rules:

• Legal Heirship Certificates: Printouts of certificates (e.g., Ex.P8 for Mrs. Rajamma dated 18.02.2024) were admitted with certificates u/s 63(4)(c) of BSA 2023. Reeja vs No Respondent - 2025 Supreme(Online)(Mad) 59399

• Photographs and Documents: Photos of restaurant branches (Ex.P20, Ex.P24) and online printouts (Ex.P10) filed with BSA 63 certificates. M/s Sangeetha Caterers And Consultants Llp vs M/S NELLAI SANGEETHAS - 2025 Supreme(Online)(MAD) 10507Loffy Mathew vs Princy and another - 2025 Supreme(Online)(Mad) 69574

• Death Certificates: Printouts like Ex.P4 (V. Kanniammal dated 26.04.2024) accompanied by u/s 63(4)(c) certificates. A.Kuttipillai vs J.Ramesh - 2025 Supreme(Online)(Mad) 61045

• Hash Reports in Trademarks: Plaintiffs sought extensions for Hash Report and Expert Certificate under Section 63(4)(C) in infringement suits. SARVATRA TECHNOLOGIES PVT LTD vs BHARAT SANCHAR NIGAM LIMITED - 2025 Supreme(Online)(DEL) 469

• Forensic Verification: In criminal cases, hard disk footage hashes were compared to detect tampering: if the files of footage are tampered, it will have different hash value than the hash value appearing in the Hard Disk. Bhupesh @ Rinku s/o Vitthalrao Tichkule VS State of Maharashtra, through Police Station Officer, Sakkardara, Nagpur - 2018 Supreme(Bom) 768Bhupesh @ Rinku s/o Vitthalrao Tichkule VS State of Maharashtra, through Police Station Officer, Sakkardara, Nagpur - 2018 Supreme(Bom) 711

These examples show hash values embedded in certificates ensure admissibility across civil (guardianship, succession) and criminal matters.

Challenges and Court Remedies

Common hurdles:- Non-Availability of Certifier: Courts direct production, as under BSA provisions. Arjun Panditrao Khotkar VS Kailash Kushanrao Gorantyal - 2019 0 Supreme(SC) 2202- Time Constraints: Extensions granted, e.g., the plaintiff is granted four weeks’ time to file abovesaid Hash Report. ALLIED BLENDERS AND DISTILLERS LIMITED vs TILAKNAGAR INDUSTRIES LIMITED & ORS. - 2024 Supreme(Online)(DEL) 32875- Technical Disputes: Mismatches lead to rejection; always use standard algorithms.

In live streaming or database copies, hashes preserve chain of custody: the technical team has gone through the recording... and copied in the pen-drive with hash-key. SUO MOTU V/s VISHWABHAI JAYANTILALBHAI VARSANI - 2025 Supreme(GUJ) 679

Key Recommendations

• Generate hashes from originals using reliable tools.
• Include hashes in BSA 63(4)(c) certificates explicitly.
• Store copies on secure media (CD/DVD) with hashes.
• For disputes, file interlocutory applications for expert verification.

Conclusion and Key Takeaways

Obtaining a hash value for a printout under BSA 63 Certificate safeguards electronic evidence's reliability in court. While technical, it's legally mandated for admissibility. Primary method: Hash the electronic original, certify via Section 63(4)(c), and produce alongside the printout. Cases affirm this protects against tampering claims.

Takeaways:- Certificates are a condition precedent for admissibility. ARJUN PANDITRAO KHOTKAR VS KAILASH KUSHANRAO GORANTYAL - 2020 4 Supreme 405- Hashes ensure integrity—courts verify matches.- Seek extensions if needed; courts are pragmatic.

This overview draws from judicial precedents but isn't exhaustive. For tailored guidance, engage a lawyer familiar with BSA 2023.

References:- ARJUN PANDITRAO KHOTKAR VS KAILASH KUSHANRAO GORANTYAL - 2020 4 Supreme 405, Arjun Panditrao Khotkar VS Kailash Kushanrao Gorantyal - 2019 0 Supreme(SC) 2202, XXXX VS State Of Kerala - 2023 0 Supreme(Ker) 888, Reeja vs No Respondent - 2025 Supreme(Online)(Mad) 59399, SARVATRA TECHNOLOGIES PVT LTD vs BHARAT SANCHAR NIGAM LIMITED - 2025 Supreme(Online)(DEL) 469, and others cited inline.