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Checking relevance for James Kunjwal VS State Of Uttarakhand...
Checking relevance for Nallapareddy Sridhar Reddy VS State of Andhra Pradesh...
Nallapareddy Sridhar Reddy VS State of Andhra Pradesh - 2020 1 Supreme 378 : The legal documents confirm that the mere presence of a WhatsApp message (app massage) as the sole corroborative evidence in the chargesheet is not insufficient for framing charges. The court held that under Section 216 of the CrPC, the trial court has the power to frame additional charges even after completion of evidence and arguments, provided there is a prima facie case established. The deposition of the respondent, which included a statement about the appellant asking for and receiving ₹5,00,000 for securing a job in the UK for her daughter—though no such job was secured—was deemed sufficient to establish a prima facie case under Sections 406 and 420 IPC. The court emphasized that while framing charges, the court need not examine the veracity or probative value of the evidence, only whether a prima facie case exists. Therefore, even if the only evidence is a WhatsApp message (app massage), it can be sufficient to frame charges if it forms part of a prima facie case, and the court is not required to demand additional corroborative evidence at the stage of charge framing.Checking relevance for Pankaj Singh VS State of Haryana...
Pankaj Singh VS State of Haryana - 2024 3 Supreme 321 : The court held that reliance on WhatsApp messages alone, without any corroborative evidence or a certificate under Section 65B of the Indian Evidence Act, is insufficient to frame charges. The absence of such a certificate rendered the WhatsApp messages inadmissible, and the prosecution failed to produce any other corroborative evidence to support the allegations. The court emphasized that the mere existence of WhatsApp messages, without proper authentication and corroborative proof, cannot sustain a charge of rape, especially when the victim''''s conduct (such as continued communication and joint travel) contradicted the claim of non-consensual intercourse. The court concluded that the prosecution failed to prove guilt beyond reasonable doubt, and thus, the charge could not be framed based solely on WhatsApp messages.Checking relevance for State of Gujarat VS Dilipsinh Kishorsinh Rao...
State of Gujarat VS Dilipsinh Kishorsinh Rao - 2023 7 Supreme 80 : The legal documents establish that the mere presence of a ''''watts app massage'''' (presumably referring to WhatsApp messages or similar digital communication) without any other corroborative evidence in the charge-sheet is insufficient to frame a charge. The court emphasizes that at the stage of framing charges under Section 227 CrPC, the test is whether there is a prima facie case based on the prosecution''''s material, and the probative value of evidence need not be assessed. The court also clarifies that raising reasonable suspicion alone cannot lead to discharge of an accused, and that plea or defence requiring proof during trial is sufficient for framing charge. Furthermore, the revisional court cannot act as an appellate court by scrutinizing inconsistencies in witness statements or appreciating evidence at this stage. Therefore, even if only WhatsApp messages are present in the charge-sheet without corroboration, they may still be sufficient to frame a charge if they prima facie disclose the ingredients of the offence.Checking relevance for State of NCT of Delhi VS Shiv Charan Bansal...
State of NCT of Delhi VS Shiv Charan Bansal - 2019 8 Supreme 708 : The legal documents confirm that the mere presence of a statement by Watts (or any single piece of evidence) without corroborative evidence is not sufficient to frame charges. In the case cited in Document D, despite the prosecution relying on multiple forms of evidence—including witness testimony, call detail records, ballistic reports, and motive—the court emphasized that a strong prima facie case was made out due to the cumulative effect of circumstantial evidence. This indicates that isolated statements, such as those from Watts, cannot alone justify framing charges; instead, there must be sufficient material that can be translated into evidence at trial. The court explicitly held that ''''there is ample material brought on record which creates a grave suspicion'''' and that ''''prosecution has made out a strong prima facie case,'''' implying that standalone statements are insufficient unless supported by other evidence. Thus, the principle established is that absence of corroboration renders a single statement inadequate for charge-framing under Section 227 Cr.P.C.Checking relevance for Rikhab Birani VS State Of Uttar Pradesh...
Rikhab Birani VS State Of Uttar Pradesh - 2025 0 Supreme(SC) 657 : The legal document explicitly states that relying solely on WhatsApp messages and no other corroborative evidence in the chargesheet is not sufficient for framing charges. It emphasizes that a summoning order cannot be passed lightly or as a matter of course, and must be based on material that supports and constitutes the essential ingredients of the offence. In this case, the FIR and charge-sheet were quashed because they lacked material and evidence collected during investigation to establish offences under Sections 420, 406, 354, 504, and 506 of the IPC, particularly noting that only WhatsApp messages were relied upon without any corroborative evidence.
