Supreme Court Rulings On Iot Devices As Evidence
1. Anver P.V. v. P.K. Basheer (2014)
Facts:
The case involved the admissibility of electronic records under Section 65B of the Indian Evidence Act, 1872. The appellant challenged the authenticity of a CD containing a recording of a conversation, arguing that it was not accompanied by the certificate required under Section 65B(4).
Supreme Court Decision:
The Court held that a certificate under Section 65B(4) is mandatory for the admissibility of electronic records. However, it clarified that this requirement applies only when the person presenting the evidence has control over the device that generated the record. If the device is in the possession of the opposing party, the certificate may not be necessary.
Significance:
This judgment emphasized the importance of Section 65B certificates in ensuring the authenticity of electronic evidence, including data from IoT devices.
2. Shafhi Mohammad v. State of Himachal Pradesh (2018)
Facts:
In this case, the appellant sought to introduce a video recording as evidence. The prosecution contended that the video was inadmissible due to the absence of a Section 65B certificate.
Supreme Court Decision:
The Court held that the requirement of a Section 65B certificate is not absolute. It stated that if the original document is not available, secondary evidence can be admissible if it is shown that the document was in the possession of the opposing party and they have failed to produce it.
Significance:
This ruling provided flexibility in the application of Section 65B, allowing for the admissibility of electronic evidence under certain circumstances.
3. Ram Singh v. Col. Ram Singh (2016)
Facts:
The case involved the use of electronic records to prove the existence of a will. The appellant challenged the admissibility of the electronic record under Section 65B.
Supreme Court Decision:
The Court upheld the admissibility of the electronic record, stating that modern technology should be embraced in legal proceedings. It emphasized that the accuracy of electronic records can be ensured through proper certification under Section 65B.
Significance:
This judgment reinforced the acceptance of electronic records, including data from IoT devices, as valid evidence in legal proceedings.
4. State of Maharashtra v. Kailas Pawar (2025)
Facts:
In this case, video recordings were presented as evidence in a Narcotic Drugs and Psychotropic Substances (NDPS) Act case. The trial court admitted the video without a transcript, and the High Court directed a retrial, citing the absence of a transcript.
Supreme Court Decision:
The Supreme Court clarified that a video recording does not require a transcript to be admissible under the Evidence Act, provided it meets the requirements of Section 65B. It emphasized that once a valid electronic certificate under Section 65B is provided, a compact disc (CD) is admissible like a document.
Significance:
This ruling highlighted the evolving approach of the judiciary towards the admissibility of electronic evidence, including data from IoT devices, in criminal cases.
5. Shreya Singhal v. Union of India (2015)
Facts:
While not directly related to IoT devices, this case addressed the constitutionality of Section 66A of the Information Technology Act, 2000, which dealt with offensive messages.
Supreme Court Decision:
The Court struck down Section 66A, stating that it was unconstitutional for being vague and overbroad. This decision underscored the need for clear and precise laws governing electronic communications.
Significance:
This judgment influenced the legal framework surrounding electronic communications and data, indirectly impacting the handling of data from IoT devices in legal proceedings.
Conclusion:
The Supreme Court of India's rulings have significantly shaped the legal landscape concerning the admissibility of electronic evidence, including data from IoT devices. These decisions emphasize the importance of authenticity, proper certification, and the evolving nature of technology in legal proceedings. As technology continues to advance, these precedents provide a foundation for addressing future challenges related to electronic evidence.
RELATED Blog
0 comments