PROFESSIONALS' LAW INSTITUTE - 9915888172
INDIAN EVIDENCE ACT 1872
• came
into force on 1st September 1872
• Drafted
by James F. Stephen
•
Divided into three parts,
• Part I of the act deals with the Relevancy of facts,
• Part ll deals with proof and the various kinds of evidence and
• Part lll deals with the Production and Effect of evidence.
•
11 chapters and comprises of 167 sections.
SALIENT FEATURES
1. Procedural
Law
2. Lex
Fori
3. Nature
of law of Evidence
4. Not
Exhaustive
5. Scheme
of the act
6. Object
of Law of Evidence
7. Basic
rules of Evidence
8. Section
1: Application of Evidence Act
9. Same
for both civil and criminal proceedings
10. Meaning
of word ‘Evidence’
11. Kinds
of Evidence
12. Relevancy
and Admissibility
13. Credibility
and Appreciation of Evidence
14. Doctrine
of Corpus Delicti
15. Falsus
in uno falsus in omnibus
1.
PROCEDURAL
LAW
The
Substantive and Procedural Laws are the two important branches of Law. The
terms “Substantive” and “Adjective” seem to have been invented by Bentham in
1843.
Substantive
laws define the legal relationship between different individuals, or between
individuals and the State. Procedural laws define the rules with which
substantive laws may be enforced.
In
the case of Commissioner of Wealth Tax,
Meerut vs. Sharvan Kumar Swarup & Sons [(1994)122 CTR(SC)380], the
distinction between Substantive and Procedural Laws was made clear. “As a
General Rule, laws which fix duties, establish rights and responsibilities
among & for persons natural or otherwise are “Substantive laws”, while
those which merely prescribe the manner in which such rights & responsibilities
may be exercised & enforced in a Court are ‘Procedural Laws’.”
Thus,
Evidence Act is essentially a procedural law.
2.
LEX
FORI
•
IEA is the law of the forum (or court)
•
If foreigners come before an Indian court they cannot insist upon their law of
evidence being followed. The Indian court knows only the Indian Law of Evidence
and will follow it
3.
NATURE
OF LAW OF EVIDENCE
The
law of evidence occupies the most important place in adjective law. It is for
the courts to ascertain the existence or non-existence of certain facts and to
apply the substantive law to the ascertain facts and to declare the rights and
liabilities of the parties in so far as they are affected by such facts. The
means by which the courts inform themselves of the existence of these facts is
termed as evidence.
Sir Stephen:
Law of Evidence is that part of the law of procedure which with view to
ascertain individual rights and liabilities in particular cases decides
a. What
facts may or may not be proved?
b. What
sort of evidence must be given of a fact which may be proved?
c. By
whom and in what matter the evidence must be produced?
4.
Not
Exhaustive
•
The Act is not exhaustive. There are many statutes which supplement the
Evidence Act Some of them are-
•
Crpc
•
CPC
•
Bankers book evidence act
•
Stamp act
•
Indian Limitation Act
5.
SCHEME
OF THE ACT
It
contains 3
parts, 11 chapters and 167 sections.
·
PART I - Relevancy Of Facts (Ss. 1-55)
o
CHAPTER I – Preliminary (Ss. 1 – 4)
o
CHAPTER II – Of the Relevancy of Facts (Ss.
5 – 55)
·
PART II – On Proof (Ss. 56 – 100)
o
CHAPTER III – Facts Which Need Not Be Proved
(Ss. 56 – 58)
o
CHAPTER IV.—OF ORAL EVIDENCE (Ss. 59 – 60)
o
CHAPTER V.— OF DOCUMENTARY EVIDENCE (Ss. 61
– 90-A)
o
CHAPTER VI. –– OF THE EXCLUSION OF ORAL BY
DOCUMENTARY EVIDENCE (Ss. 91 – 100)
·
PART III – PRODUCTION AND EFFECT OF
EVIDENCE (Ss. 101 – 167)
o
CHAPTER VII. –– OF THE BURDEN OF PROOF (Ss.
101 – 114-A)
o
CHAPTER VIII. –– ESTOPPEL (Ss. 115 – 117)
o
CHAPTER IX.— OF WITNESSES (Ss. 118 – 134)
o
CHAPTER X. –– OF THE EXAMINATION OF
WITNESSES (Ss. 135 – 166)
o
CHAPTER XI–– OF IMPROPER ADMISSION AND
REJECTION OF EVIDENCE (S. 167)
·
THE SCHEDULE [Repealed.]
6.
OBJECT
OF LAW OF EVIDENCE
1. Preamble.—WHEREAS it is expedient to consolidate,
define and amend the law of Evidence; it is hereby enacted as follows:—
The
object of the preamble of an Act is to indicate what, in general terms, was the
object of the Legislature in passing the Act. The preamble here shows that the
Indian Evidence Act is not merely a fragmentary enactment, but a consolidated
one.
The
object of the court is to prevent the inaccuracy in the admissibility of
evidence and to introduce a more correct and uniform rule of practice.
2.
The Law of Evidence helps the judges to
separate wheat from chaff amongst the mass of facts that are brought before
them. It helps to draw correct inferences from the circumstances mentioned
during the hearing of the case and helps to deliver a judgement.
3.
The IEA provides the rules relating to
a.
As to what facts may be proved?
b.
How to prove those facts?
c.
On whom burden of proof lies?
d.
How the knowledge of the witnesses to be placed before court?
e.
Who are competent witnesses and who cannot be witnesses?
f.
Rules as to chief examination, cross examination and re-examination e.g. How to
impeach the credit of the witnesses etc.
7.
BASIC
RULES OF EVIDENCE
The
main principles which forms the foundation of Law of Evidence are
•
Evidence must be confined to the matter in issue;
•
Hearsay evidence must not be admitted; and
•
Best evidence must be given in all cases.
8.
Application
of Evidence Act: Section 1 of IEA
1.
Short title, extent and commencement. -
This
Act may be called the Indian Evidence Act, 1872.
It
extends to the whole of India [[***]]and applies to all judicial
proceedings in or before any Court, including Courts-martial, [other than
Courts-martial convened under the Army Act (44 & 45 Vict.,Clause
58),] [the Naval Discipline Act (29 & 30 Vict., c.109) or [* *
*]the Indian Navy (Discipline) Act, 1934 (34 of 1934),] [or the Air Force
Act (7 Geo. t, Clause 51)], but not to [affidavits] presented to any
Court or Officer, not to proceedings before an arbitrator;
And
it shall come into force on the first day of September, 1872.
|
Where
it applies |
Where
it do not apply |
|
• In India • All judicial proceedings in or before
any Court • including Courts-martial |
• other than Courts-martial convened under
· the
Army Act (44 & 45 Vict., c. 58) · the
Naval Discipline Act (29 & 30 Vict., c. 109) or · the
Indian Navy (Discipline) Act, 1934 (34 of 1934) or ü · the
Air Force Act • affidavits presented to any Court or
Officer • to proceedings before an arbitrator |
Proceedings can be:
a) Judicial
proceedings
b) Non
judicial proceedings
c) Domestic
Tribunals
d) Disciplinary
proceedings
e) Proceedings
before an Arbitrator
Judicial Proceedings:
· The
Evidence Act applies to all judicial proceedings in or before any court. It does not apply to non-judicial proceedings.
· The
term "judicial proceedings" is
not defined by the Act. According to Section
2(i) of Cr.P.C, a judicial proceeding includes any proceedings in the
course of which evidence is or may be legally taken on oath.
· The
main object of judicial proceeding, is to determine rights, duties,
liabilities, immunities, disabilities etc. An inquiry in which evidence is
legally taken and Judgment is authorized to be given and acted upon, is
included in the term "judicial proceeding".
· That
is why the word "Court" has been defined in Section 3 as including
all Judges and magistrates, and all persons, except arbitrators, who are
legally authorized to take evidence. The word "Court" includes all
the persons who are legally authorized to take evidence.
Non-judicial Proceedings:
· A
proceeding in which only administrative duties are to be discharged cannot be
said as a judicial proceeding. An enquiry about matters of fact where there is
no discretion is to be exercised and no Judgment to be formed but something is to
be done in a certain event as duty, is not a Judicial but an administrative
enquiry.
· It
concerns with investigation of facts only and that is why, law of evidence does
not apply to non-judicial proceeding.
· Examples:
o
The statements recorded by a Magistrate in
the course of police investigation under Section 164, CrPC is not a judicial
proceeding.
o
Proceedings before a Magistrate under
Section 88, CrPC,
o
an enquiry under Section 176/ 340, CrPC,
o
an enquiry conducted by a Collector under
the Land Acquisition Act, or
o
an inquest before the Coroner under the
Coroner Act,1871,
o
proceedings before the authorities of
income-tax, sales-tax are not judicial proceedings.
Domestic Tribunals
· A
tribunal is a Court of Justice, while the Court is a Court of law and Court of
Justice.
· The
basic principle is that the domestic tribunals are not bound by the technical
rules of procedure contained in the Evidence Act but they have to conform to
the cardinal rules of evidence in order to obviate injustice.
· The
substantive rules which would form part of Principles of natural justice cannot
be ignored by the domestic tribunals.
· The
principle that a fact sought to he proved must be supported by statements made
in the presence of the person against whom the enquiry is held and that the
statements made behind the back of the person charged are not to be treated as
substantive evidence, is one of the basic principles which cannot be ignored on
the mere ground that the domestic tribunals are not bound by the technical
rules of procedure contained in the Evidence Act.
Disciplinary Proceedings:
· The
departmental proceeding/enquiry is a quasi-judicial proceeding and the
provisions of the Evidence Act may not be properly applicable to it, but the
principles of natural justice shall be.
· However,
in disciplinary proceedings, the proof required is beyond reasonable doubt as
the proceedings are like criminal proceedings.
Proceedings before an Arbitrator:
· Section
19 of the The Arbitration and
Conciliation Act, 1996
‘19. Determination of rules
of procedure.
(1) The arbitral tribunal
shall not be bound by the Code of Civil Procedure, 1908 (5 of 1908) or the
Indian Evidence Act, 1872 (1 of 1872).
******’
· The
Arbitrators are only bound by rules of natural justice.
· He
decides the disputes according to justice, equity and good conscience.
9.
SAME
FOR BOTH CIVIL & CRIMINAL PROCEEDINGS
1. S.5
IEA provides that “Evidence may be given in any suit or proceedings…………” Thus
it is clear that evidence act is applicable to both civil & criminal
proceedings.
2. However,
an Evidence may be sufficient to prove a claim or right in a civil case but the
same evidence may not be sufficient to prove a charge in a criminal case.
3. An
evidence may be admissible in a civil case and the same evidence may not be
admissible in a criminal case.
4. There
are certain provisions which are applicable only to civil and certain
provisions which are applicable only to criminal:
|
PROVISIONS
APPLICABLE ONLY TO CIVIL |
PROVISIONS
APPLICABLE ONLY TO CRIMINAL |
|
1. S.12 2. S.23 3. S.52, 55 4. No presumption of Innocence 5. BOP keeps on shifting 6. Standard of Proof- Preponderance of
probabilities 7. Estoppel |
1. S.24-30 2. S.53, 53A, 54 3. Presumption of Innocence in favour of
accused 4. BOP Always on Prosecution. It never
shifts but onus shifts 5. Standard of Proof- Beyond Reasonable
doubt 6. Accomplice |
10.
MEANING
OF WORD ‘EVIDENCE’
•
The word "evidence" is derived from the Latin word evidens or
evidere, which means "to show clearly; to make clear to the sight; to
discover clearly; to make plainly certain; to ascertain; to prove".
• Under Indian Evidence Act
• S.3 IEA: Evidence— “Evidence”
means and includes—
(1)
all statements which the Court permits or requires to be made before it by
witnesses, in relation to matters of fact under inquiry, such statements are
called oral evidence;
(2)
[all documents including electronic records produced for the inspection of the
Court], such documents are called documentary evidence
• Other Definitions
· Evidence
is anything that you see, experience, read, or are told that causes you to
believe that something is true or has really happened.
· Evidence
is the available body of facts or information indicating whether a belief or
proposition is true or valid.
· Evidence
is "the means from which an inference may logically be drawn as to the
existence of a fact. It consists of proof by testimony of witnesses, on oath,
or by writing or records."
Hardeep Singh v State of Punjab AIR
2014 SC 1400
The
definition of evidence provided under section 3 of the Evidence Act, 1872 is an
exhaustive definition. Wherever the words "means and includes" are
used, it is an indication of the fact that the definition "is a
hard-and-fast definition", and no other meaning can be assigned to the
expression other than that is laid down in the definition. It indicates an
exhaustive explanation of the meaning which, for the purposes of the Act, must
invariably be attached to these words or expression.
Syed Mohammad Husain Afqar Mohani v
Mirza Fakhrullah Beg, (1932) 8 Luck 135
The
juristic conception of the term "evidence" in the case of the oral
testimony of witnesses is that the party against whom it is used has had the
right and opportunity of cross-examining the witnesses. So long as the accused
is not allowed the right and opportunity of cross-examining the witnesses, any
statements made by them can only be described as statements but cannot be
dignified with the name of evidence.
The
definition of "evidence" covers
(a)
the evidence of witnesses, and
(b)
documentary evidence. "
Evidence
can be both oral and documentary and electronic records can be produced as
evidence.
The
word "evidence" does not cover everything that a court has before it.
There are certain other media of proof; e.g., the statements of the parties,
the result of local investigation, facts of which the court takes judicial
notice, and any real or personal property, the inspection of which may be
material in determining the question at issue, such as weapons, tools or stolen
property.
The
definition of "evidence" is considered to be incomplete as it does
not include the whole material on which the decision of the Judge may rest.
11.
KINDS
OF EVIDENCE
1. Best
Evidence
2. Direct
evidence
3. Circumstantial
evidence
· Hanumant
v. The State Of Madhya Pradesh
· Sharad
Birdhichand Sarda v. State of Maharashtra
4. Hearsay
Evidence
5. Oral
and Documentary Evidence
6. Primary
Evidence and Secondary Evidence
7. Substantive
and corroborative evidence
8. Judicial
evidence & Non-judicial evidence
9. Real
and Personal Evidence
10. Digital/electronic
Evidence
11. Scientific/Expert/Trace
Evidence
12.
Relevancy
and Admissibility
1. Relevant
facts have been defined in Section 3 and 5 of the Indian Evidence Act, 1872
(hereinafter referred to as 'Act'). A perusal of both the provisions says that
evidence may be given of-
(i) The existence or
non-existence of facts in issue; and
(ii) Of such other relevant
facts.
2. The
first part deals with points to facts which directly tend to prove or disprove
facts in issue and the second part refers to collateral facts which are so
inseparably connected with the facts in issue that they indirectly and
presumptively tend to prove or disprove any fact in issue.
3.
Furthermore, relevancy (determined by rules of the Act) is the test of
admissibility. All relevant facts may not be admissible (they may be ruled
out due to prejudice, paucity of time, confusion) and all admissible facts may
not be relevant. While relevancy is based on logic, admissibility only relies
on lawful pertinence, i.e., whether a fact can be permitted in Court on the
basis of the Act. Relevant facts can
thus be termed as genus and admissibility as its specie.
4. As per Bentham,
one fact is relevant to another, if the effect or tendency of the former when
presented to the mind, is to produce a persuasion concerning the existence of
some other matter of fact. As such the relation between factum
probandum and factum probans is called relevancy. As per Sir James Fitzjames Stephen, relevant
means any two facts to which it is applied are so related to each other that,
according to the common course of events, either taken by itself or in
conjunction with other facts, proves or renders probable past, present or
future existence, or non-existence of the other.
5. Section
5-55 of the Act deals with what facts are relevant; but the mere fact of
logical relevancy does not ensure the admissibility of a fact. Very often,
public considerations of fairness and the practical necessity for reaching
speedy decisions necessarily cause the rejection of much of the evidence which
may be logically relevant. Cases of exclusion of logically relevant facts by
positive rules of law are:
(i)
Exclusion of oral by documentary evidence:
Sections 91-99.
(ii)
Exclusion of evidence of facts by estoppel:
Sections. 115-117.
(iii)
Exclusion of privileged communications, such
as confidential communications with a legal adviser, communication during
marriage, official communications, etc.: Sections. 121-130
6. Thus,
relevancy may be considered in the decision-making process.
7. On
the other hand, admissible facts are though strings of relevant facts which are
admissible in Court. Section 136 of the Act states that it is the judge which
would decide on the admissibility of a fact/document. The essential ingredients of the Section 136 are:
i.
The judge will decide the questions of
relevancy and admissibility.
ii.
When a party proposes to adduce evidence of
any fact, the Judge may ask the party to clarify 'in what manner' the fact
would be relevant.
iii.
The Judge would 'admit' the particular
adduced fact only if he is satisfied with the answer of the party that it is,
indeed, relevant under one or the other provisions of S. 6 to 55.
Thus,
it is always the consideration of relevancy that comes first and that of
admissibility comes later, and the judge will admit the fact only if it is
relevant.
8. Admissibility
is based on law and not logic. Facts which may have no logical relevance may
sometimes be admissible in Courts. After an evidence has been declared
logically relevant and legally admissible, how it was obtained becomes
irrelevant.
9. The
Supreme Court in Ram Bihari Yadav vs.
State of Bihar AIR 1998 SC 1850, has observed that more often the
expressions 'relevancy and admissibility' are used as synonyms but their legal
implications are distinct and different from for more often than not facts
which are relevant are not admissible; so also facts which are admissible may
not be relevant, for example questions permitted to put in cross examination to
test the veracity or impeach the credit of witnesses, though not relevant are
admissible. The probative value of the evidence is the weight to be given to it
which has to be judged having regards to the fact and circumstances of each
case.
10. As
seen from above, Admissibility of evidence is strictly based on law whereas
relevancy is based on logic and probability. Secondly, Admissibility declares
whether an evidence is admissible or not, whereas relevancy declares whether
the given facts are relevant to the facts in question.
Difference between relevance &
admissibility
|
RELEVANCY |
ADMISSIBILITY |
|
Relevancy is based on logic and
Probativity. |
Admissibility is not based on logic but on
strict rules of law |
|
The rules of relevancy are described under
Sections 5-55 of IEA. |
The rules of admissibility are described
under Sections 56 onwards of IEA. |
|
The rules of relevancy declare what is
relevant |
The rules of admissibility declare whether
certain type of relevant evidence are admissible or are to be excluded. |
|
The rules of relevancy indicate the facts
permitted to be proved which then becomes admissible |
Admissibility is the means and modes for
admissibility of relevant evidence. |
|
The facts which are admissible are not
necessarily relevant |
The facts which are relevant are not
necessarily admissible |
|
The question of relevancy is a question of
law and can be raised at any stage. |
Question of admissibility is a question of
procedure and is capable of being waived. |
13.
CREDIBILITY
AND APPRECIATION OF EVIDENCE
In the case of Anvar P.V vs
P.K.Basheer & Ors 2014 SC: It was observed as under:
Construction
by plaintiff, destruction by defendant. Construction by pleadings, proof by
evidence; proof only by relevant and admissible evidence. Genuineness, veracity
or reliability of the evidence is seen by the court only after the stage of
relevancy and admissibility. These are some of the first principles of
evidence.
a)
Credibility
of Witness
· Impeaching
the credibility of Witness; Section 155 of IEA
· By
Contradiction; S. 145 IEA
· By
Corroboration; S. 157 IEA
b)
Credibility
of Evidence
· Conclusive
Evidence
· Substantive
piece of Evidence
· Corroborative
piece of Evidence
· Contradictory
piece of Evidence
· May
be taken into Consideration
Appreciation of
evidence
Appreciation of
evidence is a
matter of experience and
knowledge of human affairs. It is a delicate task to be carried out by Judges
for weighing evidence and drawing inferences. Each cases presents its own
peculiarities. Common sense and dexterity are also part of the tools.
Under
section 3 of Evidence Act first the terms
Fact, Relevant Fact and
Fact in issue are defined in
respect of evidence and later when it
can be said to be proved, disproved
and not proved is discussed. Thus, while appreciating evidence in respect
of any fact, relevant fact and fact in issue the Court has to give its anxious
consideration towards the peculiar facts of the case. There may be several facts in a case before
Court and among it some may be relevant or some may be fact in issue. The Court has to first ascertain the facts,
then it has to find out whether they are relevant and then whether they are actually
in issue. After ascertaining this, the
Court shall examine the fact and later by applying rules of evidence Court has
to see that whether those facts are proved, disprove or not proved.
In
appreciation of evidence under section 3 of Indian Evidence Act, the Hon'ble
Supreme Court has illustrated some instances in Ganesh K. Gulve Vs State of Maharashtra AIR 2002 SC 3068 in
following words;
“In order
to appreciate the
evidence, the Court
is required to bear in mind the setup and environment in which the
crime is committed. The level of
understanding of the witnesses. The over
jealousness of some of near relations to ensure that, everyone even remotely
connected with the crime be also convicted.
Everyone's different way of narration of same facts. Etc.”
It
is one of the established principles of law that a witness may lie but not the
circumstances. The guilt of person can be proved by circumstantial evidence
also.
However,
the Court must adopt a cautious approach while basing its conviction purely on
circumstantial evidence. The circumstances relied upon in support of the
conviction must be fully established and the chain of evidence furnished by
those circumstances must be so for complete has not to leave any reasonable
ground for a conclusion consistent with the innocence of the accused and
further it must be such as to show that within all human probability the act
must have been done by the accused.
Abscondance
of the accused is
not a circumstance which can be
taken as a conclusive proof of guilt. False pleas raised by the accused can be
taken as a circumstance against the accused.
False and inconsistent defences
taken by the
accused charged of murder were
held to be additional circumstances against him strengthening the chain of
circumstances already firmly established.
A
statement of an accused recorded under section 313 Cr. P.C. cannot be treated
as evidence. Further the entire prosecution evidence need not be put to the
accused. Unregistered lease deed though not allowed to be produced in evidence,
it could be used by the carrier to explain the character of the possession.
A
witness narrated to the doctor his version of the history of assault. The
doctor recorded in his papers. This was held to be not a substantive piece of
evidence. The statement would be used at based to contradict the testimony of
the person who gave the narrative. (Sujit
Gulab Sohatre Vs State 1997
Cr.L.J. 454 (Bombay).
Presence
of injury on a person of a witness does not guarantee his truthfulness. The
Court is not bound to accept his evidence if it is found to be hopelessly
contradictory and utterly unreliable.
Testimony of
child witness is
not be rejected outright but it
is to be scrutinized with greatest caution.
The
evidence of stock witnesses cannot be relied upon because of appearing as
police witnesses in number of cases and they being pliable and untrustworthy.
14.
CORPUS
DELICTI
• Refers
to the body of the offense or the essence of the crime
• The
term used to refer to the actual victim’s body in a murder case
• Relate
to what must be proven in a case to elicit an acquittal or conviction
•
Object is to protect persons from being unjustly convicted of a crime they did
not commit.
• Corpus delicti—from the Latin meaning
"body of evidence"—is the proof that a crime has taken place. When
applied to a criminal case, proof of a crime must be shown in order to convict
a person of the crime
• few examples :
•
When a person is charged with theft, the corpus delicti is proof that property
was stolen.
•
When a person is charged with the crime of mischief by fire, the corpus delicti
is the burnt property.
•
In a murder case, the corpus delicti is the dead body of the victim.
•
There are exceptions to this rule, however. In certain cases, it may be
admissible to prove the basis of corpus delicti based on presumptive
(circumstantial) evidence rather than conclusive evidence.
• The first U.S. case where conviction
was made without absolute evidence of corpus delicti took place in 1850 in the
murder trial of John Webster.
•
The Supreme Court in Badshah & Ors.
v. State of U.P., Cr. Appeal No. 554 of 2005 categorically held that in the
event of murder of an abducted person, either by direct or presumptive
evidence, an inference of murder can safely be drawn in respect whereof it
would not be necessary to prove the corpus delicti.
15.
Falsus
in Uno Falsus in Omnibus
False
in one, false in all.
This
maxim may properly be applied in those cases only where a witness speaks to a
fact with reference to which he cannot be presumed liable to mistake.
•
The maxim falsus in uno, falsus in omnibus (false in one thing, false in every
thing) is neither a sound rule of law nor a rule of practice. Hardly one comes
across a witness whose evidence does not contain a grain of untruth or at any
rate exaggerations, embroideries or embellishments, Vgar Ahir v. State of Bihar, AIR 1965 SC 277 (279).
•
The maxium 'falsus in uno, falsus in omnibus' has no application in India and
the witnesses cannot be branded as liars. The maxim 'falsus in uno, falsus in
omnibus' has not received general acceptance nor has this maxim come to occupy
the status of rule of law. It is merely a rule of caution. All that it amounts
to is that in such cases testimony may be disregarded, and not that it must be
discarded. The doctrine merely involves the question of weight of evidence
which a court may apply in a given set of circumstances, but it is not what may
be called 'a mandatory rule of evidence', Ram
Udgar Singh v. State of Bihar, (2004) 10 SCC 443 (447).
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