1.In the case of State of Maharashtra v. Prafulla B.

Desai (2003), the relevant provision under the

Relevant Section under BSA, 2023:

 Section 63 of BSA, 2023 (which corresponds to Section 3 of the Indian Evidence Act, 1872)
defines evidence to include electronic records.

 The ruling in Prafulla Desai’s case aligns with this, as it allowed video conferencing as a
legitimate mode of recording evidence, treating it as valid electronic evidence.

Thus, the principle established in the case is now codified under Section 63 of the Bhartiya Sakshya
Sanhita, 2023, reinforcing the acceptance of electronic and digital evidence in Indian courts.

2. SANTOS KUMAR SINGH V STATE THE CBI (SEC 3)

 Priyadarshini Mattoo, a law student, was harassed and stalked by Santosh Kumar Singh, a
fellow student and son of a senior police officer. Despite multiple complaints and warnings,
Singh continued his advances. On January 23, 1996, Mattoo was found raped and murdered
in her residence. Singh was the prime suspect due to his prior behavior and evidence linking
him to the crime scene.

Relevance to Bhartiya Sakshya Sanhita (BSA), 2023:

The case's reliance on DNA evidence aligns with Section 63 of the BSA, 2023, which recognizes
electronic and scientific evidence. The acceptance of DNA reports in this case underscores the
judiciary's acknowledgment of scientific methods in establishing guilt.

3. Ram Bihari Yadav v. State of Bihar (1998) (ORAL EVIDENCE SEC3)

 The case involved evidentiary value and procedural fairness in criminal trials.

 The appellant, Ram Bihari Yadav, was convicted based on eyewitness testimonies and
documentary evidence.

 The appellant challenged the conviction, arguing that some evidence was inadmissible, and
the trial was unfair.

Judgment:

 The Supreme Court upheld the conviction, stating that minor procedural lapses do not
vitiate a trial if the overall evidence supports guilt beyond reasonable doubt.

 The Court emphasized the importance of appreciating evidence holistically rather than
dismissing a case on technicalities.

 It reinforced that substantial justice should not be defeated by procedural irregularities,

 It also resonates with Section 63 (previously Section 3 of the Indian Evidence Act, 1872),
recognizing electronic and documentary evidence.

 The ruling supports the principle of weighing evidence as a whole, rather than dismissing a
case due to minor procedural defects.
4. Bishwanath Prasad v. Dwarka Prasad Case Summary

Facts:

 The case involved a dispute over a patent.

 The appellant, Bishwanath Prasad, challenged the validity of a patent granted to Dwarka
Prasad.

 The primary contention was that the patented invention lacked novelty and was not an
innovative step.

 Under BSA, 2023, this case is relevant to Sections 61 & 63, which deal with oral and
documentary evidence.

5. CBI v. V.C. Shukla & Anr. (1998) Case Summary

 The case was related to the Jain Hawala Scam, where politicians and bureaucrats were
allegedly involved in receiving illegal funds.

 The CBI charged V.C. Shukla and others under the Prevention of Corruption Act, 1988 and
Indian Penal Code (IPC).

 The main evidence was diary entries and loose sheets containing names and amounts,
which were allegedly records of payments.

 Under Section 34 of BSA, 2023 (previously Section 34 of the Indian Evidence Act, 1872),
books of account can be used as evidence only if maintained regularly.

 The ruling reinforces that loose papers and informal records cannot be treated as credible
evidence in court.

 The case highlights the importance of documentary evidence standards, which are further
strengthened in BSA.

6. Sudhakar v. State of Maharashtra (2000)(SEC 6)

o Ms. Rakhi, a 20-year-old teacher at Zila Parishad Primary School in Banegaon,

o Following the incident, she delayed reporting the crime due to societal pressures
and fear of stigma. citeturn0search4

o On July 20, 1994, she filed a complaint detailing the assault.

o Unable to bear the humiliation, Ms. Rakhi committed suicide on December 22,
1994

o The appellants challenged the conviction, arguing that the statement was
inadmissible as it was recorded months before her death and did not pertain
directly to the cause of death. citeturn0search4
 o The Supreme Court upheld the conviction, stating that Section 32(1) allows for the
admissibility of statements made by a deceased person concerning the cause of
their death or any circumstances leading to it.

Relevance to Bhartiya Sakshya Sanhita (BSA), 2023:

Under Section 6 of the BSA, 2023statements made by a person as to the cause of their death or
concerning the circumstances resulting in their death are deemed relevant and admissible.

Statements detailing events leading up to a person's death, even if recorded well before the death,
can be admissible if they have a direct or proximate connection to the cause of death.

7.LAXMAN V STATE OF MAHARASHTRA

The case involved the admissibility and validity of a dying declaration.

 The Supreme Court upheld the conviction and ruled that a dying declaration does not
require a doctor's certification if the statement is found to be voluntary and truthful.

 The Court reaffirmed that a dying declaration, if free from suspicion and recorded properly,
can be the sole basis for conviction.

 Section 6 of BSA, 2023 (previously Section 32(1) of the Indian Evidence Act, 1872) deals
with dying declarations.

 A dying declaration is admissible evidence, even without a doctor’s certification, if it is

8.MUKESH AND ANR V STATE

 This case pertains to the 2012 Delhi Gang Rape Case, where a 23-year-old woman (known
as Nirbhaya) was brutally gang-raped and assaulted on December 16, 2012, in a moving
bus.

 The victim and her male friend were later thrown out of the bus in a severely injured state.

 Nirbhaya succumbed to her injuries on December 29, 2012, in a hospital in Singapore.

 The police arrested six accused, including one juvenile and one accused who later died in
jail.

 The case was fast-tracked due to public outrage.

 Section 6 of BSA, 2023was applied, as Nirbhaya's statements before her death were
considered a dying declaration and formed key evidence.

 Section 63 of BSA, 2023 (scientific evidence) was used, as DNA evidence, CCTV footage,
and forensic reports played a crucial role in proving the guilt of the accused.