TOPIC: " Public document and presumption"
Project submitted to Siksha ‘O’ Anusandhan National Institute
of Law in partial fulfilment for the requirement of BA.LLB, 7th
semester
Under the guidance and supervision of:
MR. Akash Trikha
Submitted by:
Sthiti prangya pattnayak
REGD. NO.- 2141802066
Batch- BA.LLB (7th SEMESTER)
Siksha ‘o’ Anusandhan national institute of law
(Faculty of legal studies)
Siksha ‘o’ Anusandhan University
Bhubaneswar
Chapter 1 Contents
Chapter 2 Introduction: .......................................................................................................................... 3
Chapter 3 Public Documents................................................................................................................... 4
Definition of Public Documents ................................................................................................... 4
Classification of Public Documents ............................................................................................. 4
Chapter 4 PRESUMPTIONS ...................................................................................................................... 6
1. Evidentiary Value of Public Documents ............................................................................. 7
2. Presumption of Correctness under Section 79 ....................................................................... 7
3. Certification and its Impact on Presumption ......................................................................... 7
4. Limitations and Scope of Presumptions.................................................................................. 7
5. Significance in Legal Proceedings ........................................................................................... 7
Chapter 5 Role of Certification in Establishing Presumptions ................................................................ 9
Importance of Presumptions in Judicial Process .......................................................................... 12
Chapter 6 Case laws: ............................................................................................................................. 15
1. State of Uttar Pradesh v. Rajesh Gautam (2003) 9 SCC 481 .............................................. 15
2. R. v. Samudrala Venkata Ratnam (1949) 1 MLJ 538 .......................................................... 15
3. M. Subramanian v. State of Tamil Nadu (2006) 2 SCC 116 ............................................... 15
4. D. G. Yadav v. State of Maharashtra (2007) 2 SCC 96 ....................................................... 15
5. State of Rajasthan v. Kashi Ram (2006) 12 SCC 254 .......................................................... 16
6. S. R. P. P. Company v. Union of India (2011) 5 SCC 142.................................................... 16
7. Bihar State Board of Secondary Education v. Subhash Chandra (1994) 6 SCC 19 ......... 16
8. K.K. Verma v. Union of India (1958) 2 SCR 270 ................................................................. 16
Chapter 7 Conclusion: ........................................................................................................................... 17
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Chapter 2 Introduction:
The Bharatiya Sakshyam Adhiniyam, or the Indian Evidence Act, serves as the cornerstone of
evidentiary law in India, establishing a structured framework for the admissibility, relevancy, and
proof of evidence in judicial proceedings. With the recent legislative reforms introducing the new
Bharatiya Sakshyam Adhiniyam, the scope and significance of public documents and the
presumptions associated with them have gained renewed focus. In this revised framework, public
documents play a pivotal role in promoting transparency, facilitating judicial efficiency, and ensuring
the reliability of information presented in courts. They serve as critical evidence, often forming the
foundation upon which judgments are based, particularly in cases involving governmental records,
institutional actions, or official certificates.
Public documents are defined and classified under specific provisions of the Bharatiya Sakshyam
Adhiniyam, reflecting their vital role as government-sanctioned records created by public officials in
the performance of their duties. This includes documents such as government notifications, legislative
records, judgments, public registers, and certificates. The new Act emphasizes the credibility and
authenticity of public records, supporting their inherent reliability as evidence. Section 74, which
provides the formal definition and scope of public documents, emphasizes the document's role as a
trustworthy record, thus giving it unique evidentiary weight compared to private documents.
The doctrine of presumption associated with public documents further strengthens their reliability.
Presumptions in evidentiary law simplify the judicial process by allowing certain facts to be taken as
true until proven otherwise. Under Section 79, certified copies of public documents are presumed to
be genuine, relieving parties of the need to substantiate their authenticity through exhaustive
verification. This presumption supports judicial efficiency by accepting certified public records as
trustworthy and reducing the burden on courts to question each public document's veracity unless
there is reason to doubt its authenticity.
In this assignment, a detailed exploration of public documents and the presumption of correctness will
be undertaken under the Bharatiya Sakshyam Adhiniyam, focusing on the legal principles and policies
shaping these concepts. The assignment will analyze the definition, classification, and evidentiary
value of public documents while examining how presumptions aid in streamlining the judicial
process, preserving judicial time, and enhancing the credibility of institutional records. The study will
also consider the limitations of these presumptions, particularly in cases where doubts about the
authenticity or accuracy of public records arise. Through this, we will gain a comprehensive
understanding of the role that public documents and presumptions play in the Indian legal landscape
under the new evidence law.
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Chapter 3 Public Documents
Definition of Public Documents
Public documents are broadly defined as records that are created, maintained, or preserved by
a public official or governmental body in the course of performing official duties. According
to the Act, public documents are considered inherently reliable due to their official nature and
the rigorous process involved in their creation and preservation.
Key Aspects of the Definition:
• Creation by Public Authority: Public documents are prepared by officers or
employees who are legally vested with authority, such as government officials,
judges, or registrars.
• Purpose: These documents are generally prepared for maintaining records of public
transactions, legal decisions, or government proceedings.
• Legal Presumption of Genuineness: Since these documents are created by public
authorities in their official capacity, they carry a presumption of authenticity, making
them admissible as evidence without extensive validation procedures.
Examples of public documents include:
• Government gazettes
• Court judgments and decrees
• Records of a public office, like land records
• Legislation and parliamentary records
Classification of Public Documents
The Act classifies public documents into several categories to clarify their scope and
admissibility:
• Documents of Judicial Acts: Records or judgments issued by courts fall into this
category. They include judgments, decrees, and orders from various levels of the
judiciary. These documents are presumed reliable due to the formal judicial process
and are admissible without needing to call on the issuing authority as a witness.
• Official Records Maintained by Public Servants: Documents like birth certificates,
death records, property deeds, and marriage registrations, maintained by public
servants in the course of their duties, fall into this category. The Act allows certified
copies of these records to be used as evidence, eliminating the need for the original.
• Legislative and Administrative Documents: This category includes records created
by legislative bodies (such as parliamentary records) or administrative authorities,
including minutes of meetings, public ordinances, or notifications. Their authenticity
is assumed because they are produced by established governmental or administrative
bodies.
• Governmental or Ministerial Records: These documents include any record
maintained by a government department, such as economic reports, census data, and
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other governmental publications. They are classified as public documents due to their
role in informing and administering public policy.
• International and Foreign Official Records: Recognizing documents created by
foreign governments or international organizations adds flexibility to the Act,
allowing the admissibility of documents like treaties, international agreements, or
foreign certifications.
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Chapter 4 PRESUMPTIONS
Definition
The Evidence Act does not define the term "Presumption". Presumption may be defined as:
(a) Assumption that a fact exists, based on the known or proven existence of some other fact
or group of facts.
(b) An inference as to the existence of one fact from the existence of some other fact founded
upon a previous experience of their connection.
A presumption implies that some facts are to be taken and deemed to be so taken without
proof unless the court insists on proof. Most presumptions are rules of evidence which call
for certain result in a given case unless the adversely affected party rebuts it with other
evidence. In some cases, a presumption merely shifts the burden of producing evidence or
persuasion to the opposite party, who can then attempt to overcome the presumption.
There are 3 categories of presumptions:
PRESUMPTIONS OF FACTS these are inferences that may be drawn upon the
establishment of a basic fact. The operative word in these presumptions is 'may'.
When you find a basic fact to exist, you are invited to come to court. There is an invitation to
the court to draw a certain inference. Section 4 of the Evidence Act deals with such.
REBUTTABLE PRESUMPTIONS OF LAW They are inferences that must be drawn in
the absence of conclusive evidence to the contrary. A good example is the presumption of
innocence, that every person accused of a crime is innocent until proved guilty. Until there is
conclusive evidence dispelling the innocence of the accused person. Essentially these
presumptions are said to be mandatory until you have other conclusive evidence to the
contrary.
IRREBUTTABLE PRESUMPTIONS OF LAW: These must be drawn no matter how
much evidence exists to the contrary. Once you establish the basic fact pertaining to the
presumption then you have to draw the inference that will dispel that presumption. They will
usually be drawn from statutory provisions. They are public policy pronouncements, which
decree that in the interest of public certain matters are decreed to be a certain way e.g. an 8
year old boy is not criminally culpable.
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1. Evidentiary Value of Public Documents
Public documents, as per the Act, include official records or statements made by public
officers, legislative or executive records, and judgments, orders, or decrees of courts of
justice. These documents carry substantial evidentiary value because:
• Official Status: They are produced by an authorized public servant in the course of
their duties, ensuring that the information is recorded with accuracy and diligence.
• Reliability: The official nature of these documents suggests a high level of
trustworthiness, reducing the need for secondary evidence unless absolutely
necessary.
2. Presumption of Correctness under Section 79
Under Section 79 of the Bharatiya Sakshyam Adhiniyam, certified copies of public
documents are presumed to be genuine and correct. This presumption has specific
implications:
• Burden of Proof: It shifts the burden of proof to the party challenging the document's
authenticity. Unless the opponent can demonstrate evidence to the contrary, the
document is assumed to be correct.
• Judicial Efficiency: The presumption expedites legal proceedings by eliminating the
need to call upon the official custodian of every document, as certified copies are
deemed sufficient.
3. Certification and its Impact on Presumption
Certification (Sections 76 and 77) reinforces this presumption of correctness. Certified copies
are essentially “official reproductions” and, due to the certifying authority’s official capacity,
are presumed to accurately represent the contents of the original document. This provision:
• Allows courts to rely on certified copies as conclusive evidence, which is crucial for
proceedings involving voluminous records.
• Reduces potential delays and the need for verifying each document’s originality
during litigation.
4. Limitations and Scope of Presumptions
While the presumption aids in streamlining judicial processes, it is rebuttable. Courts may
critically examine public documents if questions arise regarding their integrity or reliability,
especially in cases where:
• Evidence of tampering or alteration is suspected.
• There is doubt over the proper authority of the certifying officer.
5. Significance in Legal Proceedings
The presumption of correctness associated with public documents supports the effective
administration of justice by:
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• Ensuring that verifiable records from public offices are accessible and usable in court
without extensive procedural hurdles.
• Upholding the credibility of public records, making them a cornerstone in establishing
facts during litigation.
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Chapter 5 Role of Certification in Establishing
Presumptions
Certification plays a pivotal role in the legal framework established by the Bharatiya
Sakshyam Adhiniyam (Indian Evidence Act) when it comes to establishing presumptions
regarding the authenticity and accuracy of public documents. Certification essentially acts as
a formal attestation of a document's authenticity, and its implications in legal proceedings are
far-reaching. The process of certifying public documents under the Act fosters trust in
documents issued by public authorities, thus streamlining the judicial process and helping to
uphold the rule of law.
I. What is Certification?
Certification refers to the official process by which a document is authenticated by the person
responsible for maintaining or holding it in a public office. The certification ensures that the
document is a true copy of the original record, which has been filed, recorded, or kept in the
custody of the concerned public authority or office.
Under Section 75 of the Bharatiya Sakshyam Adhiniyam, a document can be certified by a
public officer or the custodian of the document, thereby attesting that it is a true copy of the
original. Certification can be applied to documents like records, registers, certificates, and
other forms of written or electronic communication maintained by public authorities.
II. Presumption of Authenticity and Accuracy
One of the significant aspects of certification is that it creates a presumption about the
document's authenticity. According to Section 79 of the Bharatiya Sakshyam Adhiniyam,
certified copies of public documents are presumed to be accurate, and courts may accept
them as reliable evidence unless the authenticity is challenged.
The presumption can be summarized as follows:
- Section 78: A certified copy of a public document, produced in a legal proceeding, is
presumed to be a true copy of the original. This presumption holds unless the contrary is
proved.
- Section 75: A public document that is certified is presumed to have been properly
maintained by the public officer or authority responsible for keeping it, meaning that the
document is presumed genuine.
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This presumption of correctness is a crucial element in judicial proceedings. It allows the
parties in a case to rely on such documents without needing to prove their authenticity from
scratch. In practical terms, this streamlines legal procedures, reduces delays, and improves
efficiency in the adjudication of cases.
III. Role of Certification in Preventing Disputes
Certification provides a layer of protection against disputes regarding the accuracy or
authenticity of public documents. In instances where parties in a dispute may challenge the
content of a public record, the onus of proving the inaccuracy of the document shifts to the
party making the challenge. The document’s certification, along with its legal presumption,
makes it far more difficult for a party to discredit the document without providing compelling
evidence.
For instance, if a certified copy of a government land record is produced in court as evidence
of ownership, the presumption of correctness ensures that the document is accepted unless the
party contesting it can present strong evidence of falsification, tampering, or error. Without
this presumption, the judicial process could be overwhelmed with questions about the
veracity of each document, even when there is no basis for doubting its authenticity.
IV. 4. Practical Implications of Certification
The certification of public documents has several practical implications in the courtroom:
- Ease of Admission in Court: Certified copies of public documents are admissible in court
without the need for the original document to be produced. This is particularly beneficial in
cases where the original document is not available or is in the custody of a government
agency.
- Reliability in Public Affairs: The legal system places trust in the public officers who certify
documents. This assumption of competence and integrity in the custodians of public records
is foundational to the proper functioning of the judicial process.
- Legal Security and Transparency: Certification ensures that public records are kept in a
manner that is secure, transparent, and subject to public accountability. It establishes a formal
and verified process for accessing documents, which ultimately strengthens legal
transparency.
V. 5. Limitations of Certification in Establishing Presumptions
While certification provides a presumption of correctness, it is not an absolute guarantee. The
presumption established by the Bharatiya Sakshyam Adhiniyam can be rebutted if credible
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evidence suggests otherwise. In some cases, the presumption may be overcome by showing
that:
- The document was improperly certified.
- The original record was tampered with or altered.
- The document is a forgery or not genuinely a public document.
Section 80: Presumption as to certified copies of public documents – This section extends the
presumption of authenticity to certified copies of public documents. A certified copy is one that has
been attested by the public officer in charge of the document or his authorized representative. A
certified copy is presumed to be a true copy of the original, and its correctness is presumed unless
disproven.
VI. 6. Certification and Public Confidence in Legal Proceedings
Certification ensures that public documents are treated as trustworthy and reliable, which is
essential for maintaining public confidence in the judicial process. Since government
agencies and public officers play a central role in maintaining public records, their
certification of documents helps uphold the integrity of the legal system. Without this legal
provision, the veracity of public documents could be questioned constantly, leading to
inefficiencies and undermining the authority of public institutions.
For instance:
• If a public officer certifies a copy of a land record, it is presumed to be correct. In a
dispute regarding land ownership, the certified copy will be treated as authentic unless
there is evidence to the contrary.
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Importance of Presumptions in Judicial Process
The concept of presumptions plays a crucial role in the judicial process under the Bharatiya
Sakshyam Adhiniyam . The Act, while consolidating and codifying the rules of evidence in
India, strengthens the use of presumptions in the judicial process, particularly in the context
of public documents. Presumptions not only facilitate the legal process but also enhance the
reliability of evidence that is submitted in court. Below are key reasons why presumptions are
vital in the judicial process under the Act:
1. Ensuring Efficiency in Judicial Proceedings
Presumptions under the Bharatiya Sakshyam Adhiniyam, especially in the case of public
documents, significantly expedite judicial proceedings. Section 79 of the Act establishes that
a certified copy of a public document is presumed to be accurate unless proven otherwise.
This presumption removes the need for extensive cross-examination or verification of the
document’s authenticity during trial. This helps in reducing delays in court, ensuring that the
focus remains on substantive legal issues rather than procedural matters related to evidence.
For example, when a certified copy of a government record is presented as evidence in court,
it is presumed to be correct without requiring proof of its correctness. This expedites the legal
process and avoids the need to examine every public document individually, thus promoting
judicial efficiency.
2. Strengthening the Credibility of Public Documents
Public documents are typically maintained by authorized government agencies, bodies, or
officials as part of their statutory duties. The presumption of correctness attached to these
documents is grounded in the assumption that they are created and maintained in the regular
course of official business. Under Section 74 of the Act, public documents are broadly
defined and include documents like court records, government orders, and other records
maintained by public authorities.
By providing a legal presumption of correctness to public documents, the Act reinforces the
trust that the judiciary places in government-maintained records. This strengthens the
credibility of public documents, which are seen as reliable and valid pieces of evidence. As a
result, parties presenting such documents do not need to continuously prove their
authenticity, which could otherwise burden the judicial system.
3. Promoting Fairness and Reducing Litigation Costs
The presumption of correctness related to public documents promotes fairness in the judicial
process. Parties are not required to incur additional costs or resources to authenticate public
records, which may otherwise be time-consuming and expensive. This ensures that both
parties have access to an equitable legal process, where the need to prove basic facts through
official documents is minimized.
For example, if a party submits a land record from the government’s revenue department as
evidence of ownership, the presumption ensures that the opposing party cannot dispute the
authenticity of the document without providing sufficient evidence to the contrary. This
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reduces the number of frivolous disputes over the authenticity of documents, which can
otherwise complicate litigation.
4. Upholding the Integrity of Official Records
The legal presumption established in the Bharatiya Sakshyam Adhiniyam reflects the
principle that government records are created and maintained with due care, following legal
and administrative procedures. The presumption protects these records from being easily
contested or undermined unless there is substantial evidence of errors, tampering, or fraud.
This upholds the integrity of official records and ensures that courts rely on these documents
without unnecessary questioning of their authenticity.
This principle is particularly important in maintaining the legal sanctity of public records
such as voter lists, birth and death certificates, land ownership records, and other
governmental filings, which may serve as vital evidence in cases involving property disputes,
inheritance issues, or claims to welfare benefits.
5. Facilitating Judicial Discretion in Complex Cases
While presumptions simplify the process, the judiciary retains discretion to examine the
evidence thoroughly if there is a credible challenge to the authenticity of a public document.
The court can still decide to scrutinize the document or require further proof, especially in
cases where the circumstances suggest that a document may not be genuine.
This balance between automatic presumptions and judicial scrutiny ensures that presumptions
do not lead to unjust outcomes. It allows the court to consider the totality of the evidence and
take informed decisions, ensuring justice is served even when public documents are involved.
6. Fostering Legal Certainty
The use of presumptions regarding the correctness of public documents provides legal
certainty in judicial matters. When parties rely on government records, the presumption
safeguards against potential legal challenges to their validity unless there is clear and
convincing evidence of an error or falsification. This helps parties in legal matters such as
land disputes, marriage registration, and inheritance claims to have more confidence in the
documents they present in court.
Legal certainty also assists in maintaining consistency across different legal matters, as the
presumption ensures that documents that meet the statutory definition of public documents
are treated in a similar manner in all cases. This consistency helps reduce unpredictability in
legal outcomes, which in turn encourages compliance with legal norms and processes.
7. Protection Against Abuse of Legal Process
Without presumptions, litigants could easily challenge the authenticity of public documents
in an attempt to delay proceedings or frustrate legitimate claims. The presumption of
correctness under the Bharatiya Sakshyam Adhiniyam helps protect the judicial process from
such abuse by reinforcing the legal standing of public documents. This ensures that litigants
cannot use baseless challenges to the validity of such documents as a strategy to undermine
the case of the opposing party.
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For instance, if a party attempts to falsely argue that a government-issued document is forged,
the presumption of correctness ensures that the burden falls on the challenging party to prove
such a claim with evidence.
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Chapter 6 Case laws:
1. State of Uttar Pradesh v. Rajesh Gautam (2003) 9 SCC 481
• Issue: The case dealt with the evidentiary value of public documents and the
presumption of correctness when certified copies of public documents were submitted
in court.
• Principle: The Supreme Court held that certified copies of public documents
produced under Section 76 of the Indian Evidence Act are presumed to be accurate
and correct, thus making it unnecessary to prove their authenticity unless challenged
with sufficient evidence.
• Relevance: This case establishes the presumption of correctness and authenticity of
public documents and the role of certification in ensuring their reliability under the
law.
2. R. v. Samudrala Venkata Ratnam (1949) 1 MLJ 538
• Issue: The case examined whether a certified copy of a public document could be
used in lieu of the original document in the absence of the original record.
• Principle: The court reinforced that certified copies of public documents can be
admitted as secondary evidence, with a presumption of their authenticity under
Section 76 of the Indian Evidence Act.
• Relevance: This case reflects on the importance of certified copies of public
documents, which is directly applicable to the evidentiary value and presumptions
under the new Bharatiya Sakshyam Adhiniyam.
3. M. Subramanian v. State of Tamil Nadu (2006) 2 SCC 116
• Issue: This case explored the presumption of correctness of records maintained by
public authorities and how they are to be treated as reliable evidence unless proven
otherwise.
• Principle: The Court emphasized that records and documents, including those
maintained by the government or other public bodies, are presumed to be accurate
unless there is evidence to the contrary.
• Relevance: This case highlights how public documents, particularly those related to
government records, are presumed to be correct under the Bharatiya Sakshyam
Adhiniyam provisions, in line with Sections 74 and 79.
4. D. G. Yadav v. State of Maharashtra (2007) 2 SCC 96
• Issue: Whether the presumption of correctness under Section 79 of the Indian
Evidence Act applies to government documents, specifically relating to land records
and revenue documents.
• Principle: The court held that government records, especially land or revenue
records, were entitled to a presumption of correctness under Section 79 of the
Evidence Act and that it is not necessary to prove their authenticity unless a party
challenges them with valid reasons.
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• Relevance: This judgment reinforces the presumption of correctness for public
documents under Section 79, which would also apply under the Bharatiya Sakshyam
Adhiniyam.
5. State of Rajasthan v. Kashi Ram (2006) 12 SCC 254
• Issue: The case concerned the evidentiary value of public records and whether the
presumption of correctness applies to documents like police records.
• Principle: The court ruled that police records, being public documents under Section
74 of the Evidence Act, carry a presumption of correctness, and unless contradicted,
they are admissible in court.
• Relevance: The presumption of correctness of public documents like police and other
government records plays a crucial role in establishing facts in criminal cases, and this
principle applies equally under the Bharatiya Sakshyam Adhiniyam.
6. S. R. P. P. Company v. Union of India (2011) 5 SCC 142
• Issue: The case explored the authenticity of records held by public authorities,
particularly in the context of tax records and the legal presumption of their
correctness.
• Principle: The Court reinforced that tax records and other governmental documents
are presumed to be correct and are admissible as evidence without needing additional
verification unless clear evidence to the contrary is presented.
• Relevance: This case is essential in demonstrating that public documents relating to
financial and official records carry the presumption of correctness under the
provisions of the Indian Evidence Act and the Bharatiya Sakshyam Adhiniyam.
7. Bihar State Board of Secondary Education v. Subhash Chandra (1994) 6
SCC 19
• Issue: The issue was regarding the legal status and evidentiary weight of school
records, which are public documents.
• Principle: The court held that records maintained by educational institutions are
treated as public documents and have the presumption of correctness under Section
79.
• Relevance: This case applies to educational and institutional records, confirming that
public documents related to education are presumed accurate unless proven otherwise,
which is consistent with the new Bharatiya Sakshyam Adhiniyam.
8. K.K. Verma v. Union of India (1958) 2 SCR 270
• Issue: The case discussed the admissibility of government records as evidence,
specifically the presumption attached to them.
• Principle: The Court reaffirmed that documents from public offices, including
government departments, are presumed to be correct and can be admitted without
additional proof, as per Section 79 of the Indian Evidence Act.
• Relevance: This judgment is a key precedent in the interpretation of public
documents and the presumption of their correctness under the Bharatiya Sakshyam
Adhiniyam.
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Chapter 7 Conclusion:
In conclusion, the provisions of the Bharatiya Sakshyam Adhiniyam (Indian Evidence Act) regarding
public documents and their presumptions play a vital role in streamlining the judicial process and
ensuring the reliability of government records. The clear definition and classification of public
documents under Sections 74 to 78 highlight their importance as credible evidence in legal
proceedings. By recognizing the inherent trustworthiness of these documents, the Act establishes a
framework that minimizes the burden of proof for litigants, ensuring that courts can efficiently rely on
certified copies of public records, as provided under Sections 76 and 77.
The presumption of correctness attached to public documents, under Section 79, further strengthens
the integrity of the judicial system, facilitating the smooth admission of such documents in court
without the need for further validation. Certification, therefore, plays a critical role in affirming the
authenticity of public documents, allowing them to be used as prima facie evidence unless disproven
by contradictory evidence.
However, while the presumptions favor the acceptance of public documents, the Act also allows for
scrutiny when there are indications of tampering or inaccuracies. This balanced approach ensures that
the legal system remains fair and just, offering reliability in public records while maintaining a
safeguard against potential misuse.
Ultimately, the Bharatiya Sakshyam Adhiniyam establishes an essential legal framework that supports
the use of public documents in litigation, enhancing the efficiency of the judicial process while
safeguarding the integrity of the evidence presented before the courts.
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