Tirupati Balaji Minerals v. Municipal Council

Shreya ShreeCase Summary

Presentation of computer-generated bills as evidence despite objections during a trial

Tirupati Balaji Minerals v. Municipal Council
2024:CGHC:43930
In the High Court of Chhattisgarh
WP(227) 563/2022
Before Justice D.K. Tiwari
Decided on November 12, 2024

Relevancy of the case: Presentation of computer-generated bills as evidence despite objections during a trial

Statutes and Provisions Involved

  • The Indian Evidence Act, 1872 (Section 65A, 65B)

Relevant Facts of the Case

  • The First Additional District Judge, Bilaspur, disallowed admission of evidence produced by the petitioner in the form of computer-generated copies of bills in which WAT had also been collected during the time of recording of evidence.
  • Aggrieved by the District Judge’s order, the petitioner has approached the High Court.

Prominent Arguments by the Counsels

  • The petitioner’s counsel argued that:
    • The Supreme Court, in Bipin Shantilal Panchal v. State of Gujarat (2001), framed the rule that trial courts must do away with the practice of disallowing evidence at the trial, since this deprived the appellate courts of valuable evidence, leading to a lot of orders of retrial. The Supreme Court further ordered that the trial court should record all the evidence produced before it and mention those being considered for judgment, along with pieces of evidence not being considered for judgment.
    • Relying on this judgment, the counsel prayed before the High Court to allow the use of computer-generated bills as evidence.
  • The respondent’s counsel relied on the Supreme Court’s decision in Arjun Panditrao Khotkar v. Kailsash Kushanrao Gorantyal (2020). In this case, the Supreme Court stated that certification of an electronic record is a precondition for the court to consider the evidence.

Opinion of the Bench

  • The Supreme Court judgment in Bipin Shantilal Panchal (2001) is applicable in this case, since the exclusion of documents after allowing an objection regarding the relevancy of evidence deprived the appellate courts of the benefit of that evidence.

Final Decision

  • The court allowed the presentation of bills as evidence despite objection.