Relevancy of Facts under Indian Evidence Act

TABLE OF CONTENTS
Introduction
Requirements for Relevancy
Relevant Sections of the Act
Judgments on Relevancy of Facts under Indian Evidence Act
Conclusion

Introduction

The term fact has been defined under Section 3 of the Indian Evidence Act. Facts are either tangible realities, states of affairs, or relationships between things that can be observed and sensed by the human senses. Alternatively, they encompass any mental state or condition of consciousness that an individual is aware of.

“Relevancy of Facts” serves as a mechanism for discerning pertinent facts that are pertinent to a given case. Not everything holds significance within a legal context; only specific occurrences, whether concrete or conceptual, that are presented to the court through proper legal procedures, possess relevance.

Each incident inherently constitutes a fact and is composed of various individual details. The framework of evidentiary law was established to substantiate these ‘facts’.

Requirements for Relevancy

  • Unverified information should not be accepted for matters requiring proof.
  • Admissibility depends on whether legal principles or policies exclude such information.
  • Verified and probative evidence should be allowed unless explicitly prohibited.
  • Relevancy acts as the connecting link between a statement for proof and the statement needing to be proven.

Understanding Relevancy of Facts in comparison to Admissibility

Relevancy encompasses a broader scope, signifying that facts connect in a way that makes the existence or non-existence of other facts likely according to common human behavior or events. It derives from logic and human experience and determines the connection between facts, acting as the cause. The court may exercise discretion in assessing relevance.

In contrast, admissibility occurs when facts receive legal recognition as relevant under the Indian Evidence Act. It is narrower in scope and is grounded in specific legal provisions. Admissibility discerns between relevant facts that can be admitted as evidence and those that cannot, serving as the effect. The court has limited discretion in determining admissibility.

The question regarding relevancy has been enunciated in Section 5 to Section 55 of the Indian Evidence Act, 1872 whereas, the question of admissibility is provided in Section 56 of the Indian Evidence Act, 1872.

While all admissible evidence is relevant, not all relevant evidence is admissible in a court of law, as only legally relevant facts can be admitted. This distinction is crucial in the practice of evidence law.

ASPECT Relevance Admissibility
SCOPE Broader Narrower
BASIS Logic and human experience Legal provisions
DETERMINES Connection between facts Which facts can be admitted
ROLE Cause Effect
DISCRETION Court may exercise discretion Court has limited discretion
APPLICATION Sections 5 to 55 of the Indian Evidence Act Section 56 of the Indian Evidence Act
RELATION TO EACH OTHER All admissible evidence is relevant Not all relevant evidence is admissible
GROUNDING In logic and human experience In legal provisions

Relevant Sections of the Act

The Indian Evidence Act does not provide a specific definition for the terms “relevancy” or “relevant fact.” Instead, it essentially illustrates the circumstances under which one fact becomes pertinent to another.

Section 3 of the Indian Evidence Act, 1872, defines “Evidence.” It encompasses statements or documents presented before the court by witnesses regarding matters under inquiry.This Code does not make a clear distinction between admissibility and relevancy.

Section 5 of the Indian Evidence Act, 1872 stipulates that evidence is permissible in any legal case to establish the presence or absence of facts in contention, as well as other facts that are deemed relevant as outlined subsequently, and not beyond. The determination of relevance is grounded in principles of logic and likelihood, guiding the admissibility of evidence.

Section 6 of the same Act states that facts not directly under consideration but intertwined with a relevant fact to the extent of constituting a unified event are also pertinent, whether they occurred concurrently or at distinct times and places. This encompasses both actions and omissions, which need not be continuous but should contribute to the broader context of the concerned transaction. The legal concept of “Res Gestae” is outlined in Section 6 of the Act, denoting an action or event.

Sections 6 to 16 encompass facts closely connected to the issue, including causality, motive, and direct relevance. Confessions fall within the purview of Sections 17 to 31 of the Act, while Sections 40 to 44 pertain to the relevance of court judgments.

Sections 45 to 51 address when third-party opinions can be considered relevant. The Act also outlines situations where a person’s character is relevant, as covered in Sections 52 to 55.

To summarise, Sections 5 to 55 of the Indian Evidence Act outline various methods through which the correlation between different facts can establish the concept of relevant facts. The relevance of a fact to another is determined based on the connections detailed in these sections.

If such a connection is absent, the fact is considered irrelevant. However, a court has the authority to exclude pertinent evidence if the potential risks outweigh the probative value of the evidence. Such risks may encompass unfair prejudice, confusion of issues, misleading the jury, undue delays, or the unnecessary introduction of cumulative evidence.

Judgments on Relevancy of Facts 

Lakshmandas Chaganlal Bhatia v. State

The court established several relevant factors: Facts serve to elucidate or present the truth in question or a pertinent fact; they can support or challenge an inference proposed by a fact in issue or a relevant fact; they establish the character of a person or thing whose identity matters; they pinpoint the time and place of occurrence of a fact in issue or a significant event; and they reveal the relationship between parties involved in the execution of a fact in issue or a relevant fact.

Section 9 of the Evidence Act, 1872, outlines specific facts that hold relevance. Another provision, Section 11, addresses circumstances where ordinarily insignificant facts become significant if they contradict relevant truths or make the presence or absence of a pertinent fact more likely or improbable. 

Sainudeen v. State of Kerala                                                                    

This case deems facts valuable when they contribute to supporting, disproving, elucidating, or presenting crucial truths. For instance, consider a scenario where an individual goes into hiding shortly after being accused of a crime; this fact becomes pertinent as it is influenced by the circumstances surrounding the case. In this case, the identification of the accused through his voice was considered relevant and significant under this section.

Conclusion

Over the course of many years, evidence has gained increasing significance in shaping case outcomes. The substantial authority held by administrative figures in determining the admissibility of evidence is considerable and necessitates regulation.

The current body of evidence law may not be well-suited to the demands of the contemporary era, necessitating reforms to improve the efficiency and effectiveness of the legal system. It is crucial to establish a distinct boundary between the discretionary powers held by individual judges and the authority of the judicial collective. This demarcation is essential because unchecked empowerment of individual judges can potentially result in the misuse of their authority and power.

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