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Video Conference Technology in Indian Judiciary System

One of the most crucial stages of a trial is the recording of the evidence. Indian courts and tribunals prefer the physical method of recording witness testimony, but as we all know, there are many cases in which parties or witnesses were unable to physically appear before the court due to a variety of reasons, such as the illness of the parties, an overseas witness or party, physically disabled persons, etc. All of these were obstacles for the parties and delayed their justice.

To avoid these, there is a way to electronically record evidence and Indian courts have ruled that video conferencing is a legitimate way to present record evidence in a number of rulings. However, at the time of the COVID-19 pandemic, everyone carried their work online, driving the need for video conference technology in courts and tribunals to serve justice to parties without the delay.

At the midpoint of the COVID-19 pandemic, the Supreme Court highlighted the importance of video conference technology in such situations and also issued guidelines, ordering the high court to frame the guidelines regarding the video conference in the judicial system.

This paper examines the position of Indian law regarding the use of video conferences for recording evidence, witness examination, general procedural guidelines, and Telangana guidelines of recording evidence through video conference. It also provides an overview of the evolution and circumstances of implementing video conferences in the judiciary system, and how the courts accepted the method of video conferences in recording evidence.

The implementation of video conferences in the judiciary system is not new to India; it is used in many other nations, including the USA, Australia, Canada, and others. The Indian judicial system has been accepting video conferences in numerous civil and criminal cases for the last two decades.

The government and Supreme Court have expanded the use of video conference in courts across the nation after the courts and tribunals expressed the value of the technology in their rulings and awards. This opened the door for amendments to the laws governing video conferencing in the judicial process.

However the courts have emphasized the value of video conferences in hearings during the COVID 19 pandemic situations. These circumstances outlined why the Indian judiciary had a higher need for video conferencing technology. So, integrating technology into the Indian judicial system won't replace regular court procedures; rather, it will serve as an alternative. It also helps to lower barriers to parties, such as cost and distance and improves citizens' access to justice.

At present video conference is one of the most advantageous methods used in the Indian judiciary system that has enabled the audio-visual communication between the parties who are at different locations and also the use of video conference recording evidence helps to reduce the burden on courts, cost and time for witnesses who are required to travel for court proceedings.

This paper provides an overview of video conferences in trials, historical background of video conference in proceedings and provides detailed aspects of legal recognition of video conference and Telangana guidelines about video conference in judicial proceedings. It also examines how the various courts accepted the method of video conference in a number of rulings.

A Brief Historical Background of Video Conference in Indian Judiciary System:
In the Indian judiciary system there is no particular legislation regarding the usage of video conference in judicial proceedings but through the various judgements of Supreme Court and high court recognized the need of video conference in judiciary proceedings and discussed the circumstances of implementation of video conference in trials. However these judgements only paved the way to certain amendments for video conference proceedings.

In 2002, Saleem bar association v. union of India [i] was the first case which allowed the use of video conference in civil cases during the stage of recording the evidence under CPC. A year later in the State of Maharashtra v. Dr. Praful Desai [ii] judgement the Supreme Court interpreted the order 18 rule 4(3) states the examination of witness, in this court or commissioner can record the evidence either in writing or mechanically in the presence of judge or commissioner.

While interpreting this provision the Supreme Court held that the word mechanically includes the audio- visual apparatus. Apart from recording evidence through video conference, the high court allowed a petition which filed for cross-examining the witness through video conference who was located in the United States and also several safeguards of audio-visual examination of witness, filing of an affidavit, administration of oath.

However, the use of video conferences in trials is not limited to civil cases. In the state of Maharashtra v. Dr. Praful Desai the apex court held that the presence of the accused does not only means that physical appearance which mandated the presence of accused under section 273 of code of criminal procedure and the court allowed the video conference at the stage of recording evidence in a criminal trial.

In criminal cases judges often use the video conference in remands, bail application, examination of witnesses and in the sensitive matters. Subsequently, the section 164(1) of Cr.P.C. was amended in 2009 and according to the amended provision that any confession or statement made under this subsection may also be recorded by audio- video electronic means in the presence of the advocate of the accused person in the offence.

In 2017, Supreme Court in Santhini v. Vijay Venkatesh [iii] case permitted the video conferencing in matrimonial cases instead of transferring the suit. If the parties are located outside the jurisdiction of court, then it is an alternative to the transfer petition. Now, in different parts of the country courts are using the technology for recording the evidence and cross examination of witnesses.

Introducing the video conference mechanism in trails helps to avoid delay and travel expenses. In the wake of covid 19 pandemic situation 2020, Supreme Court directed to start the using of video conference and ordered high courts to make the proper rules and guidelines of using video conference in judicial proceedings.

Video Conference:
Video conferencing is an interactive form of communication that enables two or more people to communicate face-to-face via voice or video at the same time without physically being present together.

Conduct of Judicial Proceedings through Video Conference [iv]:
All stages of the legal process can use video conferences, and all the rules that apply in a physical courtroom also apply in a virtual one. These rules and guidelines allow the court to use video conferences for hearing arguments, recording evidence, and at both the trial stage and the appellate stage.

Circumstances of implementing the video conference in a suit:
Video conference can be implemented in the following circumstances:

Urgent Matters:
Physical appearance is an exception in instances where a matter comes as an emergency and parties have to present an application to the court with justifications for using a video conference. When a court chooses to use a video conference to conduct the proceedings, the court must take precautions in enforcing the law and must safeguard the parties' interests and rights.

For instance, in a civil case whenever a party tries to alienate the suit's schedule property, just as in criminal cases involving rape victims, bail applications, and matrimonial cases involving restraining orders or child possession. In these conditions, the situation qualifies as an emergency, and an expeditious decision must be made to prevent damage to the parties. So whenever there is urgency in a suit parties can avail the video conference facility by filing an application to the court.

Overseas or Outstation of Parties:
When parties or witnesses live in another country and are unable to physically attend court, they have the option of appearing before the court via video conference, in which the case will continue without delay.

Crimes against Women:
A woman who has been the victim of a heinous crime may not be able or willing to appear in court. In order to safeguard the victim from the offender, she is permitted to use video conferencing or in-camera proceedings which exist to make her statements. Examples: POCSO and rape cases.

By application of parties or suo moto of court:
​​Court hearings may be held via video conference either on its own or at the request of parties. The consent of both parties should be required whenever parties choose to request virtual proceedings from the appropriate judge. After hearing arguments from both parties, the judge decides whether to grant or reject the application with reasons.

Sickness of Parties:
When a required party or witness is ill and unable to appear in person before the court, the judge may authorize the order for such a party to appear, present evidence, or undergo questioning via video conferencing.

In addition to the aforementioned scenarios, the court may permit video conferences between the parties during a suit depending on the facts and conditions.

Recording of Evidence and Cross Examination of Parties via Video Conference:
The concept of recording evidence and conducting cross-examination of witnesses via video conference is not new to the courts, and from time to time the Supreme Court has been framing guidelines regarding its use in proceedings. During the Covid 19 pandemic, physical hearings were not possible, which resulted in a delay in the administration of justice to the parties. In these circumstances the best option to regular court proceedings is the conduct of proceedings via video conference.

Therefore, as part of its authority under Article 142 of the Indian Constitution, the Supreme Court issued an order to high courts directing them to establish rules and safeguards regarding the use of video conferences in legal proceedings for the administration of justice without delay and allowed the courts to conduct trials through video conference.

Even with the absence of a specific statute governing the use of video conferences in trials, numerous landmark decisions have established rules and safeguards that govern the implementation of video conferences in the judiciary system. These decisions have also paved the way for amendments pertaining to the video conference. However, it is evident that video conferencing can be used to record evidence and conduct witness cross-examination in the proceedings; this was upheld in a number of Supreme Court and high court rulings.

Laws and Guidelines Which Are Talks about the Use of Video Conference for Recording Evidence and Cross Examination:
The court either by the application of parties or on its own motion directs the parties or witnesses to appear before the court through video conference. The relevant statutory provisions applicable to judicial proceedings including provisions of CPC (order16 & 18), CRPC, Contempt of court, Indian evidence act 1872 and information technology act 2000 shall apply to the proceedings conducted by video conference.

Evidence Act 1872[v]:
Unless there is a mandatory requirement in the law or an agreement between the parties that requires them to physically appear before the court, evidence may be recorded via video conference. The court will reject the application whenever it believes that doing so will jeopardize the interests of the parties and the rule of law. In addition to these, every court should abide by the CPC, Crpc, Indian Evidence Act of 1872, and any current SC and HC guidelines before approving a request to use videoconferencing in proceedings.

Evidence encompasses both oral and documentary evidence, according to section 3 of the Indian Evidence Act of 1872. Documentary evidence in this context refers to all document materials including electronic records, submitted to the court for inspection. It is divided into two categories: primary evidence and secondary evidence.

Primary evidence (section 62) - the documents itself (originals) produced before the court for inspection.

Secondary evidence (section 63) - secondary evidence is nothing but all the copies made from or compared from the originals and also any certified copies issued by authorised representatives consistent with law.

Sections 65(A) and 65(B) of the Evidence Act of 1872, which speak about any evidence recorded in electronic form coming under electronic evidence and being treated as documentary evidence, were inserted in 2000, marking a significant amendment to the law. It implies that all electronic data, including hard discs, SD cards, memory cards, pictures, music, and video, falls under the category of electronic evidence, which is regarded as the main source of proof. If any copies are made from those SD cards or hard discs, those copies are regarded as secondary evidence.

By analysing the provisions and amendments it is clear that recording the evidence through video conference is permissible and admissible in the court of law.

Code of Civil Procedure [vi]:
By amending the code of civil process in 2002, order 18 rule 4(3) was inserted, it has laid the foundation for implementing the use of electronic recordings made during video conferences as evidence in accordance with section 65(B) of the Indian Evidence Act of 1872. Significantly, rule 4(3) of order 18 allows the recording of evidence orally or mechanically in the presence of the judge or commissioner, as the case may be and also the code of civil procedure's Order 18 Rule 13 acknowledges the value of mechanically documenting evidence.

Code of Criminal Procedure [vii]:
Sections 275(1) and 164(1) of the Code of Criminal Procedure were introduced by the 2009 amendment.

This states as follows:
Section 275(1) talks about the evidence of witnesses under this subsection that can be recorded by audio-visual form in the presence of the advocate of the person accused of an offence

Section 164(1) of code of criminal procedure was amended in 2009, provided that any confession or statement made under sub section may also be recorded by audio- video electronic means in the presence of the advocate of the person accused of an offence.

Here as per section 273 of CrPC evidence must be taken in the presence of the accused but here presence of accused doesn't mean actual physical presence, the evidence may also be taken in the presence of advocate of accused. The Supreme Court also permitted recording of evidence of witnesses staying abroad through video conference- this was held in the case of state of Maharashtra v. Dr. Praful Desai and Anr. As a result, all the statutory provisions from section 277 to 283 of Cr.P.C. applicable to proceedings conducted via video conference same as applies to normal court proceedings.

Telangana Rules for Recording Evidence and Examination of Witness via Video Conference [viii]:

In chapter III of Telangana rules for video conference discuss about the procedure for video conference.
  1. Any party in the case or witness may apply to the concerned court for a recording of the evidence or examination of the parties through video conference. Except in cases where it is impossible, such as urgent applications, a request for video conferencing should be addressed with another party to the proceedings initially. The court will make a decision in response to such a request once it has determined that the application was not submitted with the purpose to impede proceedings or obstruct a fair trial also the courts have the power to decide the video conference timetable while granting such requests.( rule 6 of Telangana Guidelines for video conferencing for courts )
  2. The witness who's going to be questioned via video conferencing receives a summons that specifies the time and location of the relevant remote point and instructs the witness to appear with identity proof. Regarding the summons and absence of witnesses, the CPC and CrPC's existing regulations will apply. ( rule 7 of Telangana guidelines for video conferencing for courts)
  3. Examination of parties or witnesses - Any individual, who is being questioned, including a witness, will be questioned via video conference. In order to prove their identity, they must either present an identity document or, in the absence of identity proof, an affidavit attested by one of the relevant authorities. A copy of identity proof or affidavit will be given to the opposite party. ( rule 8 of Telangana guidelines for video conferencing for courts)
  4. The person who is going to be examined will be questioned during the court's normal working hours. The coordinator at the court point will administer the oath. ( rule 8.2)
  5. The relied-upon documents must be sent to the applicant before the witnesses are questioned, and if a witness is summoned to give evidence in relation to a specific document, the summons must be served to the witness along with a properly certified copy of the document (rule 8.5). The court will take notice of any objections the person raised at the time of the examination.( rule 8.7 )
  6. The subject of the examination will read the deposition and sign it once the examination is completed. The signed transcript's hard copy will be delivered to the appropriate judge by courier or registered speed post.
  7. The examination must continue uninterrupted and without being extended unnecessarily. Depending on the circumstances, the court or commissioner will decide whether to grant an adjournment.
  8. The provision of CPC, CrPC, Indian Evidence Act 1872, and contempt of court act and information technology will apply while examining a person through video conferencing. ( rule 3 (iii) )
  9. When a person is physically unable to travel to the court or a remote location or when their presence cannot be secured without undue delay or cost, the court permits video conferencing to take place from the location where they are. ( rule 8.15 )
  10. It must be noted in the order sheet whenever any procedures are conducted via video conference.
  11. Before making any decision or issuing an order, the chairman/secretary of the district legal service authority, the taluk legal service committee, or members of the Lok Adalats must examine the person if the proceedings were connected to legal aid clinics or Lok Adalats.
  12. A copy of the award or order and a record of the proceedings will be sent to the remote location. Such awards or orders shall have the same effect as if they were issued by a regular Lok Adalat or Jail Adalat.

Video Conference in Matrimonial Cases:
The family courts in India have been using video conference in all marital disputes and the use of video conferences in divorce cases before family courts has been approved in a number of cases handled by the Supreme Court, but it has been prohibited in transfer petition cases.

The various landmark judgments given by the Supreme Court explained the use of video conference in matrimonial matters, in the Krishna Veni Nigam V. Harish Nigam 2017[ix] case the Supreme Court granted the petition for a transfer and explained the conditions under which it would be granted, along with an alternative.

However, the Supreme Court was of the opinion that considering such a transfer petition would delay the administration of justice, so it directed all high courts to issue administrative orders to maintain and regulate the use of video conferences in specific circumstances. The courts should have certain safeguards in place for matrimonial cases involving parties who reside outside of the court jurisdiction, such as the availability of video conferencing, access to legal counsel, and a contact email or phone number. Doing so helps to prevent the denial of justice to either party.

However, the Supreme Court in Santhini v. Vijay Venkatesh case overruled the Krishna Veni Nigam V. Harish Nigam. In Santhini case, Supreme Court held that the compliance of section 11 of family court act 1984 proceedings of matrimonial disputes may have to be conducted in camera. The application for conducting proceedings via video conferencing is only permitted after the parties have been unable to reach a settlement through mediation or conciliation.

At that point, the parties must file the application jointly or both parties must agree to file it before the relevant family court, which the court may do at its discretion. Aside from this, the Supreme Court clearly stated that video conferences were not permitted in transfer petitions unless they were jointly submitted by both parties.

At the same time the Supreme Court ordered all family courts to use video conferencing to conduct trials in the case of Anjali Brahmavar Chaun v. Navin Chaun[x] because physical court proceedings at the time of pandemic COVID 19 were not feasible and could cause delays for the parties. In order to avoid these delays, the court used video conference technology in such situations.

Although video conferencing is an old method in many nations, the pandemic in our country emphasised its significance in the judicial system. As a result, our judiciary system became more flexible and in various judgements the court permitted the use of video conference in proceedings.

General Guidelines for the Conduct of Judicial Proceedings through Video Conference [xi]:
When a lockdown was imposed in India due to COVID 19 everything was done online, and even the courts admitted using video conferences to conduct proceedings because the litigants shouldn't have to wait for justice to be served.

As a result, the Supreme Court of India ordered all high courts to establish guidelines governing the use of video conferences for conducting proceedings in accordance with Article 142 of the Indian Constitution. The primary reason for establishing such rules is to prevent litigants and attorneys from physically appearing before the court when it is necessary to maintain social distance. It also ensures that litigants can obtain justice without delay.

However, there is no specific law that explains the use of video conferences in judicial proceedings; rather, the Supreme Court and high court established general guidelines and rules in a number of decisions made during the COVID 19 pandemic situation.

The following is a summary of the guidelines issued on how to conduct proceedings via video conference:
  1. The courtroom or other locations where the court conducts its proceedings are referred to as "court points" in the High Court Rules. The location of the person and/or witness who will be cross-examined via video conference will be the "remote point," which may also be the location of an official (commissioner) designated by the court to record the evidence and statements.
  2. Person to be examined is the one whose deposition or statement must be recorded, or whose presence must be recorded during certain procedures.
  3. As per the possibility, video conference proceedings shall be treated and conducted as typical court proceedings, and the established protocols and courtesies shall be observed precisely as if they were to be observed in person in a court. In such video conferences, all statutory provisions that apply to such procedures, including those of the Information Technology Act of 2000 and the Indian Evidence Act of 1872, shall apply equally.
  4. A video conference facility can be used in many cases, such as remands, civil and criminal trials, bail applications, etc., where a witness is located interstate, intrastate, or abroad, excluding the procedures mentioned under section 164 of the CrPC.
  5. The guidelines applicable to the Court will apply to a local commissioner appointed by the court to record the evidence.

Challenges in Recording Evidence through Video Conferencing [xii]:
  1. Absence of clearly laid down procedures for video conferencing
  2. Lack of infrastructure
  3. Lack of fluency with the technology
  4. Evaluation of witnesses

Current Scenario of Use of Video Conference in Indian Judiciary:
However, as of September 2021, the COVID-19 pandemic had greatly increased the use of video conferencing in legal proceedings in India. Both regular and urgent hearings in the Indian judiciary, including those in the Supreme Court and different high courts, have been conducted via video conferencing.

Video conferencing has made it possible for the judicial system to continue operating while upholding social distance protocol and lowering the risk of virus transmission. Access to justice has been improved, especially for those who live in remote or underserved areas, due to the use of video conferencing, which has also made it possible for attorneys and litigants to take part in proceedings online.

Concerns have been voiced, though, about the use of video conference in the Indian judicial system. Some people have voiced concern over the lack of adequate technological infrastructure, which could cause delays or disruptions in proceedings. Concerns have also been raised regarding the fairness and confidentiality of the video conferencing-based trials.

Overall, the Indian judiciary's use of video conferencing has been a crucial response to the challenges posed by the epidemic. It has improved access to justice and supported the judiciary's ongoing activities. To ensure that the use of video conferencing in legal processes is fair, effective, and efficient, it is necessary to address the difficulties and concerns expressed.

Judicial Precedents:
  1. State of Maharashtra v. Dr. Praful Desai and Anr 2003 4 SCC 601[xiii]

    Facts of the case:
    Dr. Ernest Greenberg of Sloan Kettering Memorial Hospital in New York, USA, examined the complainant's wife, who had terminal cancer, and concluded that she should only be given medication. They later consulted with the respondent, a surgeon with 40 years of experience, and despite being aware of Dr. Greenerg's view; the respondent proposed removing the uterus surgically.

    Dr. Mhukerjee operated on the complainant's wife, when the stomach was opened during the complainant's wife's surgery, ascetic fluids oozed out of the belly. Dr. Mukherjee then contacted the respondent and proposed closing the stomach. After the surgery, the complainant's wife passed away and endured physical torture and mental suffering.

    The complainant brought a lawsuit against the respondent, who claimed that the complainant's wife is not his patient. However, the respondent's fees were shown on hospital bills in Mumbai.

    • Can evidence be reliably and effectively recorded through video conferencing in a criminal trial?
    The court held that the video conferencing recording evidence satisfied the requirements of section 273 of the criminal process code. With the development of science and technology, it was now possible to install video conferencing equipment within the courtroom, where testimony could be recorded by the magistrate or taken down while he dictated in front of the court.

    The provisions of Section 273 of the Criminal Procedure Code would thus be entirely satisfied if that was done. It was further stated that the court could consider issuing a commission to record evidence by way of video conferencing in cases where the attendance of a witness cannot be procured without an amount of delay, expense, or inconvenience.

    The Supreme Court further added that cross-examination could be conducted in front of the court's presiding officer or could be recorded by a commissioner appointed by the court after the documents were filed in court along with the affidavit and the court had determined their relevance and admissibility. The court also permitted video conferencing to be used to record the testimony of witnesses who were abroad.
  2. Twentieth Century Fox Film Corp. Vs. NRI Film Production Associates (P) Ltd 2003 AIR 2003 Kant 148, 2003 (5) KarLJ 98[xiv]
    The words "Witness in attendance" are to be understood as a person being present and it need not be physical presence, according to the High Court of Karnataka's ruling in a matrimonial matter. Order 18 Rule 4 CPC once contemplated hearing suit, examination of witnesses, and recording of evidence by the commissioner. As a result, recording evidence via an audio or video link is acceptable as long as it complies with the rules for in-person testimony. The two ends would be in real-time communication. The image would also be captured, along with everything else. The Court would then have access to see this. Additionally, there would be recording on both ends and this reduces the danger of losing recorded data.

    The Judge further noted that Order 18, Rule 3(4) (3) allows for the mechanical or written recording of evidence in front of a judge.
  3. Amitabh Bagchi Vs Ena Bagchi 2004 AIR 2005 Cal 11, (2004) 3 CALLT 263 HC[xv]
    In this case the court held that physical presence does not always imply the actual physical presence in court. It is important to keep in mind that, as a result of an amendment and addition to Sections 65A and 65B of the Evidence Act, a special provision regarding electronic record evidence and the admissibility of electronic records was introduced as of October 17, 2000. The court decided that "presence" does not always imply actual physical presence in court.
  4. Bodala Murali Krishna v. Smt. Bodala Prathima on 11 October, 2006 AIR 2007 AP 43[xvi]
    In this case, the petitioner is the respondent's husband; they were married in 1977 and blessed with a child. The petitioner is a resident of the USA, and wants to use video conferencing to record his evidence during the trial. The application was denied by the trial judge, and a CRP was filed.

    It was held that video conferencing for the purpose of recording proof was legal as long as the necessary precautions were taken.

    It is the petitioner's responsibility to set up the required technology for video conferencing, and to satisfy the trial court as to the equipment's accuracy and the witness' identity: The petitioner will be required to show the passport and any of its pages upon request, and he must follow any instructions the court issues while the case is being recorded.

  • There is no specific law governing the use of video conferences in the judicial system, despite the fact that the Supreme Court and high court have established rules, guidelines, and protections regarding their use in proceedings in their judgements. Therefore, there is a need for special legislation to allow for the use of video conferences in legal proceedings. Statutory recognition will also help to clarify all concerns about when, where, and how to use a video conference in a legal proceeding as well as the rights, obligations, and process for doing so.
  • Additionally, there is a need to strengthen privacy protection for parties, e-filings, case document management, and evidence management, all of which are crucial for the success of the virtual court system. With the help of this virtual court system, delays and costs are dropped significantly. In addition, it assists parties who are physically unable to appear in court due to a disability, residence outside of the court's jurisdiction, or illness and whose case may be dismissed for default or exparte decree in such cases. In these situations, the video conference will help in the dismissal of the lawsuit and there will be no delay in the administration of justice.
  • Video conference awareness schemes- will educate parties who are not familiar with legal procedures about the possibility of using a video conference facility rather than physically presenting in court when they are unable to attend in person.

The use of video conferencing in Indian courts has significantly increased in response to the COVID-19 pandemic to ensure that the legal system continues to operate without endangering the health and safety of those involved. A number of high courts, including the Supreme Court of India, have given directives and orders regarding the use of video conferencing for remote hearings and trials.

It has been acknowledged as a valuable tool that has helped to improve access to justice for many people, particularly those in remote or underserved areas, despite some difficulties and concerns raised about its use in the Indian judiciary, such as connectivity, security, and issues with fairness in conducting trials.

Overall, the Indian judiciary's use of video conferencing has been a necessary response to the evolving conditions brought on by the pandemic, and its ongoing use may have the potential to enhance the effectiveness, accessibility, and cost-effectiveness of the legal system in the future.

  • [i]AIR 2003 SC 189
  • [ii]2003 1 SCC 49, para
  • [iii]2018 1 SCC 1
  • [iv] Paper 4 video conferencing in Indian courts: a pathway to the justice platform; daksh
  • [v]Section 62, 63, 65(a) and 65(b) of Indian evidence act 1872
  • [vi]Order 18 rule 4 and 13 of code of civil procedure 1908
  • [vii]Section 164(1), 273 and 275(1) of code of criminal procedure 1973
  • [viii]Chapter 3, rule 3, 6, 7, 8 and 15 of Telangana Guidelines for video conferencing for courts
  • [ix]2017 4 SCC 150
  • [x]2021 SCC online SC 38
  • Recording evidence by video conferencing. [Internet]. [cited7 August 2020]Available from:
  • Dr. Prafulll desai v. state of maharastra
  • Twentieth Century Fox Film Corp. Vs. NRI Film Production Associates (P) Ltd 2003 AIR 2003 Kant 148, 2003 (5) KarLJ 98
  • Amitabh Bagchi vs Ena Bagchi on 16 February, 2004
  • Bodala Murali Krishna v. Smt. Bodala Prathima on 11 October, 2006 AIR 2007 AP 43
Written By: Syam Priyanka Badri, College Name: ICFAI Law School

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