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Relation Between Relevancy And Admissibility

Relevancy and admissibility are related but distinct legal concepts. While all admissible evidence must be relevant, not all relevant evidence is admissible. Relevancy is the logical connection between facts based on common sense, human experience, and practical knowledge and determined without strict legal rules. It involves facts connected in ways outlined in the Evidence Act (Sections 5 to 55) and facts that the judge deems relevant under Section 136.

Admissibility, however, is a legal process where the court decides if the relevant evidence can be received based on specific legal rules. For evidence to be admissible, it must be appropriate and meet additional legal criteria under the Evidence Act. While relevancy is broader and determined by logic, admissibility is narrower and governed by law. Thus, relevancy is often called "logical relevancy," and admissibility is called "legal relevancy."

Relevant
In legal terms, "relevant" refers to the connection between facts that influence the determination of the facts in a case. A fact is considered relevant if it has a reasonable connection to another fact and helps prove or disprove the existence of that fact in the past, present, or future. In evidence law, a relevant fact must have some probative value to the case.

"Facts in issue" are the main points of dispute in legal proceedings. These facts are central to the case and must be determined to decide legal rights, liabilities, or disabilities. In civil cases, facts in issue are framed from the parties' pleadings. In contrast, in criminal cases, they arise from the allegations made by the prosecution and denied by the defense. Identifying the facts in the issue is crucial because evidence must be relevant to these facts to be considered by the court.

According to Section 2 of the Indian Evidence Act, one fact is relevant to another if they are connected in ways specified in Sections 5 to 55. Sir James Stephen describes relevancy as the connection between cause and effect, meaning that relevant facts help prove or disprove the facts in issue, either directly or inferentially, by affecting their probability. Thus, a fact is relevant if it has a certain degree of probative force, influencing the likelihood of the fact in the issue being true or false.

Relevant Facts And Evidence
"Relevant facts" are connected to the facts in the issue, which help prove or disprove them. These facts are not directly disputed but serve as valuable inferences that can impact the court's understanding of the facts. However, even if a fact is relevant, it may not always be admissible. For instance, communications between spouses, professional communications, or those made in an official capacity may be relevant but are not admissible under certain legal protections.

The key distinction between "facts in issue" and "relevant facts" is their role in a case. Facts in the issue are the main points of contention that need to be resolved by the court. In contrast, relevant facts are connected to these issues and help infer their truth or falsity. Sections 5 to 55 of the Indian Evidence Act provide an exhaustive list of relevant facts; only those under these sections are treated as relevant.

"Relevant evidence" is evidence that has probative value, meaning it makes a fact in issue more or less likely to be true. However, relevant evidence may be excluded if it is prejudicial, confusing, or wastes time. Generally, relevant evidence is admissible, while irrelevant evidence is always inadmissible.

Relevancy
Relevancy in evidence law refers to the logical connection between a fact presented as evidence and the issue to be proved in a case. It measures how much a fact tends to prove or disprove a fact in an issue. Sections 5 to 55 of the Evidence Act outline relevant facts, but not all relevant facts are admissible. Admissibility depends on legal standards, which may exclude relevant facts due to potential prejudice, confusion, or other legal reasons, such as hearsay, privileged communications, or police confessions.

For instance, in a murder case where A is tried for killing B with a club, the facts in the issue would include A's beating of B, B's death caused by the beating, and A's intention to kill B. A relevant fact might be that A and B were quarreling before the murder, which helps establish A's intent. However, even if a fact is logically relevant, it may be ruled inadmissible based on legal restrictions or court considerations.

In conclusion, relevancy is based on logic, while admissibility depends on legal criteria under the Evidence Act. Therefore, not all relevant facts are admissible in court.

Legal Evidence And Logical Evidence
Logical relevancy refers to the reasonable connection between facts based on their causal relationship, meaning one fact makes the existence or non-existence of another more probable. However, logical relevancy alone does not guarantee that a fact will be admitted as evidence in court. Legal relevancy, defined in Sections 5 to 55 of the Evidence Act, specifies which logically relevant facts are permissible in legal proceedings. For example, a confession made to a police officer might be logically relevant but is legally inadmissible under Section 25.

While all legally relevant facts are also logically relevant, not all logically relevant facts are legally permissible. Public policy considerations, such as fairness and the need for efficiency, can exclude specific logically relevant evidence like hearsay. Thus, relevancy is a broader concept, while admissibility is a narrower subset based on legal standards. Legal relevancy ensures that only logically pertinent and legally reliable facts are admitted in court.

Admissibility
Admissibility refers to the court's acceptance of relevant evidence under the law. While relevance is based on logic and common sense, admissibility depends on legal standards. Under Section 141 of the BSA, the judge can determine whether evidence is admissible. Before allowing a witness to give evidence, the judge can ask the party how the evidence will be relevant to the case. The evidence is admitted if the judge is satisfied that it fits under Sections 6 to 55 of the Act. Thus, relevancy is considered first, followed by admissibility.

The court ensures that only evidence confined to relevant facts is admitted to avoid straying beyond the trial's scope. Even if logically relevant, evidence may be excluded due to legal limitations, such as gossip, which is generally not admissible despite being logically relevant. For example, a witness who only heard about a crime cannot testify, as oral evidence must be direct (Section 60). Similarly, confessions obtained through inducement, threats, or made to police officers below the rank of inspector (Sections 24, 25, and 26) are also inadmissible, even if they appear logically relevant.

While relevancy is determined by logic and common sense, admissibility is based on legal standards and the judge's discretion to ensure fairness and proper limits during a trial.

Rule of admissibility and relevancy
Chapter 11 of Part 1 of the Indian Evidence Act, 1872 (Sections 5 to 55) outlines the relevancy of facts, dealing with various concepts such as res gestae, hearsay evidence, character evidence, similar facts, and confessions. Relevancy refers to the relationship between facts, whereas admissibility is a matter of law and depends upon the provisions of the Evidence Act and other enacted legislation. The court has discretionary power, as granted by Section 136, to order the admission or rejection of evidence. Thus, only relevant facts can be taken into consideration during a trial.

Relevancy is defined by logic and common sense, but admissibility is a matter of legal rules. For example, while a fact may be logically relevant, it must meet the specific legal criteria under the Act to be admissible. This distinction was emphasized in cases like Sris Chandra Nandy v. Rokhalananda and Public Prosecutor v. Dato Seri Anwar bin Phrahim, where the courts ruled that procedural rules govern admissibility, not substantive facts. Hearsay and opinion evidence, while logically relevant, are exceptions and typically inadmissible.

Section 9 specifies that facts necessary to explain or introduce a fact in an issue, support or rebut an inference, establish identity, or fix the time and place of an event are considered relevant. Section 11, however, allows specific facts to become relevant if they are inconsistent with a pertinent fact or make a relevant fact more or less probable. However, these facts must strongly connect to the fact in question, as ruled in Bibi Khaver v. Bibi Rukha and R. v. Prabhudas. There are also limitations under Section 11, controlled by Sections 17 to 39, which means depositions of deceased persons must meet the criteria under Sections 32 and 33 to be admissible.
In conclusion, relevancy deals with the connection between facts. Admissibility is usually based on legal standards and the discretion of the court, which means that facts are admitted to the court only if they meet the requirements mentioned under the Evidence Act.

Conclusion
The concepts of relevancy and admissibility are very closely related but distinct in evidence law. Relevancy or logical relevancy refers to the rational and practical connection between facts, assessed based on common sense and experience. It is a more general concept, covering facts pertinent to the case as per Sections 5 to 55 of the Evidence Act. However, not all relevant facts are automatically admissible in court.

The test of admissibility is very narrow and is tested objectively against the legal assessment given to it by the courts. In contrast, relevancy also bridges the gap between fact-establishment points to establish a connection with fact through admissible and relevant evidence. Relevant and sufficiently complying with the strictly strict conditions of the Evidence Act alone helps in making evidence admissible.

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