“GALFAR ENGINEER AND CONTRACTING (INDIA) Pvt. Ltd. Vs.

STATE OF
UTTARAKHAND AIR 2014 Utr 69”

SUBMITTED BY:

Tanushka Shukla B.A. LL.B.(2169)

SUBMITTED TO:

Dr. Meeta Mohini,

Assistant Professor of Law of Evidence,

CHANAKYA NATIONAL LAW UNIVERSITY

MITHAPUR, PATNA (800001)

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 DECLARATION

I hereby declare that the project entitled “GALFAR ENGINEER AND CONTRACTING
(INDIA) Pvt. Ltd. Vs. STATE OF UTTARAKHAND AIR 2014 Utr 69 ” submitted by me at
CHANAKYA NATIONAL LAW UNIVERSITY is a record of bona fide project work carried out
by me under the guidance of our mentor Dr. Meeta Mohini . I further declare that the work
reported in this project has not been submitted and will not be submitted, either in part or in full,
for the award of any other degree or diploma in the university or in any other university.

TANUSHKA SHUKLA

ROLL NO- 2169

B.A.L.L.B.(Hons.)

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 ACKNOWLEDGEMENT

It is a fact that any research work prepared, compiled or formulated in isolation is inexplicable to
an extent . This research work, although prepared by me, is a culmination of efforts of a lot of
people who remained in veil, who gave their intense support and helped me in the completion of
this project.

Firstly, I am very grateful to, my subject teacher Dr. Meeta Mohini, without the kind support and
help of whom the completion of this project was a herculean task for me. I would like to thank
her for her valuable suggestions towards the making of this project.

I am highly indebted to my parents and friends for their kind co-operation and encouragement
which helped me in completion of this project. I am also thankful to the library staff of my
college which assisted me in acquiring the sources necessary for the compilation of my project.

Last but not the least; I would like to thank the Almighty who kept me mentally strong and in
good health to concentrate on my project and to complete it in time.

I thank all of them!

TANUSHKA SHUKLA

ROLL NO.-2169

B.A.LL.B. (Hons.)

SESSION: 2019-2024

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 Table of Contents

DECLARATION.........................................................................................................................................2
ACKNOWLEDGEMENT...........................................................................................................................3
INTRODUCTION...........................................................................................................................................5
SECTION 57, INDIAN EVIDENCE ACT,1872...................................................................................................8
JUDGEMENT ANALYSIS..............................................................................................................................12
CONCLUSION.............................................................................................................................................15
BIBLIOGRAPHY...........................................................................................................................................16

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 INTRODUCTION

The evidence Act which was passed by the British parliament in the year 1972 contains a set of
rules and regulation regarding admissibility of the evidences in the court of law. These
provisions speak about both procedure and rights, as it provides the procedure as to how to
proceed to the court or how to establish our claim before the court.  The Evidence Act, identified
as Act no. 1 of 1872, and called as the Indian Evidence Act, 1872, has eleven chapters and 167
sections, and came into force on 1st September 1872. Spread Over a period of approximately 140
years since its enactment, the Evidence Act has predominantly retained its original form except
certain amendments from time to time.

All the definitions, methods related to evidence and how the Law of evidence in consolidated is
included in this Act. It is applicable to all over India except the state of Jammu and Kashmir.
This act is not applicable to army law, naval law, disciplinary act and all the affidavits which are
presented in front of officers or the courts. This act is applicable to only the court proceedings.
The word ‘Evidence’ has been gotten from the Latin word ‘evidere’ which infers to show
particularly, to clarify to view or sight, to find unmistakably, to verify, to sure, to learn, to
demonstrate.

The facts of the case in question are as follows-

In this case several writ petitions were filled and all the writ petitions had identical question of
fact and law and hence all the writ petitions were taken up together for hearing and and were
disposed of by the common judgment. This case was decided on 18 August,2015.

The petitioners in this were involved in the business of mines and minerals. All the appeals
which were made before the court arose out of the orders passed by the single learned judges in a
matter relating to “transit fee” being charged by the state government. The power to make rules
and to regulate transit fee on forest produce is given to the state government under section 41 of
the Indian Forest Act,1927. Section 41 of the Indian Forest Act,1927 states that-

Power to make rules to regulate transit of forest produce.—

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(1) The control of all rivers and their banks as regards the floating of timber, as well as the
control of all timber and other forest-produce in transit by land or water, is vested in the 1[State
Government], and it may make rules to regulate the transit of all timber and other forest-produce.

(2) In particular and without prejudice to the generality of the foregoing power such rules may—

(a) prescribe the routes by which alone timber or other forest-produce may be imported, exported
or moved into, from or within 2[the State];

(b) prohibit the import or export or moving of such timber or other produce without a pass from
an officer duly authorised to issue the same, or otherwise than in accordance with the conditions
of such pass;

(c) provide for the issue, production and return of such passes and for the payment of fees
therefor;

(d) provide for the stoppage, reporting, examination and marking of timber or other forest-
produce in transit, in respect of which there is reason to believe that any money is payable to the
3[Government] on account of the price thereof, or on account of any duty, fee, royalty or charge
due thereon, or, to which it is desirable for the purposes of this Act to affix a mark;

(e) provide for the establishment and regulation of depots to which such timber or other produce
shall be taken by those in charge of it for examination, or for the payment of such money, or in
order that such marks may be affixed to it, and the conditions under which such timber or other
produce shall be brought to, stored at and removed from such depots;

(f) prohibit the closing up or obstructing of the channel or banks of any river used for the transit
of timber or other forest-produce, and the throwing of grass, brushwood, branches or leaves into
any such river or any act which may cause such river to be closed or obstructed;

(g) provide for the prevention or removal of any obstruction of the channel or banks of any such
river, and for recovering the cost of such prevention or removal from the person whose acts or
negligence necessitated the same;

(h) prohibit absolutely or subject to conditions, within specified local limits, the establishment of
saw-pits, the converting, cutting, burning, concealing or making of timber, the altering or
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effacing of any marks on the same, or the possession or carrying of marking hammers or other
implements used for marking timber;

(i) regulate the use of property marks for timber, and the registration of such marks; prescribe the
time for which such registration shall hold good; limit the number of such marks that may be
registered by any one person, and provide for the levy of fees for such registration.

(3) The 4[State Government] may direct that any rule made under this section shall not apply to
any specified class of timber or other forest-produce or to any specified local area1.

Under the aforesaid provision the state of Uttar Pradesh had framed the rules for charging transit
fee on forest produce. In the erstwhile state of Uttar Pradesh, these rules were known as “Uttar
Pradesh Transit of timber and other forest produce Rules,1978”. These rules were also applicable
in the state of Uttarakhand, since the creation of new state, but in the year 2012, the state of
Uttarakhand framed it’s own rules known as “Uttarakhand transit of Timber and Forest Produce
rules ,2012”

Rule 5 of Uttarakhand Transit of timber and forest produce rules,2012 is the charging provision
where a “transit fee” per lorry of timber and other forest produce were made Rs.50/- per tonne. It
is an admitted fact that prior to it , the prevailing rules prescribed transit fee was Rs.5/- per tonne.
In 2012 it was increased to Rs.50/- per tonne by the state government. It is also an admitted fact
that this increase was being done after a period of thirty four years.

The increase from Rs.5/- to Rs.50/- was these forest produce such as peat, surface soil, rock and
minerals(including Lime-stone, materite, mineral oils and all products of mines or quarries,
which are lying in the surface/river bed material in the forest area and is being carried away by
the stone crushers and other persons who deal in such materials.

A large number of writ petitions were filed before the court and a learned single judge of the
court, purely as an interim measure, reduced the transit fee from Rs.50/- to Rs.15/- per tonne.
The first interim order was passed on 07.08.2012 in WPMS No. 1420 of 2012 by the learned
single judge of the court, which was being followed in all succeeding writ petitions. This matter

1
The Indian Forest Act,1927,No.16,Acts of Parliament,1927(India)
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was ultimately heard and decided by a learned single judge of the court in WPMS No. 2859 of
2013 along with other connected petitions vide order dated 25.04.2014.

The learned single judge of the court was of the opinion that this increase per tonne has been
done after a long period of time, during which the expenditure of the state government has
increased and and it is not necessary for the state government to render accounts of each paisa,
which is incurred in making check-posts and bringing regulatory mechanism in order to manage
such posts. Some of the petitioners have challenged the order of the learned single judge of the
court dated 25.04.2015 .

However, even though there was a decision of this court holding that the increase in transit fee
per tonne is justified, where all such petitions were dismissed by the learned single judge of the
court. Moreover, before the court  the state government in it's counter affidavit as well as series
of affidavits filed later had always taken a stand that the increase is perfectly justifiable as it has
incurred expenses upto Rs.50/-.After this another learned judge of the court, who had earlier
reserved for judgment similar matters noticed both the earlier judgment of the court on similar
issue as well as the subsequent reduction of the transit fee by the state government,
understandably expressing surprise disposed the matter stating that nothing further need to be
done. The only issue before the learned judge was that as to whether the interim protection which
was granted to the petitioners whereby the petitioners who were only paying the transit fee
@Rs.15/- per tonne for the time period from 18.05.2012 to 18.12.2014 were required to pay the
increased amount of Rs.50/- per tonne or Rs. 15/- per tonne, during this period or not.

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 SECTION 57,IEA
The provision which was highlighted in the present case is related to Section 57 of the Indian
Evidence Act. The doctrine of judicial notice is an exception to the fundamental rule that matters
relevant to an action must be established be formal proof. As Professor McNaughton has noted,
"the one distinguished characteristic of judicial notice is the concept that the tribunal has the
right, in appropriate instances, to inform itself as to material matter be methods in addition to the
reception of formal evidence, and it is implicit that the information may be obtained by resort to
sources other than those adduced by the litigating parties. " In essence then judicial notice refers
to the acceptance of a matter of fact or law by the court, without the necessity of formal proof in
the form of evidence adduced by one of the parties.

Section 57 in The Indian Evidence Act, 1872

Facts of which Court must take judicial notice.—The Court shall take judicial notice of the
following facts:—1.  All laws in force in the territory of India;]

2. All public Acts passed or hereafter to be passed by Parliament 2[of the United Kingdom], and
all local and personal Acts directed by Parliament [of the United Kingdom] to be judicially
noticed;

3. Articles of War for [the Indian] Army, [Navy or Air Force]; [(4) The course of proceeding of
Parliament of the United Kingdom, of the Constituent Assembly of India, of Parliament and of
the legislatures established under any law for the time being in force in a Province or in the
State;]

5. The accession and the sign manual of the Sovereign for the time being of the United Kingdom
of Great Britain and Ireland;

6. All seals of which English Courts take judicial notice: the seals of all the [Courts in [India]],
and all Courts out of [India] established by the authority of [the Central Government or the
Crown Representative]: the seals of Courts of Admiralty and Maritime Jurisdiction and of
Notaries Public, and all seals which any person is authorized to use by [the Constitution or an
Act of Parliament of the United Kingdom or an] Act or Regulation having the force of law in
[India];

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7. The accession to office, names, titles, functions, and signatures of the persons filling for the
time being any public office in any State, if the fact of their appointment to such office is notified
in 10[any Official Gazette];

8. The existence, title and national flag of every State or Sovereign recognized by [the
Government of India];

9. The divisions of time, the geographical divisions of the world, and public festivals, fasts and
holidays notified in the Official Gazette;

10. The territories under the dominion of [the Government of India];

11. The commencement, continuance, and termination of hostilities between [the Government of

India] and any other State or body of persons;

12. The names of the members and officers of the Court and of their deputies and subordinate
officers and assistants, and also of all officers acting in execution of its process, and of all
advocates, attorneys, proctors, vakils, pleaders and other persons authorized by law to appear or
act before it;

13. The rule of the road, [on land or at sea]. In all these cases, and also on all matters of public
history, literature, science or art, the Court may resort for its aid to appropriate books or
documents of reference. If the Court is called upon by any person to take judicial notice of any
fact, it may refuse to do so, unless and until such person produces any such book or document as
it may consider necessary to enable it to do so.

Judicial notice is a rule in the law of evidence that allows a fact to be introduced into evidence if
the truth of that fact is so notorious or well known, or so authoritatively attested, that it cannot
reasonably be doubted. This is done upon the request of the party seeking to rely on the fact at
issue. Facts and materials admitted under judicial notice are accepted without being formally
introduced by a witness or other rule of evidence, and they are even admitted if one party wishes
to plead evidence to the contrary.

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Judicial notice is frequently used for the simplest, most obvious common sense facts, such as
which day of the week corresponded to a particular calendar date or the approximate time at
sunset.

CLAUSE 1- All laws in force in the territory of India

Under this clause the court should take judicial notice of all laws prevalent in India. The court
shall take judicial notice only of the Indian laws not the foreign laws.

CLAUSE 2- All public Acts passed or hereafter to be passed by Parliament 2[of the United
Kingdom], and all local and personal Acts directed by Parliament [of the United Kingdom]
to be judicially noticed

Under the clause the court shall take judicial notice of all Public Acts passed or to be passed by
the British Parliament and all local and Personal Act passed under the direction of the
Parliament. Judicial notice can be taken of the matter described the support of India’s white
paper. The court can take judicial notice of Acts of Parliament and interpret the schedule to the
Act in the light of English version. Even though India has become an independent country, we
are still bound to take judicial notice of all Acts of the British Parliament.2

CLAUSE (3): Articles of war for the Indian Army, Navy or Air Force:

The courts shall take judicial notice of articles of war for officers, solders etc. of the Indian
Army, Navy or Air Force.

CLAUSE (4): The course of proceeding of parliament of the United Kingdom etc.:

The courts are bound to take judicial notice of the course of proceeding of the British Parliament;
of the Constitutional Assembly of India; of Parliament and of the Legislatures in the Provinces or
in the state. Judicial notice can be taken of the matter described in the Government of India’s
white paper

CLAUSE (5): Accession of United Kingdom:

2
Diganth Raj Sehgal, Judicial Notice Under The evidence Act,1872, ipleaders (march 21,2020)
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Under the clause the court shall take judicial notice of the accession and the sign manual of the
sovereign for the time being of the United Kingdom of Great Britain 

CLAUSE (6): Seals of which English courts take judicial notice:

The courts are bound to take notice of all seals of which English Courts take judicial notice; the
seals of all the courts in India, and of all courts out of India established by the authority of the
Central Government or the Crown representative, the seals of court of Admiralty and maritime
jurisdiction and of Notaries Public, and all seals any person is authorized to use by the
Constitution or an Act of Parliament of the United Kingdom or an Act or Regulation having the
force of law in India.

CLAUSE (7): Judicial notice of Gazetted Officer:

The courts shall take judicial notice of the appointments, names, titles, functions and signatures
of public officers if the appointment is notified in Official Gazette.

CLAUSE (8): Recognition of title, national flags etc. of Foreign States:

The courts are bound to take judicial notice of existence of title and national flag of every state or
sovereign recognized by the Government of India

CLAUSE (9): Division of time etc.:

Under the clause the courts shall take judicial notice of the divisions of time, the geographical
divisions of the world, and public festivals, facts and holidays notified in Official Gazette.

CLAUSE (10): Territories of India:

The Courts shall take judicial notice of the territories under the dominion of Government of
India.

CLAUSE (11): Hostilities:

The courts shall take judicial note of the commencement, continuance and termination of
hostilities between Government of India and any other state or body of persons.

CLAUSE (12): Names of members and officers of courts:

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Under the clause the courts shall take judicial notice of the officers of the court, their subordinate
officers and assistants, of process servers, of advocates, attorneys, proctors, vakils and pleaders.

CLAUSE (13): Rules of the Land:

The courts shall take judicial notice of the rule of the road on land or at sea.

In addition, the Section 57 has also provided that on all matters of public history, literature,
science or art, the court may resort for its aid to appropriate books or documents of reference.
The Koran is considered to be a holy book by the followers of Islam. Judicial notice cannot be
taken of the facts stated in a news item being the nature of hearsay secondary of evidence, unless
proved by evidence aliened.

Section 57 has also provided that if the court is called upon by any person to take judicial notice
of facts referred in this section and on matters of public history etc., it may refuse to do so unless
and until such person produces any such book or document as source of information concerning
matters about which no evidence has been given in the case. It is only after being called upon to
produce gazette notification of appointment; the person concerned fails to produce the gazette
issue that the court can refuse to take judicial notice. Not having done so it was not open to the
court after close of trial not to take judicial notice.

Notorious facts:
Judicial notice is taken of various notorious facts for their universal notoriety. No court insists
upon formal proof by evidence of notorious facts of history, past or present. As a means of
establishing notorious and widely known facts judicial notice is superior to formal proof.

The court is required to take judicial notice of the proceedings of the two houses of Parliament
approving emergency and that the two proclamations of Emergency were in force by virtue of
the resolutions passed by the House of Parliament until they were duly revoked by the two
Proclamations which were used by the Vice- president acting as President of India in the year
1977.

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Judicial notice may be taken of the widespread mailise or illegal immigration. The court will see
the supply of essential commodities. It is customary in Central Government of India to serve rice
with “dal roti.” The court is also bound to take notice of subsequent events and mould relief.

JUDGEMENT ANALYSIS

In this case Mr. R.K. Raizada, Sr. Advocate along with Mr. Piyush Garg and Mr. B.S. Adhikari,
advocates appearing for the petitioners has vehemently argued that although transit fee can be
imposed under rule 5 of the rules read with section 41 of the Indian forest Act but transit fee
should not be excessive and while imposing the transit fee the state government must keep in
mind principle of equivalence and transit fee should be levied in order to meet out real expenses
for the purpose of regulating the transportation of forest produce. He further contends that it is
not appropriate for the state government to generate revenue in the name of transit fee so
collected. He further contends that if transit fee @rs.50 per ton is allowed to be recovered, then
the Forest department would earn approximately about Rs. 100crore per annum while the actual
expenses incurred to transport forest produce cannot be calculated more than rs 22 crore per
annum, therefore, enhanced transit fee is excessive, arbitrary, irrational and unjustified.
On the other hand Mr. Subhash upadhyay, learned chief standing counsel and Mr. R.C. Arya
learned standing counsel for the state of Uttarakhand, vehemently argued that there is no denial
to the fact that state government can impose transit fee which is regulatory in nature. If
competence to levy the transit fee in not under challenge, then ordinarily, this court, while
exercising jurisdiction under article 226 of the Constitution of India should not interfere in the
policy matter of the state government to find out as to the levied transit fee is excessive or
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unreasonable; to maintain the ecological balance the state government is required to protect the
forest, forest produce and wild life; since about 65% of the total area of state of Uttarakhand is
covered by the forest therefore, heavy expenses are being incurred by the state government to
protect, maintain and develop the forests.
Hon'ble apex court in the case of Vam Organic chemicals Ltd. V. State of U.P. 3 has held that
although in the case of regulatory fee like the licence fee existence of quid pro quo is not
necessary, however, fee imposed must not be, in the circumstances of the case, excessive.
The view taken by the Hon'ble Apex court in the case of Vam organic was relied upon by Three
judge bench in the case of A.P. Paper Mills Ltd. v. govt. Of A.P. and otrs. 4
Apex court in the case of State of U.P. and others v. Sitapur Packing Wood Suppliers and others 5
in paragraphs 7,8,9 and 10 has held as under,
"7. Having found that the constitutional competence in providing fees as set out in rule 5 is not
lacking, the High Court accepted challenge to the validity of levy on the ground that the fees is
not supported by the principle of quid pro quo. It held that no service is provided in lieu of the
fees to any person much less to the person from whom the transit fee is charged. In the view of
the High Court, reasonable relationship between the levy of the fee and the services rendered has
not been established."
"8. The distinction between tax and fee is well settled and need not to be restated herein. It is
clear from the afore-noticed provisions of the act and the ruled that the transitory fee is
regulatory in nature. The question of quid pro quo is necessary when a fees is compensatory. It is
well established that for every fee quid pro quo is not necessary. The transit fee being regulatory,
it is not necessary to establish the factum of rendering of service. Thus there is no question of a
levy of transit fee being invalidated on the ground that quid pro quo has not been established."
"9. In state of Tripura and Ors. v. Sudhir Ranjan Nath 6 almost similar question came up for
consideration in relation to state of Tripura. It was held that section 41 and 76 of the act vest total
control over the forest produce in the state government and empower it to regulate the transit of
all timber or other forest produce for which purpose the state government is also empowered to
make the rules. The decision of the High Court invalidating the levy of application fee in the said

3
(1997) 2 SCC 715 (India)
4
(2000) 8 SCC 167 (India)
5
(2002) 4 SCC 566 (India)
6
AIR 1997 SC 1168
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case on the ground that the state had not established that the services were rendered in lieu of the
said fees, was reverted by this Court holding that the fee was regulatory and not compensatory.
Reference may be made to the case of corporation of Calcutta and Anr. v. Liberty cinema 7
wherein it was held that the expression license fee does not necessarily mean a fee in lieu of
services and in case of regulatory fee no quid pro quo need to be established. "
"10. The transit fee under rule 5 is clearly regulatory and thus, it was not necessary for the state
to establish quid pro quo. The high court was in error in holding that transit fee is invalid in
absence of quid pro quo. As a consequence the penalty would also be valid. The penalty was
held to be invalid by the high court in view of it's conclusion about the invalidity of the transit
fee. The penalty, however, is not under challenge in these appeals as the state government after
the impugned judgment of the High Court realizing it's mistake amended the rules so as to bring
the provision of penalty in accord with the provisions of the act. "
As per the dictum of the apex court in the case of sitapur packaging transit fee under rule 5 is
clearly regulatory in nature and thus, it wasn't necessary for the state government to establish
quid pro quo, therefore this judgement has full application in the present case. This the judge in
this case state that 'I find that state government is competent to levy transit fee on the forest
products and the state government is not required to establish quid pro quo. I am conscious of the
fact that although this court while exercising the writ jurisdiction under Article 226 is not
supposed to behave like an expert body in accountancy however, this court, with the help of
material placed before this court, should make every attempt to find out as to whether transit fee
levied is excessive or arbitrary. Undisputedly in the year 1978 about 34-years ago, the transit fee
imposed was Rs. 5 per ton on the forest products and after 34 year in the year 2012 it was
enhanced to Rs. 50 per ton. As per section 57 of the Indian evidence Act this court must take
judicial notice of the fact that during 34 years costs of regulating, controlling, and management
of the transportation of the forest products must have increased manifold. Learned counsel for
the petitioner, while taking me to the counter -affidavit filed by the Principal secretary, forest and
environment, state of Uttarakhand has argued that to maintain the barriers established by the
forest department it is incurring expenses of about Rs. 21-22 crore per annum while total revenue
being generated by charging transit fee @rs 50 per ton is about Rs. 100 crore per annum,
therefore, transit fee is excessive and there is no rationality between transit fee and expenses

7
AIR 1965 SC 1107
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being incurred by the forest department.
Persual of the affidavit filed by the Principal secretary, forest and environment would reveal that
of course, for maintaining the barriers established for collection of transit fee, the state
government is incurring expenses of Rs. 21-22 crore per annum but affidavit further reveals that
the department is paying huge salaries to the officers, officials and other staff of the forest
department, who are responsible to regulate transportation of forest produce and protection and
development of the forest. Affidavit further demonstrates that over and above the salaries of the
employees of forest department, expenses are also being incurred on the vehicles, telephones,
JCB machines for the purpose of regulating transportation of forest products within forest and
outside the forest area.since regulatory fee has no nexus with quid pro quo therefore, the state
government is not required to demonstrate every expenses justifying rate of regulatory fee i.e.
transit fee. Having pursued the entire material I find that enhanced transit fee @Rs.50 per ton,
after 34 years, from Rs. 5 per ton cannot be said to be excessive, arbitrary and unjustified. "
Consequently all the writ petitions were dismissed.

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 CONCLUSION

After going through the case in question the researcher has come to the conclusion that in the
cases where there is increase of any type of fees levied by the state government and the fees is
regulatory in nature that means any and all fees and charges imposed by the regulatory authority
in connection with the development, manufacture, packaging, labeling, storage, import, export,
marketing etc. of any product in question then that fees doesn’t have to be linked with quid pro
quo.

The state government concerned doesn’t necessarily have to render services equivalent to the
fees levied. However the fees should not be in excess and unjustified. In this case the learned
judge under section 57 took judicial notice of the fact that the increase in transit fee was made
after 34 years. And this transit fees includes not only the expense of transportation of forest
produce but also the salaries of the officers in charge of forest and various other expenditure
done by the state government to protect and take care of the forest as well as wild animals there.

The researcher agrees with the learned judge’s view. Though the sudden increase in fee was
made by the state government but this fact cannot be disregarded that this increase was done
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after 34 years. Hence the government is fully justified in increasing the fees through this big
margin as a prudent person cannot deny the fact that 34 years is a long time to increase the fees;
in these years the salaries of the officers would have been increased, the salaries of the staff
would have been increased and various other expenses can also be said to incearse. Thus the
researcher agrees with the judgememt given in thus present case.

BIBLIOGRAPHY

1- Law of Evidence by Batuk Lal

2- www.casemine.com
3- Blog.ipeaders.in
4- heinonline.org

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