Courts’ Reliance on Google Maps to Determine Geographical Facts: An Indian Law Perspective on its use and precautions

 Key Takeaway: Indian courts may admit Google Maps evidence subject to the same principles governing other maps and charts under the Indian Evidence Act, 1872 and Bharatiya Sakshya Adhiniyam, 1980, but must scrutinize accuracy, relevance, and potential privacy implications before relying on it for decisional purposes.

1. Statutory Framework for Admissibility of Maps and Charts

·       Section 30 of the Bharatiya Sakshya Adhiniyam (BSA) deems “published maps or charts generally offered for public sale, or maps or plans made under authority of the Central or State Government” as relevant facts, admissible without further proof of their contents.

·       The Indian Evidence Act, 1872 contains no express exclusion of private or commercial maps; hence, Google Maps screenshots or distance measurements may be admitted as secondary evidence under Sections 63–65, provided their authenticity and accuracy are established.

2. Judicial Notice and Google Maps

·       Judicial Notice of Locations: Courts routinely take judicial notice of street names, public landmarks, and well-known localities. In Koperasi Tanjong Keramat Malaysia Berhad v. Permodalan Kelantan Berhad & Anor, the Malaysian High Court took judicial notice of two shoplot addresses and measured the straight-line distance via Google Maps to hold the breach of a 3 km exclusive territory clause.

·       Indian Counterparts: Indian courts have similarly used Google Earth imagery to determine possession or land use (e.g., annexed Google Earth snapshots were tendered in land-possession petitions, though the Kerala High Court cautioned that such images are not conclusive proof of title or occupation.

3. Case Law Examples

Case	Court & Year	Use of Google Maps/Earth	Outcome
Frank Vitus v. NCB & Ors.	Supreme Court, 2024	Examined “dropping a PIN” feature in bail conditions; issued notice to Google to understand technical aspects.	Held that forcing accused to share Google pin violates right to privacy under Article 21.
Koperasi Tanjong Keramat v. Permodalan Kelantan	High Court of Malaya, 2025	Measured direct distance (less than 60 m) between two outlets using Google Maps to establish breach of exclusivity clause.	Court relied on Google Maps as objective, verifiable evidence of proximity.
State of Kerala v. P. Rajendran (land dispute)	Kerala High Court, 2018	Parties tendered Google Earth snapshots of property from 2003 to 2017 to demonstrate land use.	Court noted that imagery alone is insufficient to prove possession; accepted it as supporting but not conclusive evidence.
Karnataka High Court WP(C) No. 9598/2022	Karnataka High Court, 2023	Fisheries officer’s report included Google Earth distance measurements between quarry and wildlife sanctuary.	Data used to support administrative decision; no challenge to admissibility.

 

4. Principles Governing Judicial Reliance on Google Maps

1.       Foundation of Accuracy:

– Google Maps measurements are approximate, based on satellite data, and subject to updates; courts must allow expert testimony or cross-examination to challenge precision.

2.       Authentication:

– The party tendering a Google Maps screenshot must authenticate it, for instance through a qualified IT or survey expert, under Sections 65 and 67 of the Evidence Act.

3.       Corroboration with Official Records:

– To satisfy Section 30 BSA, courts should cross-verify Google Maps data with Survey of India maps, revenue plans, or municipal records.

4.      Privacy Considerations:

– As Frank Vitus underscores, reliance on dynamic location-sharing features (e.g., live tracking or PIN drops) raises Article 21 privacy concerns; static screenshots present fewer issues.

5. Practical Guidance for Advocates and Judges

·       Drafting Pleadings: Specify the exact URL, date, time, and zoom level of the Google Maps image or measurement relied upon; annex the screenshot with metadata where possible.

·       Pre-trial Motions: File a notice of intention to rely on Google Maps evidence, allowing the court to appoint a neutral survey expert if accuracy is contested.

·       Cross-Examination: Prepare expert evidence on satellite imagery reliability and potential distortions (e.g., projection errors, outdated imagery, seasonal cloud cover).

·       Balancing Rights: Where bail or privacy rights are at stake, avoid conditions mandating ongoing access to the accused’s real-time location; static geospatial evidence should be limited to fixed-point facts.

Conclusion

Indian courts may, in appropriate cases, rely on Google Maps to determine geographical distances and locations, provided the evidence is properly authenticated, corroborated by official sources, and used in a manner that respects fundamental rights. Advocates should meticulously lay the foundation for such evidence, and judges should apply established rules of evidence to ensure that the convenience of modern geospatial tools does not compromise accuracy or privacy.

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