Don't Just Believe What You See: A Practical Method for Judicial Fact-Finding, and How Appeals Review It

 Judgments are often reversed on fact-finding errors, not on questions of law. A unanimous 2026 decision of the Caribbean Court of Justice (CCJ), Robateau v Robateau [2026] CCJ 15 (AJ) BZ, sets out a clear method for trial judges. It also explains how a final appellate court reviews findings that two lower courts have already agreed on .

A Brother, a House and a Promise

Mrs Robateau held a government lease of a Belize City plot. The lease required her to develop the plot or risk forfeiture. Her son Ewart returned to Belize and built a family house on her promise of a life interest. He lived there openly for about 34 years.

Read full judgment here: Click here

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Think Like LiquidText: Turning Case Files into Proof Maps with Perplexity, Copilot and Meta AI

 How LiquidText’s active-reading method can be approximated with Perplexity, Microsoft Copilot and Meta AI—without surrendering judicial reasoning, confidentiality or source verification.

The basic idea

LiquidText is not merely a PDF reader. It places several source documents beside an expandable workspace, permits the reader to pull out excerpts, arrange them into groups, draw live “Ink Links,” compare distant passages and return from every note to its original context. It can import multiple documents into one project, display remote portions together and link notes or excerpts back to their sources.

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The Digital Bench: A Judge’s Guide to Mastering iPad & LiquidText

 

In the traditional courtroom, the "Bench" is often buried under physical mountains—bulky paper books, fragile charge sheets, and loose-leaf precedents. For a Session Judge handling serious criminal trials or complex bail applications, the cognitive load of physically managing these files often competes with the intellectual task of deciding them.

Enter the combination of an iPad and LiquidText. This is not merely a digital upgrade; it is a fundamental shift from reading a file to interacting with it.

This guide explores how judicial officers can leverage this specific hardware-software duo to create a "Digital Workspace" that is faster, lighter, and smarter than any physical file.

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From Record to Reasons: How LiquidText on Ipad Helps Judges to decide complex and complicated cases Better?

A practical guide to reading, marshalling and deciding a criminal record on the digital bench (updated October 2026)

Why This Matters on the Sessions Bench

A Sessions Judge handles some of the heaviest files in the district judiciary: murder trials, NDPS and POCSO cases, sessions appeals, criminal revisions, and a steady stream of bail applications. Each file brings a charge-sheet, the FIR, statements under Section 180 BNSS (old Section 161 CrPC), the spot and seizure panchanamas, medical and post-mortem reports, the FSL report, depositions and the arguments of both sides.

The real work lies not in reading these papers but in connecting them. You compare what PW-3 said in the witness box with what he told the police, set the post-mortem injuries against the eyewitness account, and check the seizure date against the chain of custody of the sample. On paper this means flags, slips and constant flipping between pages. LiquidText, a reading and annotation app for iPad (and also for Mac, Windows and iPhone), is built for exactly this kind of cross-document comparison.

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Supreme Court: Claimant is not entitled to get compensation in motor accident if he fails to prove identity of offending vehicle in the accident

 5.3 All the above evidence, circumstances and

considerations reinforce that the factum of involvement of

the offending vehicle as claimed and asserted by the

claimants was not proved. The claimants failed to

discharge their obligation on this count which was to be

the primary step. Given the above strong evidentiary

considerations, even on the principle of the

preponderance of probabilities, the involvement of Tata

Magic vehicle with registration number MH-13-B-2719

could not be concluded and was not established.

5.4 It was correct on the part of the High Court to

conclude that mere mentioning of Tata Magic by name in

the inquest Panchnama or in the FIR would not be

sufficient to hold that it was the same Tata Magic

belonging to respondent No.1 and insured with

respondent No.2 in absence of its clear identification.

6. It is a settled position of law that in a motor- accident

claim petition, the initial burden to prove the factum of

accident and involvement of offending vehicle lie on the

claimants. It is the claimants who have to discharge this

primary burden by establishing the occurrence of the

accident and the involvement as well as identity of the

vehicle at least on prima facie basis. Only then the onus to

disprove shifts to the other side.

Non-Reportable

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

CIVIL APPEAL NO.6794 of 2025

VANITA & ORS. Vs M/S SHRIRAM INSURANCE COMPANY LTD. & ANR. 

Author: N.V. ANJARIA, J.

Citation: 2025 INSC 1077

Dated: SEPTEMBER 04, 2025.

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Delhi HC: The object of Section 24 of HMA is to avoid vagrancy but it is not meant to equalize the income of the wife with that of the husband

 It is settled that object of Section 24 of HMA is to avoid vagrancy but it is not meant to equalize the income of the wife with that of the husband. A co-ordinate Bench of this Court has observed in K.N. v. {Para 16}

“12. The provisions of this section are not meant to equalize the income of the wife with that of the husband but are only to see that when divorce or other matrimonial proceedings are filed, either of the party should not suffer because of paucity of source of income and the maintenance is then granted to tie over the litigation expenses and to provide a comfortable life to the spouse. Where, however, both the spouses are earning and have a good salary, merely because there is some salary difference cannot be a reason for seeking maintenance.”

IN THE HIGH COURT OF DELHI AT NEW DELHI 

  MAT.APP.(F.C.) 109/2022

 MEENAKSHI BATRA  Vs  VIJAY KUMAR BATRA 

CORAM: HON’BLE MR. JUSTICE VIVEK CHAUDHARY HON’BLE MS. JUSTICE RENU BHATNAGAR

Dated: 08.10.2026.

Read full judgment here: Click here.

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Delhi HC: Whether wife is entitled to get maintenance if her expenses are more than her recurring income?

The appellant has relied upon her monthly expenditure, which according to her affidavit is approximately Rs. 1,16,150/-, apart from litigation expenses. The mere assertion of an expenditure figure, however, cannot be treated as conclusive. Section 24 requires the Court to determine the reasonable needs of the applicant. The assessment necessarily has to take into account the age of the parties, their present circumstances, their established standard of living, their medical requirements, residential expenses and other genuine necessities. {Para 21}

22. The fact that a particular expenditure has been disclosed in an affidavit does not make the expenditure, by itself, an expenditure which the other spouse is statutorily liable to fund. The Court has to distinguish between expenses which are necessary for reasonable support and expenses which represent discretionary expenditure or a manner of deployment of one's resources which cannot automatically be fastened upon the other spouse.

 The fact that the appellant’s disclosed expenditure exceeds her recurring income cannot, by itself, lead to the conclusion that she is entitled to maintenance under Section 24. The expenditure claimed must first be assessed for reasonableness.Section 24 is intended to secure reasonable support and the necessary expenses of litigation; it does not contemplate reimbursement of every item of expenditure disclosed by the claimant irrespective of its nature or necessity.

IN THE HIGH COURT OF DELHI AT NEW DELHI 

  MAT.APP.(F.C.) 109/2022

 MEENAKSHI BATRA  Vs  VIJAY KUMAR BATRA 

CORAM: HON’BLE MR. JUSTICE VIVEK CHAUDHARY HON’BLE MS. JUSTICE RENU BHATNAGAR

Dated: 08.10.2026.

Read full judgment here: Click here.

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Retirement corpus can't be treated as monthly income for maintenance, Delhi High Court clarifies in matrimonial dispute

 In considering these assets, a distinction has to be made between the retirement corpus and the income generated from that corpus. The retirement corpus is accumulated capital. It cannot, merely because it is substantial, be treated as if it were a monthly income. A retired person cannot be expected to consume his or her retirement savings merely for the reason that such savings exist. At the same time, where the retirement savings are invested and generate interest or other returns, such recurring returns are income and have to be considered. The question before the Court is, therefore, not whether the appellant has a substantial retirement corpus, but whether she has sufficient recurring income and financial resources to meet her reasonable needs. {Para 18}

19. The Family Court, while considering the appellant’s financial position, placed considerable reliance upon her retiral benefits and investments. To that extent, the approach requires some clarification. The entire retiral corpus cannot be treated as recurring monthly income. What can be taken into account as income is the interest or other return actually generated from those investments.

20. However, the existence of a retirement corpus is not completely irrelevant. It forms part of the overall financial circumstances of the appellant. The Court is entitled to consider the financial resources available to her while deciding whether she is in a position to support herself. What the Court cannot do is to treat the corpus itself as though it were a recurring salary.

IN THE HIGH COURT OF DELHI AT NEW DELHI 

  MAT.APP.(F.C.) 109/2022

 MEENAKSHI BATRA  Vs  VIJAY KUMAR BATRA 

CORAM: HON’BLE MR. JUSTICE VIVEK CHAUDHARY HON’BLE MS. JUSTICE RENU BHATNAGAR

Dated: 08.10.2026

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Supreme Court: Whether appellate court must hear accused on the point of sentence while convicting him after setting aside order of his acquittal?

It can be seen from Section 386(a), Code of Criminal Procedure, that where in an appeal from an order of acquittal, the court hearing the appeal finds the Accused guilty it is required to pass a sentence on him according to law. {Para 13}

14. In Kumar Exports v. Sharma Carpets   MANU/SC/8414/2008 : 2008:INSC:1437, this Court interpreting Section 386(a), Code of Criminal Procedure, while holding that appellate court ought not, after recording conviction, remit the matter to the trial court and that the appellate court is obligated to impose an appropriate sentence, held as under:

26. This Court has also noticed a strange and very disturbing feature of the case. The High Court, after convicting the Appellant Under Section 138 of the Act, remitted the matter to the learned Magistrate for passing appropriate order of sentence. This course, adopted by the learned Single Judge, is unknown to law. The learned Single Judge was hearing an appeal from an order of acquittal. The powers of the appellate court, in an appeal from an order of acquittal, are enumerated in Section 386(a) of the Code of Criminal Procedure, 1973. Those powers do not contemplate that an appellate court, after recording conviction, can remit the matter to the trial court for passing appropriate order of sentence. The judicial function of imposing appropriate sentence can be performed only by the appellate court when it reverses the order of acquittal and not by any other court. Having regard to the scheme of the Code of Criminal Procedure, 1973 this Court is of the view that after finding the Appellant guilty Under Section 138 of the Act, the judicial discretion of imposing appropriate sentence could not have been abdicated by the learned Single Judge in favour of the learned Magistrate. Having found the Appellant guilty Under Section 138 of the Act it was the bounden duty of the High Court to impose appropriate sentence commensurate with the facts of the case. Therefore, we do not approve or accept the procedure adopted by the High Court. Be that as it may, in this case, we have found that reversal of acquittal itself was not justified.

[Emphasis supplied]

15. Not only should the appellate court not remand the matter to the trial court only for the purpose of imposing a sentence, after it finds Accused guilty, it has a bounden duty to hear and impose an appropriate sentence.

16. The appellate court which will include the High Court, in a given scenario, while recording a conviction after reversing the acquittal, should adjourn the matter to a suitable date, hear the convicts, and impose an appropriate sentence itself.

IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 1432 of 2019

Decided On: 08.10.2026

Ramkrushna Prahllad Dongardive Vs. The State of Maharashtra

Hon'ble Judges/Coram:

Ujjal Bhuyan and A.S. Chandurkar, JJ.

Author: A.S. Chandurkar, J.

Citation: MANU/SC/1143/2026,2026 INSC 1099.

Read full judgment here: Click here.

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Supreme Court: What should be approach of appellate court while deciding appeal against acquittal?

 Since the impugned judgment is one of reversal of acquittal, the broad principles to be borne in mind by an appellate Court when it considers an appeal from an order of acquittal are required to be noted. In this regard, we may refer to the observations in paragraph 20 of the judgment in Chelloor Mankkal Narayan Ittiravi Nambudiri (supra) which reads as under: {Para 11}

20. It cannot be disputed that the High Court, even though it was hearing an appeal from an order of acquittal, had full powers to review the entire evidence on the record and reach its own conclusion that the acquittal order should be set aside. But as the Privy Council pointed out in --'Sheoswarup v. Emperor', in exercising these powers the High Court should and will always give proper weight and consideration to such matters as: (1) the views of the trial court as to the credibility of witnesses; (2) presumption of innocence in favour of the Accused, a presumption certainly not weakened by the fact that he had been acquitted at the trial; (3) the right of the Accused to the benefit of any doubt; and (4) the slowness of an appellate court in disturbing a finding of fact arrived at by a Judge who had the advantage of seeing the witnesses.

IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 1432 of 2019

Decided On: 08.10.2026

Ramkrushna Prahllad Dongardive Vs. The State of Maharashtra

Hon'ble Judges/Coram:

Ujjal Bhuyan and A.S. Chandurkar, JJ.

Author: A.S. Chandurkar, J.

Citation: MANU/SC/1143/2026,2026 INSC 1099.

Read full judgment here: Click here.

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Supreme Court: Procedural Violation Will Not Vitiate Seizure But Can Affect Evidentiary Value

It is true that non-compliance of the requirements of Section 100 of the Code by itself would not vitiate a seizure and the same would be an irregularity in the investigation. However, when this factor is considered cumulatively with other factors that contribute to doubting the prosecution case, the same would weigh in favour of the Appellant, especially in an appeal against acquittal. In this regard, we may refer to two decisions of this Court. In Sunder Singh v. State of Uttar Pradesh   MANU/SC/0118/1955 : AIR 1956 SC 411, it was held as under:

In respect of the search of the room occupied by the Appellant and the recovery of the bloodstained shirt and bloodstained pants aforesaid it was necessary to have at least two search witnesses as required by Section 103. Assuming that the two rickshaw-wallahs who actually witnessed the search as found by the Courts below were not respectable inhabitants of the locality, that circumstance would not invalidate the search. It would only affect the weight of the evidence in support of the search and the recovery. Hence at the highest the irregularity in the search and the recovery in so far as the terms of Section 103 had not been fully complied with would not affect the legality of the proceedings. It only affected the weight of evidence which is a matter for courts of fact and this Court would not ordinarily go behind the findings of fact concurrently arrived at by the courts below.

Similarly, in State of Punjab v. Balbir Singh and Ors.   MANU/SC/0436/1994 : 1994:INSC:96, this Court held as under:

At this juncture we may also dispose of one of the contentions that failure to comply with the provisions of Code of Criminal Procedure in respect of search and seizure even upto that stage would also vitiate the trial. This aspect has been considered in a number of cases and it has been held that the violation of the provisions particularly that of Sections 100, 102, 103 or 165 Code of Criminal Procedure strictly per se does not vitiate the prosecution case. If there is such violation, what the courts have to see is whether any prejudice was caused to the Accused and in appreciating the evidence and other relevant factors, the courts should bear in mind that there was such a violation and from that point of view evaluate the evidence on record.

In the light of the aforesaid position, weightage to be given to the articles stated to be seized from the house of the Appellant would have to be cumulatively assessed with the other material on record. {Para 19}

IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 1432 of 2019

Decided On: 08.10.2026

Ramkrushna Prahllad Dongardive Vs. The State of Maharashtra

Hon'ble Judges/Coram:

Ujjal Bhuyan and A.S. Chandurkar, JJ.

Author: A.S. Chandurkar, J.

Citation: MANU/SC/1143/2026,2026 INSC 1099.

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Supreme Court: Victim Also Has Right To Seek Speedy Trial Like Accused

Therefore, to say that the role of the victim is limited

to being a witness, is not correct. A victim or the legal

guardian of the victim is a definite stakeholder in the

criminal justice system. Like the accused, she has also a

vested right to insist on a speedy trial and also for a fair

trial. Therefore, on a reading of the statutory scheme as

enumerated supra, certainly a victim has locus standi to seek

a speedy trial. She can certainly bring a petition under

Section 528 B.N.S.S. seeking a direction from the High Court

to the Trial Court to expedite the trial proceedings. {Para 20}

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL No.______OF 2026

(@ SPECIAL LEAVE PETITION (CRIMINAL) NO.13468/2026)

RENUKA JAIN  Vs  THE STATE OF NCT OF DELHI & ORS. 

Citation: 2026 INSC 1100.

Dated: 24th SEPTEMBER, 2026.

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Supreme Court: Under which circumstances Non-collection of tower location of the two mobiles is a serious investigational lapse?

 Lapse in collecting tower location of mobile(s) while

obtaining CDR

51. During investigation, the investigating officer was

apprised of mobile numbers of the deceased Mithilesh

Kumari (D-1) and the accused respondent. PW-19 was

produced to prove the CDR of one of the mobiles, though

both CDRs were part of police papers collected during

investigation. However, interestingly, the CDRs do not

disclose tower location of the concerned mobiles which

could have helped in pin-pointing as to whether the two

mobiles at the relevant time were in close proximity of each

other, and whether D-1’s mobile had moved to the place of

residence of the accused from where it was allegedly

recovered. Non-collection of tower location of the two

mobiles is a serious investigational lapse in the facts of the

case.

52. Further, strangely, the CDR of D-1’s mobile was

not even exhibited. Interestingly, PW-20 (i.e., the

investigating officer) does not even disclose whether D-1’s

mobile was operative or not after 31.08.2011 as per its

CDR.

53. In our view, CDRs of the two mobiles with corresponding tower locations would have been critical in revealing:

a. whether the accused’s mobile at the relevant

time was near the location where the dead

bodies of the two deceased were found; and

b. whether D-1’s mobile was active any time

after 31.08.2011; if yes, whether she received

any call after 31.08.2011; if yes, from what

location.

54. The importance of clarity on the aforesaid

questions cannot be undermined as they had the potential

to either corroborate or demolish the prosecution story.

Because if the mobile of the deceased was operative after

31.08.2011, PW-1’s statement that it was found switched

off would have been negated. Besides, its tower location

would have indicated where the person in possession of that

mobile was located. This was crucial because the

prosecution story hinges on the circumstance that the

deceased and the accused were together on 31.08.2011.

Therefore, if the tower location of the two mobiles had

disclosed that they were not in close proximity to each other

on the fateful day, some explanation would have been

required as to why it was so, when, according to the

prosecution, owners of those two mobiles were together on

the fateful day. Assuming that the accused may not have

carried her mobile to the scene of crime, tower location of

D-1’s mobile could have reflected upon the truth of the

prosecution story. Here there is no explanation by the

prosecution as to why the tower location was not collected.

In our view, lack of information in that regard is a serious

investigational lapse.

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL No. 166 of 2019

THE STATE OF HIMACHAL PRADESH VsANCHLA @ CHANCHLA

Author: MANOJ MISRA, J.

Citation: 2026 INSC 1074

Dated: October 01, 2026.

Read full judgment here: Click here.

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Investigating Officer Must Not Create Evidence' : Supreme Court Upholds Acquittal After Finding Witnesses Were 'Set Up'

 To a lay man, the above circumstances may appear

irrelevant in assessing credibility/ trustworthiness of a

witness. But to a trained judicial mind it is an important

circumstance in assessing whether a person is a natural

witness, who is aware of relevant facts, or is the one who

has been set up to create evidence. Normally, when a person

is aware about a crime and has knowledge of any

circumstance which, to his understanding, is incriminating

in nature and may be of help to the police, he may, as a

responsible person of the society, provide information to the

police. But where the circumstance, of which one has

knowledge or awareness, in itself is not one which could be

considered incriminating or relevant for investigation of a

crime, there is no likelihood of that person reporting it to

the police. Therefore, the answer to the question as to why,

when and in what circumstances the witness statement

was recorded during investigation becomes an important

tool in assessing the credibility of that witness. The reason

is simple. Because the answer would help in determining

whether the witness is a natural one or has been set up to

create evidence. {Para 41}

42. It is well settled that the role of the investigating

officer is to collect evidence and not to create one. Where

there is no occasion for the investigating officer to record

statement of a person, or for that person to impart

information to the police, yet, the police proceeds to record

his statement without narrating the circumstance in which

it was considered necessary to record his statement, a

serious doubt arises as to whether that witness has been

set up to create evidence.

43. We have no doubt in our mind that an investigating

officer may pick up clues from any statement recorded

during investigation to record statement of another. Such

an exercise is completely bona fide. For example, if after

recording statement of A, the investigating officer comes to

know that B may have knowledge of something relevant, he

would be justified in recording statement of B. But if the

investigating officer straightway records statement of B,

and there is no palpable reason for him to believe that B is

possessed of relevant information, and B has no reason to

impart information on his own to the investigating officer, a

suspicion would arise whether the exercise of recording

statement of B is undertaken just to create evidence. Lack

of explanation in that regard may dent the credibility of B.

44. Ordinarily an investigating officer collects evidence

from witnesses who are either present at the scene of crime

or are likely to be aware of the crime and have information

about it. Evidence may also be collected from persons who,

by virtue of their relationship with the victim or the named

accused, are likely to have relevant information.

Investigation may also reach out to those who may be in

contact with the victim, or the known accused, based on

Call Detail Record (CDR) of the mobile of the victim or the

suspects. Likewise, information may be collected on the

basis of information received through disclosure statement

suffered by the accused. However, where a person is not

even aware that the information which he is possessed of is

incriminating against some person, there is no likelihood of

that person reporting that information to the police. In such

circumstances, what propels the investigating officer to

record his statement becomes important, and failure to

disclose the reason may dent the credibility of that witness

as it may reasonably be inferred that the said witness is one

who has been set up.

45. In the present case, PW-20 i.e., the investigating

officer ducks the question and feigns ignorance as to when

he recorded the statement of PW-4 and PW-18 during

investigation. Further, there is no explanation as to what

prompted him to record statements of PW-4 and PW-18

during investigation. Importantly, PW-20 does not state

that in her disclosure statement the accused had disclosed

about travelling by Taxi from Chamba to Diur and back or

about her stay at the hotel. PW-20 only states that the

accused in her disclosure had stated that she could get the

keys and mobile recovered. Thus, statements of PW-4 and

PW-18 appear to have been recorded only to create

evidence.

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL No. 166 of 2019

THE STATE OF HIMACHAL PRADESH VsANCHLA @ CHANCHLA

Author: MANOJ MISRA, J.

Citation: 2026 INSC 1074

Dated: October 01, 2026

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Speak to Type: A Complete Guide to Using Voice Typing in Google Docs

 Writing doesn't always require a keyboard. Google Docs includes a powerful, built-in feature called Voice typing that transforms your spoken words into written text in real time. Whether you want to draft an essay hands-free, speed up your writing process, or improve accessibility, this guide will walk you through setting up and mastering speech-to-text in Google Docs.

System Requirements & Setup

Before you begin, ensure you have a working microphone (either built-in or external) and a stable internet connection.

·       Desktop Compatibility: Voice typing is fully supported on desktop browsers including Google Chrome, Microsoft Edge, and Apple Safari.

·       Mobile Availability: The feature is available on both Android and iOS devices through your smartphone's default keyboard microphone.

Step-by-Step: Using Voice Typing on Desktop

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Supreme Court: Testimony For Sexual Offence Within Home Does Not Require Same Corroboration As Crimes Committed In Open

The third principle concerns the appreciation of

evidence in cases of sexual offences and of crimes

committed within the privacy of the home. Offences

of this nature are seldom committed in the presence

of witnesses. The sexual abuse of a child within the

household, in particular, is perpetrated in secrecy

and in stealth, and the persons ordinarily present are

the perpetrator, the child and, if at all, a member of

the household who is powerless to prevent it. To

insist, in such cases, upon the kind of corroboration

that might be available in a crime committed in the

open would be to insist upon a standard that the very

nature of the offence renders impossible of

attainment, and would be to grant to those who prey

upon children within the home an immunity founded

upon the secrecy in which they cloak their crime. {Para 31}

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NOS. 429-430/2020

WARIS Vs THE STATE OF MADHYA PRADESH 

Author: VIKRAM NATH, J.

Citation: 2026 INSC 1050.

Dated: SEPTEMBER 24, 2026

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Supreme Court: Statement Of Accused U/S S. 313 of CrPC cannot Be Used To Complete An Unestablished Chain Of Circumstances

 On an overall consideration of all the circumstances relied upon by the prosecution, we find that the evidence led by the prosecution is woefully short of pointing to the guilt of the appellant. The witnesses examined were not sure as to whether the appellant was last seen with the victim as they had their own doubts in that regard. The discovery effected under Section 27 of the Act of 1872 was from a place that was ordinarily visible to others, thus, requiring such discovery to be considered with caution. The DNA report in clear terms refers to the bone extracts being of male origin while the victim was a female. The said bones naturally did not match with the blood samples of the victim’s mother and sister. The report from the FSL also does not take the case of the prosecution any further. There is a doubt created as to whether the brown shawl claimed by the prosecution to be brought by the appellant from his mother was the same as the appellant’s mother had denied that it belonged to her. Therefore, the appellant’s statement under Section 313 of the Code cannot be taken as an additional link in the chain of circumstances. In other words, the chain of circumstances has not been formed on the basis of the prosecution evidence. The Sessions Court, in our view, failed to notice these material factors that were very much available on record. It, therefore, erred in convicting the appellant on the basis of circumstantial evidence.  {Para 10}

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO.107 OF 2018

SANTOSH GURUNG Vs STATE OF SIKKIM 

ATUL S. CHANDURKAR, J.

Dated: OCTOBER 1, 2026.

Citation: 2026 INSC 1073.

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Instagram Chats Alone Cannot Prove ‘Living In Adultery’: Allahabad High Court In Maintenance Case

 In the present case, the sole foundation of the revisionist's claim of adultery is digital evidence in the form of Instagram chats. This brings the Court to the crucial aspect of the admissibility and evidentiary value of electronic records. {Para 12}

13. It is a settled proposition of law that the admissibility of electronic evidence must be tested strictly at the anvil of Section 65-B of the Indian Evidence Act, 1872. In the landmark decision of Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal (2020) 7 SCC, a three-judge bench of the Hon'ble Supreme Court clarified the mandatory nature of this statutory requirement.

14. It was further reiterated in the said judgment, following the ratio in Anvar P.V. v. P.K. Basheer 2014 (10) SCC 473, that the statutory certificate is a mandatory condition precedent to the admissibility of evidence by way of an electronic record. Secondary evidence of electronic records is admissible only if led in the strict manner stated in the statute, and not otherwise.

15. The necessity for such strict verification stems from the inherent vulnerabilities of digital data. As observed by the Apex Court in various pronouncements dealing with electronic evidence and private investigations, there is an ever-present danger regarding the authenticity of such material.

16. Applying these settled legal principles to the facts at hand, it is evident that the Instagram chats produced by the revisionist are not supported by the mandatory statutory certification. In the absence of such a certificate, it would be entirely incorrect in law to treat this electronic evidence as admissible.

17. Even if, for the sake of argument, the contents of the unverified chats were to be perused, mere text messages on a social media platform, without corroborative evidence of physical intimacy or cohabitation, are thoroughly insufficient to legally establish that the wife is continuously "living in adultery". The burden lies heavily upon the revisionist to prove a continuous adulterous lifestyle, which he has failed to discharge.

HIGH COURT OF JUDICATURE AT ALLAHABAD

CRIMINAL REVISION No. - 7800 of 2025

Court No. - 85

HON'BLE JAI KRISHNA UPADHYAY, J.

Dated: September 29, 2026.

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Delhi HC: Father-in-law can't be held liable in domestic violence case for failing to control adult son

 The first allegation does not make out a case against respondent No. 2. The application records that he opposed the proposed trip involving respondent No. 3, Kira, Ms. Sonal Jindal and her children. He stated that, had he been in the petitioner's position, he would not have sent Kira if Ms. Sonal Jindal were present. Nothing in this account shows his participation in the alleged matrimonial misconduct of respondent No. 3. A father cannot be made liable under the DV Act merely because he did not control the conduct of his adult son. {Para 19}

IN THE HIGH COURT OF DELHI AT NEW DELHI

CRL.M.C. 6388/2023 & CRL.M.A. 36957/2024

Deepali  Vs. State Through Chief Secretary and Ors.

Hon'ble Judges/Coram:

Madhu Jain, J.

Date of Order: 19.08.2026.

Citation: MANU/DEOR/87314/2026

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Tripura HC : Pillion Rider Not Covered Under Act-Only Motor Insurance Policy Without Additional Premium

In view of the above and considering facts and circumstances of the present case on hand, this Court is of the considered view that since the policy is only an Act policy issued by the respondent-Insurance company to the insurer and the son of the appellants i.e. the victim was only an occupant of the rider of the motor cycle, cannot be considered as 'third party' of the vehicle. The doctrine of ‘pay and recovery’ also cannot be applied to the facts of the case, since the Insurance company is not liable to pay the compensation in view of the above discussions. {Para 13}

HIGH COURT OF TRIPURA AGARTALA

 MAC APP 59 OF 2026. 

Sri Ranjan Chakraborty Vs Sri Debabrata Saha,

BEFORE HON‟BLE JUSTICE DR. T. AMARNATH GOUD 

Citation: TRHC010007842026 2026:THC:1222

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