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Central Act · India · Part II · Chapter II — Relevancy of Facts

Section 28 BSA Entries in books of account when relevant

Bharatiya Sakshya Adhiniyam, 2023 · Edition: Original enacted Gazette, 25 December 2023; supplied UP Police IEA comparison (printed pages 9–25)

Statements made under special circumstances

Entries in the books of account, including those maintained in an electronic form, regularly kept in the course of business are relevant whenever they refer to a matter into which the Court has to inquire, but such statements shall not alone be sufficient evidence to charge any person with liability.

Illustration. A sues B for one thousand rupees, and shows entries in his account books showing B to be indebted to him to this amount. The entries are relevant, but are not sufficient, without other evidence, to prove the debt.

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Judgments on Section 28

LOK 2026 (9) SC 87 · Supreme Court of India

Santosh Singh v. State of Madhya Pradesh

Equivalent citations: 2026 INSC 972 : 2026 KLT OnLine 4545

SubjectCriminal
JudgesJustice J.B. Pardiwala, Justice K. Vinod Chandran
ActsCriminal Procedure Code 1973 - Section 319 Penal Code 1860 - Sections 34 149 Evidence Act 1872 - Section 134

The name of A13 was not spoken of by many eyewitnesses initially, and was only brought in after they were recalled and examined-in-chief post-summons under Section 319 CrPC — Testimony against A13 was found to be tutored and lacked substantive corroboration from prior statements —…

LOK 2019 (4) SC 28 · Supreme Court of India

National Investigation Agency v. Zahoor Ahmad Shah Watali

Equivalent citations: 2019 INSC 456 : AIR 2019 SC 1734 : 2019 (2) Crimes 63 : 2019 CriLJ 2609 : JT 2019 (4) SC 51 : 2019 KLT (Online) 3012 : 2019 (5) Scale 774 : (2019) 5 SCC 1 : 2019 KHC 6384

SubjectBail, Criminal Law, Unlawful Activities (Prevention) Act
JudgesJustice A.M. Khanwilkar, Justice Ajay Rastogi
ActsUnlawful Activities (Prevention) Act, 1967 (Section 43D(5), (6) and (7); Sections 13, 16, 17, 18, 20, 38, 39 and 40); National Investigation Agency Act, 2008 (Section 21); Indian Penal Code, 1860 (Sections 120B, 121, 121A and 124A); Code of Criminal Procedure, 1973 (Sections 161, 164 and 173); Indian Evidence Act, 1872 (Section 34)

The respondent, a Kashmiri businessman named as Accused No. 10 in an NIA case of terror funding and conspiracy to wage war, was refused bail by the Designated Court. The charges were under Sections 120B, 121, 121A and 124A IPC and Sections 13, 16, 17, 18, 20, 38, 39 and 40 of the UAPA. The High Court granted bail after examining the prosecution material in detail. It treated the central document, a loose “green sheet” recording foreign receipts and disbursements (D-132(a)), as inadmissible, discarded Section 161 statements, and declined to consider the Section 164 statements of protected witnesses produced in a sealed cover. The NIA appealed.