Section 30 of Bharatiya Sakshya Adhiniyam, 2023: Relevancy of statements in maps, charts and plans

Bharatiya Sakshya Adhiniyam, 2023 • Official Statutory Text & Practice Guide

Statutory Regulation
Legal Standard
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Act 2023
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Legal Commentary & Landmark Judgments: Section 30

Section 30 governs the admissibility of entries in books of account, including those kept in electronic or digital form, regularly kept in the course of business, establishing an exception to hearsay for accounting logs.

  • Regular Course of Business: The accounts must be maintained continuously and systematically according to established mercantile or digital accounting practices (e.g. ERP, SAP, Tally).
  • Electronic & Digital Expansion: Expressly encompasses electronic ledgers, digital audit trails, and core banking database entries.
  • Corroboration Requirement: Statutory mandate: ledger entries alone are insufficient to charge any person with liability without independent corroborative evidence of actual transaction or delivery.
Key Landmark Precedents:
  • CBI v. V.C. Shukla (1998) 3 SCC 410 (Jain Hawala Case): The Supreme Court ruled that spiral notebooks, loose sheets, and diary entries do not constitute 'books of account regularly kept in the course of business'; entries alone cannot establish liability without corroboration.
  • State of A.P. v. Cheemalapati Ganeswara Rao (AIR 1963 SC 1850): Held that regular ledger entries corroborate oral testimony regarding monetary advances, but cannot substitute for substantive proof of contractual disbursement.
Courtroom Practice & Strategic Litigation Guidance:

In commercial summary suits and Section 138 NI Act trials, never rely solely on computerized ledger printouts. Always tender corresponding bank account statements, tax invoices, and e-way bills to satisfy the mandatory corroboration rule.