A CRITICAL STUDY ON EVIDENTIARY VALUE OF TAPE-RECORDED CONVERSATION

Indian Journal of Integrated Research in Law Volume II Issue IV | ISSN: 2583-0538

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A CRITICAL STUDY ON EVIDENTIARY VALUE OF TAPE-

RECORDED CONVERSATION

Abhijeet Mishra, Symbiosis Law School, Hyderabad

ABSTRACT

In today’s era, people have shifted to the electronic device, starting from

phone to lending of money. Globalization has not only aided to the society

but also increased the ranges and variety of crime. People confined in a four

walled room are doing heinous crimes and there is little to no scope in

identifying the witness. Bribery, cyber-bullying, forgery is planned through

electronic medium. In order to prevent it, the governmental officials have

discretionary power to check and identify the crimes through tape recordings.

Have you ever been a victim of phone tapped recording or has someone

threatened you to reveal or post your conversation? The question arises if

phone tapped recordings can be produced before the court and what is the

evidentiary value of such evidence. The researcher through this research tries

to understand the admissibility of phone tapped recording and its evidentiary

value.

Keywords: Forgery, Discretionary, Phone-tapped-recording, Admissibility,

Evidentiary

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INTRODUCTION

With advent of new technology, the right to privacy can easily be invaded through few clicks

via surfing on the internet. Cyber-bullying, cybercrimes are newer forms of offence that has

seen growth in this 21

century. The legal system in our nation has adapted the new era of

technology and tries to change itself as the technology evolves through generation. The same

can be laid down in case of Law of Evidence, the judiciary has admitted the growth of new

possible crimes and recognized electronic evidence as admissible with certain exceptions.

Tape recording falls under the criterion of documentation of evidentiary value, which is

collected through the magnetic tapes or digital multimedia devices. The practise of presenting

tape-recorded conversations as evidence in law courts has seen a fundamental rise, especially

under the cases of preventing corruption and criminal conspiracy. The criminal courts have

addressed the usage of the tape recording in various cases from bribery to planning of crimes.

In the similar view, civil courts have used tape recorded evidence to support or identify the

offender and victim. Before the amendment of Information Technology Act, the Indian

Evidence Act mainly dealt with oral and documentary evidence. There is no value of electronic

evidence or evidence recorded through electro-magnetic devices, as the admissibility and

evidentiary value were questioned, and nature was criticized. There was only Telegraph Act,

1885 that directed tampering or damaging of telegraph would lead offence. The court reasoned

that it would be incorrect to deny to the law of evidence advantages obtained by new techniques

and devises.

RESEARCH OBJECTIVE

• To analyse the evolution of admissibility of tape-recorded evidence in India.

• To understand the nature and conditions of tape-recorded evidence.

• To establish a general idea on evidentiary value of tape-recorded evidence.

• To identify the loopholes of the admissibility of tape-recorded conversation.

• To understand the judicial interpretation on the admissibility of such evidence.

RESEARCH QUESTION

• How did the admissibility of phone tape recording evolve in India?

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• What is the nature of the phone tapped recordings and what are conditions to be fulfilled

before courts?

• Is tape recorded evidence hearsay or res gestae?

• Is it illegal to record a conversation without the consent of the other party? If not,

doesn’t it violate the right to privacy?

RESEARCH METHODOLOGY

For the goal of the study, the researcher used doctrinal and analytical form of research

methodology. Websites and sources available on an internet platform were used as primary

data sources. Secondary data sources included journals, papers, books, and a variety of other

sites. Relevant resources for data analysis and interpretation were gathered. Pure analytics was

employed to comprehend and determine the evidentiary value of the tape-recorded evidence.

The analysis of primary and secondary sources was critical to the completion of the research.

Finally, the judicial interpretation was laid down for better understanding of the concept and a

few suggestions were put forward.

LIMITATION

The research lacks in detailed analysis of the international laws regarding the admissibility of

the tape-recorded evidence. It also fails to provide detailed information on how the right to

privacy is hampered. Due to limited range of literature, the researcher couldn’t analyse deeply

the other provision such as Telegraph Act. The research failed to produce more information on

electronic evidence, as evidentiary value of electronic evidence is vast topic to explore.

LITERATURE REVIEW

RECORDINGS, TRANSCIRPTS AND TRANSLATION AS EVIDENCE

by Clifford

S. Fishman

A law review material that highlights the history of admissibility of recordings and transcripts,

it talks about the nature and authenticity of the recording and transcripts. The materials deals

on how the recording can be admissible and what are the loopholes while translation of the

transcript. Thus, it helped to understand how the court needs to understand the context of the

Clifford S. Fishman, Recordings, Transscripts and Translations as Evidence, 81 WASH. L.REV. 473 (2006)

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recorded conversation and evidence should be analyzed thoroughly before coming to the

judgement.

PHONE-TAPPING AND RECORDING OF A PHONE CONVERSATION: IS IT

LEGAL AND ADMISSIBLE?

by Bharat Chugh

This is an article determining if one party records the conversation of the other without the

consent of other party, would it be considered legal? This article adds the various statutes that

govern the electronic evidence in India. It also states the reasoning of admissibility of the same.

This was important for the commencement of research as it valued for reasoning and also

described the importance of such evidence in day-to-day basis. Moreover, it stated how this

evidence can affect the privacy of the individual, if there is no limitation of generating such

evidence.

LAWS ON PHONE TAPPING IN INDIA: IS PRIVACY AT STAKE?

by Anisha

Bhandari

Article 21 safeguards the right to privacy and fosters the nobleness of the individual. The article

talks about the ultimate power of government officials in invading the right to privacy of

common citizen. This article talks about judicial approach towards the tapped recording

conversation. It suggests the government to ensure the right is privacy is maintained as the

privacy are stake. It was helpful in determining the flaws of such evidence.

EVOLUTION OF TAPE RECORDINGS: ADMISSIBILITY OF SUCH EVIDENCE

Oral and documentary evidence were under the purview of Indian Evidence Act, 1872. In those

earlier periods of time, there was no recognition of advanced technology. Eventually through

decades, photographs were realised and were admissible as direct evidence. By enactment of

the Information Technology Act, CCTV footages, information stored in computer or electronic

devices and recorded conversation played a crucial role in identify the facts of the case. Many

offences, such as corruption, bribing etc., are operated inside an opaque room or secretly,

Phone-tapping and Recording of a Phone conversation: Is it legal and admissible?, BHARATCHUGH, (Mar

18, 2022 10:31PM)

https://bharatchugh.in/2020/07/05/phone-tapping-and-recording-of-a-phone-conversation-by-a-private-party-

issues-relating-to-legality-and-admissibility/

Anisha Bhandari, LAWS ON PHONE TAPPING IN INDIA: IS PRIVACY AT STAKE? OXFORDUNIMEDIA

(Mar 20, 2022 10:45PM)

https://www.oxfordunimediasoc.com/blog/2021/1/24/laws-on-phone-tapping-in-india-is-privacy-at-stake

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making it difficult to obtain evidence. Thus, it has led to usage of telephone tapping and phone

recording conversation for gathering the first hand information or proof of the offence. The

issue which lies here are the nature and admissibility of such tape recording, the recording if

illegally obtained or doesn’t have any relevant context to the case and is manipulated, then the

credibility of such conversation be zero. The judiciary also looked upon this matter, as there is

scarce of direct evidence in such cases, thus there is importance of tape-recording evidence but

there is need to devise principles and guidelines for such questions given their importance in

such matter.

One of the foremost and earliest cases with regard to addressing the admissibility of tape

recorded evidence was observed in the case of Rup Chand v. Mahabir Parshad, “The court in

this case declined to treat tape-recorded conversation as writing within the meaning of section

65(3) of the General Clauses Act, as it interpreted writing as representing or reproducing words

in a visible form and it stated that the record which appears on a tape-recorder, could not fall

within the ambit of this definition.”

The admissibility of tape recorded evidence was denied

under “Sec. 145 of Indian Evidence Act.”

But it was allowed for credentials in favour of

witness under “Sec. 155(3) of the Act.”

Thus it can be stated that merely not falling under the

category of writing couldn’t declare the tape recording as inadmissible. However, the verdict

can not only be relied on the recorded conversation. Meaning, tape recording has values and

credentials in the case, but can’t be called on their own as sufficient evidence to change the

outcome of a case.

In the famous case of Yusufali E. Nagree v. State of Maharashtra, there was an argument

regarding the admission of guilt against the accused can’t be admitted as it violated the Article

20(3) of Indian Constitution. The police set up a trap and capture the discussion made by the

offender through tape recorder, who was proposing a bribe to the surgeon, who was about to

report the offence of guilty. “The Supreme Court ruled that the accused could not claim

protection under Article 20(3) on the basis of deceit since he had not been compelled to testify

against himself.”

In this landmark case, the court held that tape recording process is an

accurate form of interpreting the relevant incident or storing the relevant information of

incident and should have evidentiary value, until and unless there is has been manipulation in

Rup Chand v. Mahabir Parshad and Anr, AIR 1956 P H 173

Indian Evidence Act, 1872 § 145

Indian Evidence Act, 1872 § 155(3)

Yusufalli Esmail Nagree vs The State Of Maharashtra, 1968 AIR 147

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the recording material or there is no any relevant connection to the incident. Thus, it is

admissible under the Section 7 of Indian Evidence Act. In the case of R.M. Malkani v. State of

Maharashtra, similar view was taken for consideration, “A contemporaneous tape record of a

pertinent discussion is a relevant fact that can be used in court under Section 8 of the Evidence

Act.”

It's also similar to an image of a pertinent occasion. “As a result, the taped discussion

constitutes a material fact and is admissible under Section 7 of the Evidence Act.”

NATURE

A tape-recorded conversation is a form of storing the voice-samples on a magnetic medium.

However, in the case of Rupchand, “Punjab High Court declined to treat tape recorded

conversations as writing within the meaning of section 3 (65) of the General Clauses Act”

. It

was later recognized as documents in the Ziyauddin Burhanuddin Bukhar, the court held that

tape recorded conversation were “documents as defined by section 3 of the Evidence Act,

which stood on no different footing than photographs.”

The Section 25 of Indian Telegraph Act, 1885 stated that “the offence includes the act of

tampering a telegraph or the working of a telegraph with the intention of intercepting or

acquainting oneself with the contents of any message”

It was the first time the tape-recorded

conversation were regarded as similar to that of telegraph. After the enactment of Information

Technology Act, 2000, electronic evidence came into consideration and now the tape-recorded

conservation was under purview of electronic evidences. It was later confirmed through the

Section 65(A) with provision 65(B) of Indian Evidence Act, that the tape-recorded

conversation could now be admissible in court if it had relevancy and authenticity. Though in

general, the advancement of such evidence is done through judicial approaches.

“From the aforesaid provisions it becomes amply clear that the law, as it prevails today, takes

care of information stored on magnetic or electronic device and treats it as documentary

evidence within the meaning of section 3 of the Indian Evidence Act.”

CONDITIONS FOR ADMISSIBILITY OF TAPE-RECORDED EVIDENCE

R. M. Malkani vs State Of Maharashtra, 1973 AIR 157

Supra note at 4

Ziyauddin Burhanuddin Bukhari vs Brijmohan Ramdass Mehra & Ors, 1975 AIR 1778

Indian Evidence Act, 1872 § 3

Indian Telegraph Act, 1885 § 25

Information Technology Act, 2000

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The recorded sample of a tape-recorded conversation can be easily tampered, manipulated or

erased and inserted. This is the major issue which lies under the recorded evidence, any sort of

unfair and manipulation in the sample would directly affect the verdict of the case. Finally, if

there is a well-founded suspicion, not to mention proof, that the tape recording has been

tampered with, the court has a legitimate reason to dismiss its whole evidential value. The court

deciding on the case of “Rama Reddy and Ors. v. V.V. Giri”

, stated that tape recordings are

the first-hand information of the incident, if there is true value of recording that gives accurate

evidence without any manipulation, then its evidentiary value would be admissible. However,

the issues lie on the corresponding matter while valuing the evidences. The Apex Court, while

deciding on the matter of “Ram Singh v. Col. Ram Singh,”

laid down various conditions for

admissibility of tape-recorded conversation as follows: -

• The speaker's voice must be properly identified by the creator of the recording or by

others who know his voice. Where the recorded speaker has rejected the voice, an

extremely stringent proof will be required to decide whether or not it was indeed the

speaker's voice.

• Only by the means of direct or circumstantial evidence, the maker has to prove the

validity of the recorded conversation.

• Usage of any unfair means to tamper the recorded statements, would lose all the

credentials of the recorded materials and hence be inadmissible.

• The recorded conversation must be in context to the case and rules of Indian Evidence

Act.

• “The recorded cassette must be carefully sealed and kept in safe or official custody.”

• There should be clarity in the speaker’s voice, should be easily detectable any distort

or disturbance sounds could lead to inadmissible of the recording.

Other Important conditions for satisfying the admissibility of tape-recorded statements:

a. Identifying the voice of the parties:

When it comes to understanding the accuracy of the statement, first and foremost

concern is to identify if the voices of the parties or speaker to be true or real. “The

Shri N. Sri Rama Reddy Etc vs Shri V. V. Giri, 1971 AIR 1162

Ram Singh & Ors vs Col. Ram Slngh, 1986 AIR 3

Vinitha Tripathi, Evidentiary Value of Tape Recorded Conversation, SCRIBD (Mar 20, 2022, 10:30AM)

https://www.scribd.com/document/410251041/Law-of-Evidence

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correct identification of the recorded voice is a sine qua non for the usage of the taped

sound, such that the time, location and reliability of the recording must be determined

by the qualified witness and the sounds should be correctly recognized.”

b. Transcript

It is defined as written or printed of the original material presented in another medium.

It is impossible to dismiss the relevance of releasing a transcript of the tape-recorded

conversation since it indicates that the audio was not subsequently tampered with. The

use of transcript of a tape-recorded conversation raises issue of accuracy, admissibility

and presentation. It is difficult for anyone to analyse the context of the speakers and

most importantly how the accuracy of the statements can be valued. What should the

jury decide while reading transcript? In the case of Ramdas Mehta, it was held that the

opinion the transcriptionist has found after translation, should be used to denote the

corroborative evidence. Thus, Apex court made it clear that as per “Section 159 of

Evidence Act”

, the transcript helps the parties of the recorded conversation to

recollect the incidents and give it in as direct oral evidence as mentioned in “Section

160 of this Act”

EVIDENTIARY VALUE OF TAPE RECORDING

While determining the evidentiary value or utility of the tape-recorded information, the

following questions rises: -

a. If the evidence obtained through electro-magnetic device is primary or secondary

The case of V.V Giri, suggested that the tape-recorded evidence is the first-hand information

of the incident and must be treated as primary and direct evidence. The court held that, the

conversation by stated by the parties connected to the case and the speaker said the facts and it

was received by the receiving party. Hence there is no involvement of any third party. Both the

parties where present in a conversation. This was recapitulated in the case of R.K. Malkani too,

the court stated when a conversation is recorded and audited later, then it can be said that the

supra note at 1

Indian Evidence Act, 1872 § 159

Indian Evidence Act, 1872 § 160

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events of the incident were reproduced and hence be termed as relevant if there hasn’t been

any imposition or cuts of samples in the recorded material.

b. If the evidence obtained through tape recorded material is res gestae or hearsay

Before going into the type of evidence, it is important to understand the material and legitimacy

of the tape recordings. The two material concepts and the veracity of the recordings have

invariably been misunderstood while deciding on the judgements of illegally obtained

evidence. While deciding the case of Magraj Patodia, it was stated, “The fact that a record was

produced through unethical or even illegal means is not a barrier to its validity if it is

appropriate and authentic. However, the conditions in which it appeared to be presented in

court must be kept in mind when reviewing the evidence provided as to its authenticity”

When the court hears a recording, it tries to testify the authenticity and relevancy of the

materials. The materials of tape recording have to be relevant to the subject matter of the case,

if the court validates the reasonableness of the recording, then it can be used as decider to the

case. This appears to violate the ideas of hearsay, because the most typical issue cited when

proof of hearsay is offered is that it has not been utilised to determine the authenticity of its

content.

When the court dilates the tape recording, it utmost factor is to identify two things: -

a. The first is to understand, if the speakers are authentic and legitimate.

b. The latter is to know the motive behind the conversation, to frame an understanding

about how the incident was planned or made.

In this case, tape-recorded testimony was utilised to cross-examine a witness. When the tribunal

explicitly determined that the recording could to understand the events and decide on the matter

as well to examine the motive of the offender, any remaining ambiguity about whether it could

be used to oppose the witness was removed. The court upheld in subsequent case, a tape can

only be confirming evidence and can’t act on its own as sufficient evidence in such case, where

there is absence of any other proof of the contact. Section 91 of the Indian Evidence Act makes

recorded evidence holy. “If the recording is considered as true evidence, the exclusionary rule

of documented evidence will not be enforced.” Furthermore, if the tape is presented for

valuation, the material legitimacy stalemate must first be resolved. It may be easier to take it

Magraj Patodia vs R. K. Birla And Ors, 1971 AIR 1295

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as true facts rather than as a paper. The issues arise here is the evidence has to be classified as

res gestae in order to be regarded as real evidence.

The hypothesis of hearsay, on the other hand, remains largely unexplained. It is important to

notice that the level of proof does not differ between a person who recorded the debate and

who heard the same conversation. The evidence presented by such a person is definitely

hearsay. As a result, it must be omitted. If that is the situation, the tape may also be prohibited

and declared null. “It can only be allowed if an exemption to the rule of hearsay is made, as

was done for dying declaration and res gestae issues.”

JUDICIAL APPROACH TO ADMISSIBILITY OF TAPE RECORDINGS

Ever since its inception, the evidentiary value of the tape-recording evidence has undergone

debates. At one end, it has been heavily criticized and at the same time been in favour of the

guidelines via accepting the recent changes in the formulation of electronic evidence. Here are

the landmark cases that have helped in the evolution and recognition of such postulates.

“R.M. Malkani v. State of Maharashtra”

Here the question centred on the subject of whether a person would be liable to face criminal

charges on some damning aspects of a phone call which he had with another person. The

appellant was residing in Mumbai and wanted a forgery case, “where he attempting to accept

illicit gratuity in the amount of Rs. 15,000 from an honest doctor.” He planned to accuse the

doctor with a false case for being negligent in operation. The doctor wasn’t ready to accept

bribery and instead contacted with police issuing criminal offence. The police had used tape

recorded machines to analyse the conversation. The appellant had a conversation with the

doctor and stated him to donate the amount and place of location etc.

The police took him to custody for bribery offence. The Supreme Court held that, the tapping

of phone by the police didn’t amount to coercion and there was no compulsion which would

lead to altering or impacting the outcome. The court decided that there was no violation of the

Act, however it entertained that the procedure set up was illegal as it violates the right to privacy

Akhilesh Shah, Whether Compact Disc, Tape Recorded Conversation Is A Document And Admissible As An

Evidenc, ITATONLINE (Mar, 20 10:40AM)

https://itatonline.org/articles_new/whether-compact-disc-tape-recorded-conversation-is-a-document-and-

admissible-as-an-evidence/

supra note at 8

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of individuals. The court added, eavesdropping or phone tapping shouldn’t be evidence that

can act on itself and necessarily will not be the only evidence for declaring someone guilty or

innocent. Only government officials have the authority to phone tap but it should be done in a

proper manner with circumspection. The tape-recorded evidence was matched to a photograph

of a relevant occurrence, and “it was determined that Sections 7 and 8 of the Evidence Act,

1872 would not exclude the inclusion of fraudulently obtained evidence.”

“Justice Puttaswamy v. Union of India”

The Supreme Court ruled that privacy is not an absolute right. It is a fundamental right that

includes both physical and private information. It further said that privacy is viewed as a right

controlled by the legal system. Anyone can establish the legitimacy of such restraint by

following fair procedural method on devoid of arbitrariness. However, such evidence are

permissible in the court due to the fact that the fundamental right is not absolute.

CONCLUSION AND SUGGESTIONS

Due to globalization and industrialization, the judiciary has recognized the new forms of

electronic evidence. The admissibility of a tape-recorded evidence varies according to case

because the precision it contains, thereby eliminating the sample of the record or tampering it

with imposing sample to original. A tape-recorded evidence is admissible under Sections 7 and

8 of the Evidence Act, if it adds value to pertinent facts and matches to the image of the alleged

occurrence. The court considers the possibility of a tape recording being changed while

determining admissibility. The conditions mentioned above have to be mandated in order to

have evidentiary value of the recording. The issue of admissibility arises when the recorded

material is produced before the court. The court has the authority to reject such evidence if

certain time frame has been passed or if the authenticity or connectivity to the case is nil or

unsatisfactory.

One of the beneficial and effective improvements brought about by the advancement of

technology is the use of tape-recorded conversations as evidence in court. The Indian Evidence

Act does not clarify on this form of evidence, adding to its uncertainty. Some changes have

Kartik Bhargava, CCTV FOOTAGES AND THEIR ADMISSIBILITY AND RELEVANCY, SCRIBD (Mar 20,

2022, 10:30AM)

https://www.scribd.com/document/486950778/LAW-OF-EVIDENCE-PROJECT

Justice K.S.Puttaswamy(Retd) vs Union Of India, (2017) 10 SCC 1

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been made, but more are needed owing to developments in the domains of cyber law, the

Information Technology Act, and so on. All the advancements and information relating to tape

recorded evidence are explained through court judgements. It is unclear, that recording a phone

call by a party to the conversation without the consent of the opposing side constitutes an crime,

and this has not been decided by a court. There do not appear to have been any documented

prosecutions initiated against a party to the discussion for violating the Telegraph Act. Section

25 of the Telegraph Act, as well as the relevant sections of the IT Act, do not suggest simple

recording of a phone call by one of the parties without the consent is unlawful or not. However,

when the parties couldn’t consent for the same, it violates the right to privacy of that person.

The court also permits illegally obtained recordings admissible if it has authenticity to the case.

Thus, the issue is right to privacy is hampered with inclusion of evidentiary value of tapped

recording. The law makers should analyse the situation better so that the fundamental right of

the citizen isn’t violated, and the justice is delivered in just and fair manner.

Law makers and the courts must look upon dangers of giving the Public Prosecutor broad

discretionary powers to intervene in citizen’s privacy, as this could be immoral, affecting the

private related issues such as sanctity of martial relationship, the confidentiality of business,

and violating the principle of fairness. The researcher would conclude by suggesting that the

government should have strong hold and minimize the illegal access, have a time frame on

retention of data. This would stabilize the shortcomings and help for a better life without the

fear of fundamental rights being violated.

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    Page: 13 
 
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