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KembaraXtra – Indian Evidence Law – Bharatiya Sakshya Adhiniyam – Declaration Against the Interest of the Maker (Section 26(c))

1. Basic Principle of Section 26(c)Under Section 26(c) of the Bharatiya Sakshya Adhiniyam, the law provides that:
A statement made by a person who is dead or unavailable is relevant if it is against his own interest, i.e., it:
  • Affects his pecuniary or proprietary interest, OR
  • Exposes him to civil or criminal liability

2. Underlying Principle👉 A person would not normally make a statement against his own interest unless it is true.
  • Such statements are considered:
    • Trustworthy and reliable

3. Essential Conditions (Note Form)For admissibility under Section 26(c):
  • Unavailability of Maker
    • Person must be:
      • Dead or cannot be found
  • Personal Knowledge
    • Maker must have:
      • Direct knowledge of the facts
  • Statement Against Interest
    • Must:
      • Harm his own:
        • Financial (pecuniary) interest
        • Property (proprietary) interest
        • Legal position (civil/criminal liability)
  • Awareness
    • Maker must:
      • Know that statement is against his interest

4. Types of Interests Covered
  • Pecuniary Interest
    • Financial loss or liability
  • Proprietary Interest
    • Ownership or property rights
  • Legal Liability
    • Exposure to:
      • Civil or criminal consequences

5. Illustration from Case LawIn Bhim Singh v Kan Singh:
  • Deceased admitted:
    • Property was purchased in another’s name
    • Intended to make him real owner
👉 Court held:
  • Statement was:
    • ✔ Against proprietary interest
    • ✔ Therefore relevant evidence

6. Correlation with Section 19 (Important Note)Section 19 (Self-Serving Statements)
  • Generally:
    • ❌ Not admissible in favour of maker

Exception via Section 26(c)
  • If statement:
    • Is against interest
👉 Then:
  • ✔ Admissible:
    • In favour of:
      • Maker
      • Representative
      • Third parties

7. Evidentiary Value
  • ✔ Treated as:
    • Substantive evidence
👉 Because:
  • It carries:
    • Inherent reliability

8. Key Legal Principle👉 A declaration against interest is admissible because it is unlikely that a person would falsely make a statement detrimental to himself.

9. Purpose of Section 26(c)
  • Recognizes:
    • Statements made under:
      • Natural human conduct
  • Provides:
    • Reliable evidence when:
      • Maker is unavailable

10. Key Takeaways
  • Section 26(c) deals with:
    • Statements against interest
  • Conditions:
    • Personal knowledge
    • Awareness of prejudice
  • Value:
    • ✔ Highly reliable
    • ✔ Substantive evidence

One-Line Summary👉 Statements made by an unavailable person against his own pecuniary, proprietary, or legal interest are relevant and considered reliable evidence.
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