LAW

Published on
KembaraXtra – Indian Evidence Law – Bharatiya Sakshya Adhiniyam – Difference Between Section 26(b) and Section 28
1. Core Distinction👉 The key difference lies in:
  • Availability of the maker of the entry, and
  • Evidentiary value of the entry

2. Section 26(b) – Statements of Persons Who Cannot Be Called as Witnesses
  • Applies when:
    • The person who made the entry is:
      • Dead, or
      • Cannot be found, or
      • Incapable of giving evidence
Evidentiary Value
  • ✔ Entries are:
    • Substantive evidence
  • ✔ Can be:
    • Sufficient by themselves
    • No strict need for corroboration
👉 Reason:
  • Maker is not available for examination

3. Section 28 – Entries in Books of Account
  • Applies when:
    • Entries are made in books of account regularly kept in business
Evidentiary Value
  • ✔ Entries are:
    • Relevant evidence
  • ❌ Not sufficient alone:
    • Require corroboration
👉 Cannot by themselves:
  • Charge a person with liability

4. Key Differences (Note Form)(i) Availability of Maker
  • Section 26(b):
    • Maker is not available
  • Section 28:
    • Maker may be available as witness

(ii) Nature of Evidence
  • Section 26(b):
    • Substantive evidence
  • Section 28:
    • Corroborative evidence only

(iii) Sufficiency
  • Section 26(b):
    • ✔ Can be sufficient on its own
  • Section 28:
    • Not sufficient alone

(iv) Requirement of Corroboration
  • Section 26(b):
    • ❌ Not mandatory
  • Section 28:
    • ✔ Mandatory

5. Reason for the Difference
  • Under Section 26(b):
    • Law relaxes rules because:
      • Witness is unavailable
  • Under Section 28:
    • Law is stricter because:
      • Entries may be:
        • Self-serving
        • Made by interested party

6. Key Principle👉 Entries made by unavailable persons (Section 26(b)) may be relied upon independently, whereas business account entries (Section 28) require corroboration due to possibility of self-interest.

One-Line Summary👉 Entries under Section 26(b) can be sufficient evidence due to unavailability of the maker, while entries under Section 28 are only corroborative and cannot alone establish liability.
Picture
0 Comments