Difference between Relevancy and Admissibility of Facts
Introduction:
In layman’s understanding of the law, relevancy and admissibility of certain facts before the court will be one and the same thing. But, by diving deeper into the nitty-gritty elucidated by the Indian Evidence Act, 1872, one can easily understand these things as a necessary corollary towards getting the decree/judgment in one’s own favour.
The Indian Evidence Act contains a wide number of situations vide section-5 to section-55 pertaining to the relevancy of certain facts which has some relation with the already admitted fact by the court. On the other hand, latter part of the Act from section-56 onwards, largely deals with the scenario when a certain relevant fact can be admitted by the court keeping in mind the question(s) of law and fact as framed by the court for its due consideration.[1]
To begin with, it can be said that the requirement of fact to be “relevant” is primary hurdle which any assertion of truth supposed to pass. As only then the concerned fact can allowed to be admitted by the court. Furthermore, it has been held that if proving a specific piece of evidence would logically tend to help resolve the main question at trial, that piece of evidence is considered relevant.[2]
Under the provisions of the Evidence Act, a fact that is legally relevant but not sensible may be prohibited from being proven. All admissible evidence is relevant, but not all admissible evidence is applicable. No matter how vital a certainty may be, it is not permissible unless it is authorised to be proved by the procurements of the Evidence Act. All certainties that are allowed to be demonstrated under the procurements of the Evidence Act are important.
The Indian Evidence Act specifies what facts are relevant under Ss. 5-55, but a fact’s sheer logical relevance does not guarantee its inclusion.
Difference between logical and legal relevance:
“A reality that is logically applicable may not be legally pertinent under the provisions of the Evidence Act, and as a result, may be prohibited in proof. All admissible evidence is relevant, but not all relevant evidence as per the provisions of Indian Evidence Act can be considered as legally admissible before the court of law. However, it is not allowable unless it is permitted to be demonstrated by the provisions of the Evidence Act. All certainties that are allowed to be demonstrated under the procurements of the Evidence Act are important. A fact is said to be logically relevant to another when it has a causal relationship with the other that makes the latter’s existence or non-existence likely possible in the presence of other.[3]
Only when a fact is connected to another in one of the ways listed in Sections 5 to 55 of the Evidence Act is it said to be legally relevant.
Every fact that is relevant legally is also relevant logically, but not every fact that is relevant logically is necessarily relevant legally. Logical relevancy is broader than legal relevancy. Therefore, even though a confession given to a police officer might seem logically relevant, it is not legally relevant because S. 25 of the Act states that it cannot be used as evidence against the person who gave it.
What do you mean by admissibility of certain facts before the court of law?
In the most recent case, Ram Bihari Yadav v. State of Bihar,[4] the Supreme Court made the following observation: More often, the expressions ‘relevancy and admissibility’ are used as synonyms, but their legal implications are distinct and different from for more often than not, facts which are relevant are not admissible; so also facts which are admissible may not be relevant, for example, questions permitted to put in cross examination to test the veracity. The weight to be given to the evidence is determined by its probative value, which must be evaluated in light of the facts and circumstances specific to each case.
Despite having a connection to the fact under discussion, a fact may still not be admissible. For instance, even though they may be pertinent, communications between spouses during a marriage, professional communications, and communications made in an official capacity regarding matters of state are not admissible.[5]
It is possible to determine whether or not a specific fact is rationally connected with the main issue based on logic rather than legal standards. In other words, logical relevancy denotes a plausible connection between facts.
Several facts that can be treated as relevant are outlined in Section-9 of Indian Evidence Act of 1872. The court determined the following to be “relevant facts” in the case of Lakshmandas Chaganlal Bhatia v. State:[6]
- Facts need to set forth or clarify a pertinent truth or a fact in dispute;
- Facts that confirm or refute a conclusion drawn from a pertinent fact or a fact at dispute;
- Information that proves the identity of a relevant object or person;
- Facts that specify the moment and location at which any relevant or relevant occurrence occurred;
- Facts demonstrating the relationships between the persons involved in the transaction of any significant or pertinent fact.
The Evidence Act also has a part called Section 11 that addresses admissibility. The facts that are not otherwise important but become so if they contradict other relevant facts or render the existence or non-existence of other relevant facts highly plausible or improbable are covered under Section 11.
Section 11 does have some restrictions, though. In R. v. Prabhudas,[7] it was said that “the court must use sound judgement and ensure that the relationship between the fact to be proven and the fact sought to be provided under S.11 to prove it is so immediate as to render the co-existence of the two extremely plausible.”
Conclusion:
Therefore, in both civil and criminal proceedings, evidence is significant and essential. It is the most important and necessary component of any process. If the facts are accurate and relevant, the evidence should always be allowed in court. All of the specific provisions under the code must be satisfied by the evidence. At the time of admission, logical and legal relevance should both be taken into account. Therefore, only evidence with a strong degree of probative value should be admitted by the courts.
The law governing evidence is out of date and needs to be changed for better functionality. No man should be given the authority to bend the law because it is supreme. Here, the author had dealt with the concepts of legally relevant and logically relevant in this project. Logically pertinent: According to the dictionary, “relevancy” means “the relation of something to the matter at hand,” “pertinence,” “connection,” “materiality,” etc. Logical relevancy refers to the logical relationship between two facts and can be based on a variety of variables. For instance, if a severed body is discovered on a railroad track, it can be assumed that the person was killed when the train ran over them.[8]
When it is discovered that there is no haemorrhage close to the body, the initial inference is replaced by the one that the victim was killed elsewhere and that the body was dumped on the railroad track to give the false impression that he was run over by a train. Here, conclusions are drawn based on logic of cause and effect. It can be assumed that two or more people had a common intention if they committed the crime at the same time and location.
[1] Dr. V. N. Rao, The Indian Evidence Act (1st, LexisNexis Butterworths Wadhwa, Haryana 2012) 41.
[2] Knapp v. State [1907] 522 US 1069.
[3] E. Jain, ‘Difference between ‘Relevancy’ and ‘Admissibility’ under the Indian Evidence Act’ (shareyouressays.com 2005) <http://www.shareyouressays.com/119210/difference-between-relevancy-and-admissibility-under-the-indian-evidence-act> (accessed 15 July 2022).
[4] [1998] AIR 1859 (SC).
[5] M.Monir, Law of Evidence (15th, Universal Law Publishing, New Delhi 2010) 115.
[6] [1968] 69 AIR 807 (Bom).
[7] [1874] 11 AIR 90 (BHCR).
[8] Cook, ‘Evidence Outline’ (wcl.american.edu ) <http://www.wcl.american.edu/sba/outline_databank/outlines/Evidence_Cook_1.pdf> accessed (16 July 2022).
Author: Kumar Aditya,
School of Law, Bennett University, 4th Yr.