One of the most crucial stages of a trial is the recording of the evidence.
Indian courts and tribunals prefer the physical method of recording witness
testimony, but as we all know, there are many cases in which parties or
witnesses were unable to physically appear before the court due to a variety of
reasons, such as the illness of the parties, an overseas witness or party,
physically disabled persons, etc. All of these were obstacles for the parties
and delayed their justice.
To avoid these, there is a way to electronically record evidence and Indian
courts have ruled that video conferencing is a legitimate way to present record
evidence in a number of rulings. However, at the time of the COVID-19 pandemic,
everyone carried their work online, driving the need for video conference
technology in courts and tribunals to serve justice to parties without the
At the midpoint of the COVID-19 pandemic, the Supreme Court highlighted the
importance of video conference technology in such situations and also issued
guidelines, ordering the high court to frame the guidelines regarding the video
conference in the judicial system.
This paper examines the position of Indian law regarding the use of video
conferences for recording evidence, witness examination, general procedural
guidelines, and Telangana guidelines of recording evidence through video
conference. It also provides an overview of the evolution and circumstances of
implementing video conferences in the judiciary system, and how the courts
accepted the method of video conferences in recording evidence.
The implementation of video conferences in the judiciary system is not new to
India; it is used in many other nations, including the USA, Australia, Canada,
and others. The Indian judicial system has been accepting video conferences in
numerous civil and criminal cases for the last two decades.
The government and Supreme Court have expanded the use of video conference in
courts across the nation after the courts and tribunals expressed the value of
the technology in their rulings and awards. This opened the door for amendments
to the laws governing video conferencing in the judicial process.
However the courts have emphasized the value of video conferences in hearings
during the COVID 19 pandemic situations. These circumstances outlined why the
Indian judiciary had a higher need for video conferencing technology. So,
integrating technology into the Indian judicial system won't replace regular
court procedures; rather, it will serve as an alternative. It also helps to
lower barriers to parties, such as cost and distance and improves citizens'
access to justice.
At present video conference is one of the most advantageous methods used in the
Indian judiciary system that has enabled the audio-visual communication between
the parties who are at different locations and also the use of video conference
recording evidence helps to reduce the burden on courts, cost and time for
witnesses who are required to travel for court proceedings.
This paper provides an overview of video conferences in trials, historical
background of video conference in proceedings and provides detailed aspects of
legal recognition of video conference and Telangana guidelines about video
conference in judicial proceedings. It also examines how the various courts
accepted the method of video conference in a number of rulings.
A Brief Historical Background of Video Conference in Indian Judiciary System:
In the Indian judiciary system there is no particular legislation regarding the
usage of video conference in judicial proceedings but through the various
judgements of Supreme Court and high court recognized the need of video
conference in judiciary proceedings and discussed the circumstances of
implementation of video conference in trials. However these judgements only
paved the way to certain amendments for video conference proceedings.
In 2002, Saleem bar association v. union of India
[i] was the first case
which allowed the use of video conference in civil cases during the stage of
recording the evidence under CPC. A year later in the State of Maharashtra v.
Dr. Praful Desai
[ii] judgement the Supreme Court interpreted the order 18
rule 4(3) states the examination of witness, in this court or commissioner can
record the evidence either in writing or mechanically in the presence of judge
While interpreting this provision the Supreme Court held that the word
mechanically includes the audio- visual apparatus. Apart from recording evidence
through video conference, the high court allowed a petition which filed for
cross-examining the witness through video conference who was located in the
United States and also several safeguards of audio-visual examination of
witness, filing of an affidavit, administration of oath.
However, the use of video conferences in trials is not limited to civil cases.
In the state of Maharashtra v. Dr. Praful Desai
the apex court held that
the presence of the accused does not only means that physical appearance which
mandated the presence of accused under section 273 of code of criminal procedure
and the court allowed the video conference at the stage of recording evidence in
a criminal trial.
In criminal cases judges often use the video conference in remands, bail
application, examination of witnesses and in the sensitive matters.
Subsequently, the section 164(1) of Cr.P.C. was amended in 2009 and according to
the amended provision that any confession or statement made under this
subsection may also be recorded by audio- video electronic means in the presence
of the advocate of the accused person in the offence.
In 2017, Supreme Court in Santhini v. Vijay Venkatesh
permitted the video conferencing in matrimonial cases instead of transferring
the suit. If the parties are located outside the jurisdiction of court, then it
is an alternative to the transfer petition. Now, in different parts of the
country courts are using the technology for recording the evidence and cross
examination of witnesses.
Introducing the video conference mechanism in trails helps to avoid delay and
travel expenses. In the wake of covid 19 pandemic situation 2020, Supreme Court
directed to start the using of video conference and ordered high courts to make
the proper rules and guidelines of using video conference in judicial
Video conferencing is an interactive form of communication that enables two or
more people to communicate face-to-face via voice or video at the same time
without physically being present together.
Conduct of Judicial Proceedings through Video Conference [iv]:
All stages of the legal process can use video conferences, and all the rules
that apply in a physical courtroom also apply in a virtual one. These rules and
guidelines allow the court to use video conferences for hearing arguments,
recording evidence, and at both the trial stage and the appellate stage.
Circumstances of implementing the video conference in a suit:
Video conference can be implemented in the following circumstances:
Physical appearance is an exception in instances where a matter comes as an
emergency and parties have to present an application to the court with
justifications for using a video conference. When a court chooses to use a video
conference to conduct the proceedings, the court must take precautions in
enforcing the law and must safeguard the parties' interests and rights.
For instance, in a civil case whenever a party tries to alienate the suit's
schedule property, just as in criminal cases involving rape victims, bail
applications, and matrimonial cases involving restraining orders or child
possession. In these conditions, the situation qualifies as an emergency, and an
expeditious decision must be made to prevent damage to the parties. So whenever
there is urgency in a suit parties can avail the video conference facility by
filing an application to the court.
Overseas or Outstation of Parties:
When parties or witnesses live in another country and are unable to physically
attend court, they have the option of appearing before the court via video
conference, in which the case will continue without delay.
Crimes against Women:
A woman who has been the victim of a heinous crime may not be able or willing to
appear in court. In order to safeguard the victim from the offender, she is
permitted to use video conferencing or in-camera proceedings which exist to make
her statements. Examples: POCSO and rape cases.
By application of parties or suo moto of court:
Court hearings may be held via video conference either on its own or at the
request of parties. The consent of both parties should be required whenever
parties choose to request virtual proceedings from the appropriate judge. After
hearing arguments from both parties, the judge decides whether to grant or
reject the application with reasons.
Sickness of Parties:
When a required party or witness is ill and unable to appear in person before
the court, the judge may authorize the order for such a party to appear, present
evidence, or undergo questioning via video conferencing.
In addition to the aforementioned scenarios, the court may permit video
conferences between the parties during a suit depending on the facts and
Recording of Evidence and Cross Examination of Parties via Video Conference:
The concept of recording evidence and conducting cross-examination of witnesses
via video conference is not new to the courts, and from time to time the Supreme
Court has been framing guidelines regarding its use in proceedings. During the
Covid 19 pandemic, physical hearings were not possible, which resulted in a
delay in the administration of justice to the parties. In these circumstances
the best option to regular court proceedings is the conduct of proceedings via
Therefore, as part of its authority under Article 142 of the
Indian Constitution, the Supreme Court issued an order to high courts directing
them to establish rules and safeguards regarding the use of video conferences in
legal proceedings for the administration of justice without delay and allowed
the courts to conduct trials through video conference.
Even with the absence of a specific statute governing the use of video
conferences in trials, numerous landmark decisions have established rules and
safeguards that govern the implementation of video conferences in the judiciary
system. These decisions have also paved the way for amendments pertaining to the
video conference. However, it is evident that video conferencing can be used to
record evidence and conduct witness cross-examination in the proceedings; this
was upheld in a number of Supreme Court and high court rulings.
Laws and Guidelines Which Are Talks about the Use of Video Conference for
Recording Evidence and Cross Examination:
The court either by the application of parties or on its own motion directs the
parties or witnesses to appear before the court through video conference. The
relevant statutory provisions applicable to judicial proceedings including
provisions of CPC (order16 & 18), CRPC, Contempt of court, Indian evidence act
1872 and information technology act 2000 shall apply to the proceedings
conducted by video conference.
Evidence Act 1872[v]:
Unless there is a mandatory requirement in the law or an agreement between the
parties that requires them to physically appear before the court, evidence may
be recorded via video conference. The court will reject the application whenever
it believes that doing so will jeopardize the interests of the parties and the
rule of law. In addition to these, every court should abide by the CPC, Crpc,
Indian Evidence Act of 1872, and any current SC and HC guidelines before
approving a request to use videoconferencing in proceedings.
Evidence encompasses both oral and documentary evidence, according to section 3
of the Indian Evidence Act of 1872. Documentary evidence in this context refers
to all document materials including electronic records, submitted to the court
for inspection. It is divided into two categories: primary evidence and
Primary evidence (section 62) - the documents itself (originals) produced before
the court for inspection.
Secondary evidence (section 63) - secondary evidence is nothing but all the
copies made from or compared from the originals and also any certified copies
issued by authorised representatives consistent with law.
Sections 65(A) and 65(B) of the Evidence Act of 1872, which speak about any
evidence recorded in electronic form coming under electronic evidence and being
treated as documentary evidence, were inserted in 2000, marking a significant
amendment to the law. It implies that all electronic data, including hard discs,
SD cards, memory cards, pictures, music, and video, falls under the category of
electronic evidence, which is regarded as the main source of proof. If any
copies are made from those SD cards or hard discs, those copies are regarded as
By analysing the provisions and amendments it is clear that recording the
evidence through video conference is permissible and admissible in the court of
Code of Civil Procedure [vi]:
By amending the code of civil process in 2002, order 18 rule 4(3) was inserted,
it has laid the foundation for implementing the use of electronic recordings
made during video conferences as evidence in accordance with section 65(B) of
the Indian Evidence Act of 1872. Significantly, rule 4(3) of order 18 allows the
recording of evidence orally or mechanically in the presence of the judge or
commissioner, as the case may be and also the code of civil procedure's Order 18
Rule 13 acknowledges the value of mechanically documenting evidence.
Code of Criminal Procedure [vii]:
Sections 275(1) and 164(1) of the Code of Criminal Procedure were introduced by
the 2009 amendment.
This states as follows:
Section 275(1) talks about the evidence of witnesses under this subsection that
can be recorded by audio-visual form in the presence of the advocate of the
person accused of an offence
Section 164(1) of code of criminal procedure was amended in 2009, provided that
any confession or statement made under sub section may also be recorded by
audio- video electronic means in the presence of the advocate of the person
accused of an offence.
Here as per section 273 of CrPC evidence must be taken in the presence of the
accused but here presence of accused doesn't mean actual physical presence, the
evidence may also be taken in the presence of advocate of accused. The Supreme
Court also permitted recording of evidence of witnesses staying abroad through
video conference- this was held in the case of state of Maharashtra v. Dr.
Praful Desai and Anr.
As a result, all the statutory provisions from section 277
to 283 of Cr.P.C. applicable to proceedings conducted via video conference same
as applies to normal court proceedings.
Telangana Rules for Recording Evidence and Examination of Witness via Video
In chapter III of Telangana rules for video conference discuss about the
procedure for video conference.
Video Conference in Matrimonial Cases:
- Any party in the case or witness may apply to the concerned court for a
recording of the evidence or examination of the parties through video
conference. Except in cases where it is impossible, such as urgent
applications, a request for video conferencing should be addressed with
another party to the proceedings initially. The court will make a decision
in response to such a request once it has determined that the application
was not submitted with the purpose to impede proceedings or obstruct a fair
trial also the courts have the power to decide the video conference
timetable while granting such requests.( rule 6 of Telangana Guidelines for video conferencing for courts )
- The witness who's going to be questioned via video conferencing receives
a summons that specifies the time and location of the relevant remote point
and instructs the witness to appear with identity proof. Regarding the
summons and absence of witnesses, the CPC and CrPC's existing regulations will apply. ( rule
7 of Telangana guidelines for video conferencing for courts)
- Examination of parties or witnesses - Any individual, who is being
questioned, including a witness, will be questioned via video conference. In
order to prove their identity, they must either present an identity document
or, in the absence of identity proof, an affidavit attested by one of the
relevant authorities. A copy of identity proof or affidavit will be given to
the opposite party. ( rule 8 of Telangana guidelines for video conferencing for courts)
- The person who is going to be examined will be questioned during the
court's normal working hours. The coordinator at the court point will
administer the oath. ( rule 8.2)
- The relied-upon documents must be sent to the applicant before the
witnesses are questioned, and if a witness is summoned to give evidence in
relation to a specific document, the summons must be served to the witness
along with a properly certified copy of the document (rule 8.5). The court
will take notice of any objections the person raised at the time of the
examination.( rule 8.7 )
- The subject of the examination will read the deposition and sign it once
the examination is completed. The signed transcript's hard copy will be
delivered to the appropriate judge by courier or registered speed post.
- The examination must continue uninterrupted and without being extended
unnecessarily. Depending on the circumstances, the court or commissioner
will decide whether to grant an adjournment.
- The provision of CPC, CrPC, Indian Evidence Act 1872, and contempt of court
act and information technology will apply while examining a person through video
conferencing. ( rule 3 (iii) )
- When a person is physically unable to travel to the court or a remote
location or when their presence cannot be secured without undue delay or
cost, the court permits video conferencing to take place from the location
where they are. ( rule 8.15 )
- It must be noted in the order sheet whenever any procedures are
conducted via video conference.
- Before making any decision or issuing an order, the chairman/secretary
of the district legal service authority, the taluk legal service committee, or
members of the Lok Adalats must examine the person if the proceedings were
connected to legal aid clinics or Lok Adalats.
- A copy of the award or order and a record of the proceedings will be
sent to the remote location. Such awards or orders shall have the same
effect as if they were issued by a regular Lok Adalat or Jail Adalat.
The family courts in India have been using video conference in all marital
disputes and the use of video conferences in divorce cases before family courts
has been approved in a number of cases handled by the Supreme Court, but it has
been prohibited in transfer petition cases.
The various landmark judgments given by the Supreme Court explained the use of
video conference in matrimonial matters, in the Krishna Veni Nigam V. Harish
Nigam 2017[ix] case the Supreme Court granted the petition for a transfer and
explained the conditions under which it would be granted, along with an
However, the Supreme Court was of the opinion that considering such
a transfer petition would delay the administration of justice, so it directed
all high courts to issue administrative orders to maintain and regulate the use
of video conferences in specific circumstances. The courts should have certain
safeguards in place for matrimonial cases involving parties who reside outside
of the court jurisdiction, such as the availability of video conferencing,
access to legal counsel, and a contact email or phone number. Doing so helps to
prevent the denial of justice to either party.
However, the Supreme Court in Santhini v. Vijay Venkatesh case
Krishna Veni Nigam V. Harish Nigam
. In Santhini case, Supreme Court held that
the compliance of section 11 of family court act 1984 proceedings of matrimonial
disputes may have to be conducted in camera. The application for conducting
proceedings via video conferencing is only permitted after the parties have been
unable to reach a settlement through mediation or conciliation.
At that point,
the parties must file the application jointly or both parties must agree to file
it before the relevant family court, which the court may do at its discretion.
Aside from this, the Supreme Court clearly stated that video conferences were
not permitted in transfer petitions unless they were jointly submitted by both
At the same time the Supreme Court ordered all family courts to use video
conferencing to conduct trials in the case of Anjali Brahmavar Chaun v. Navin
[x] because physical court proceedings at the time of pandemic COVID 19
were not feasible and could cause delays for the parties. In order to avoid
these delays, the court used video conference technology in such situations.
Although video conferencing is an old method in many nations, the pandemic in
our country emphasised its significance in the judicial system. As a result, our
judiciary system became more flexible and in various judgements the court
permitted the use of video conference in proceedings.
General Guidelines for the Conduct of Judicial Proceedings through Video
When a lockdown was imposed in India due to COVID 19 everything was done online,
and even the courts admitted using video conferences to conduct proceedings
because the litigants shouldn't have to wait for justice to be served.
result, the Supreme Court of India ordered all high courts to establish
guidelines governing the use of video conferences for conducting proceedings in
accordance with Article 142 of the Indian Constitution. The primary reason for
establishing such rules is to prevent litigants and attorneys from physically
appearing before the court when it is necessary to maintain social distance. It
also ensures that litigants can obtain justice without delay.
However, there is no specific law that explains the use of video conferences in
judicial proceedings; rather, the Supreme Court and high court established
general guidelines and rules in a number of decisions made during the COVID 19
The following is a summary of the guidelines issued on how to conduct
proceedings via video conference:
Challenges in Recording Evidence through Video Conferencing [xii]:
- The courtroom or other locations where the court conducts its
proceedings are referred to as "court points" in the High Court Rules.
The location of the person and/or witness who will be cross-examined via
video conference will be the "remote point," which may also be the
location of an official (commissioner) designated by the court to record
the evidence and statements.
- Person to be examined is the one whose deposition or statement must
be recorded, or whose presence must be recorded during certain
- As per the possibility, video conference proceedings shall be
treated and conducted as typical court proceedings, and the established
protocols and courtesies shall be observed precisely as if they were to
be observed in person in a court. In such video conferences, all
statutory provisions that apply to such procedures, including those of
the Information Technology Act of 2000 and the Indian Evidence Act of
1872, shall apply equally.
- A video conference facility can be used in many cases, such as
remands, civil and criminal trials, bail applications, etc., where a
witness is located interstate, intrastate, or abroad, excluding the
procedures mentioned under section 164 of the CrPC.
- The guidelines applicable to the Court will apply to a local
commissioner appointed by the court to record the evidence.
Current Scenario of Use of Video Conference in Indian Judiciary:
- Absence of clearly laid down procedures for video conferencing
- Lack of infrastructure
- Lack of fluency with the technology
- Evaluation of witnesses
However, as of September 2021, the COVID-19 pandemic had greatly increased the
use of video conferencing in legal proceedings in India. Both regular and urgent
hearings in the Indian judiciary, including those in the Supreme Court and
different high courts, have been conducted via video conferencing.
Video conferencing has made it possible for the judicial system to continue
operating while upholding social distance protocol and lowering the risk of
virus transmission. Access to justice has been improved, especially for those
who live in remote or underserved areas, due to the use of video conferencing,
which has also made it possible for attorneys and litigants to take part in
Concerns have been voiced, though, about the use of video conference in the
Indian judicial system. Some people have voiced concern over the lack of
adequate technological infrastructure, which could cause delays or disruptions
in proceedings. Concerns have also been raised regarding the fairness and
confidentiality of the video conferencing-based trials.
Overall, the Indian
judiciary's use of video conferencing has been a crucial response to the
challenges posed by the epidemic. It has improved access to justice and
supported the judiciary's ongoing activities. To ensure that the use of video
conferencing in legal processes is fair, effective, and efficient, it is
necessary to address the difficulties and concerns expressed.
- State of Maharashtra v. Dr. Praful Desai and Anr 2003 4 SCC 601[xiii]
Facts of the case:
Dr. Ernest Greenberg of Sloan Kettering Memorial Hospital in New York, USA,
examined the complainant's wife, who had terminal cancer, and concluded that she
should only be given medication. They later consulted with the respondent, a
surgeon with 40 years of experience, and despite being aware of Dr. Greenerg's
view; the respondent proposed removing the uterus surgically.
Dr. Mhukerjee operated on the complainant's wife, when the stomach was opened
during the complainant's wife's surgery, ascetic fluids oozed out of the belly.
Dr. Mukherjee then contacted the respondent and proposed closing the stomach.
After the surgery, the complainant's wife passed away and endured physical
torture and mental suffering.
The complainant brought a lawsuit against the respondent, who claimed that the
complainant's wife is not his patient. However, the respondent's fees were shown
on hospital bills in Mumbai.
- Can evidence be reliably and effectively recorded through video conferencing in
a criminal trial?
The court held that the video conferencing recording evidence satisfied the
requirements of section 273 of the criminal process code. With the development
of science and technology, it was now possible to install video conferencing
equipment within the courtroom, where testimony could be recorded by the
magistrate or taken down while he dictated in front of the court.
of Section 273 of the Criminal Procedure Code would thus be entirely satisfied
if that was done. It was further stated that the court could consider issuing a
commission to record evidence by way of video conferencing in cases where the
attendance of a witness cannot be procured without an amount of delay, expense,
The Supreme Court further added that cross-examination could be conducted in
front of the court's presiding officer or could be recorded by a commissioner
appointed by the court after the documents were filed in court along with the
affidavit and the court had determined their relevance and admissibility. The
court also permitted video conferencing to be used to record the testimony of
witnesses who were abroad.
- Twentieth Century Fox Film Corp. Vs. NRI Film Production Associates (P) Ltd
2003 AIR 2003 Kant 148, 2003 (5) KarLJ 98[xiv]
The words "Witness in attendance" are to be understood as a person being present
and it need not be physical presence, according to the High Court of Karnataka's
ruling in a matrimonial matter. Order 18 Rule 4 CPC once contemplated hearing
suit, examination of witnesses, and recording of evidence by the commissioner.
As a result, recording evidence via an audio or video link is acceptable as long
as it complies with the rules for in-person testimony. The two ends would be in
real-time communication. The image would also be captured, along with everything
else. The Court would then have access to see this. Additionally, there would be
recording on both ends and this reduces the danger of losing recorded data.
The Judge further noted that Order 18, Rule 3(4) (3) allows for the mechanical
or written recording of evidence in front of a judge.
- Amitabh Bagchi Vs Ena Bagchi 2004 AIR 2005 Cal 11, (2004) 3 CALLT 263 HC[xv]
In this case the court held that physical presence does not always imply the
actual physical presence in court. It is important to keep in mind that, as a
result of an amendment and addition to Sections 65A and 65B of the Evidence Act,
a special provision regarding electronic record evidence and the admissibility
of electronic records was introduced as of October 17, 2000. The court decided
that "presence" does not always imply actual physical presence in court.
- Bodala Murali Krishna v. Smt. Bodala Prathima on 11 October, 2006 AIR 2007 AP
In this case, the petitioner is the respondent's husband; they were married in
1977 and blessed with a child. The petitioner is a resident of the USA, and
wants to use video conferencing to record his evidence during the trial. The
application was denied by the trial judge, and a CRP was filed.
It was held that video conferencing for the purpose of recording proof was legal
as long as the necessary precautions were taken.
It is the petitioner's responsibility to set up the required technology for
video conferencing, and to satisfy the trial court as to the equipment's
accuracy and the witness' identity: The petitioner will be required to show the
passport and any of its pages upon request, and he must follow any instructions
the court issues while the case is being recorded.
- There is no specific law governing the use of video
conferences in the judicial system, despite the fact that
the Supreme Court and high court have established rules,
guidelines, and protections regarding their use in
proceedings in their judgements. Therefore, there is a need for special
legislation to allow for the use of video conferences in legal proceedings.
Statutory recognition will also help to clarify all concerns about when, where,
and how to use a video conference in a legal proceeding as well as the rights,
obligations, and process for doing so.
- Additionally, there is a need to strengthen privacy
protection for parties, e-filings, case document management,
and evidence management, all of which are crucial for the
success of the virtual court system. With the help of this
virtual court system, delays and costs are dropped
significantly. In addition, it assists parties who are
physically unable to appear in court due to a disability,
residence outside of the court's jurisdiction, or illness
and whose case may be dismissed for default or exparte decree in such cases. In these
situations, the video conference will help in the dismissal of the lawsuit and
there will be no delay in the administration of justice.
- Video conference awareness schemes- will educate parties
who are not familiar with legal procedures about the
possibility of using a video conference facility rather than
physically presenting in court when they are unable to
attend in person.
The use of video conferencing in Indian courts has significantly increased in
response to the COVID-19 pandemic to ensure that the legal system continues to
operate without endangering the health and safety of those involved. A number of
high courts, including the Supreme Court of India, have given directives and
orders regarding the use of video conferencing for remote hearings and trials.
It has been acknowledged as a valuable tool that has helped to improve access to
justice for many people, particularly those in remote or underserved areas,
despite some difficulties and concerns raised about its use in the Indian
judiciary, such as connectivity, security, and issues with fairness in
Overall, the Indian judiciary's use of video conferencing has
been a necessary response to the evolving conditions brought on by the pandemic,
and its ongoing use may have the potential to enhance the effectiveness,
accessibility, and cost-effectiveness of the legal system in the future.
Written By: Syam Priyanka Badri,
- [i]AIR 2003 SC 189
- [ii]2003 1 SCC 49, para https://tta.co.ke/case-brief-the-state-of-maharashtra-vs-dr-praful-b-desai-20034-scc-601/
- [iii]2018 1 SCC 1 https://www.shoneekapoor.com/santhini-versus-vijay-venkatesh/
- [iv] Paper 4 video conferencing in Indian courts: a pathway to the justice platform; daksh https://dakshindia.org/wp-content/uploads/2020/06/Paper-4-_Video-Conferencing-in-Indian-Courts.pdf
- [v]Section 62, 63, 65(a) and 65(b) of Indian evidence act 1872 https://www.indiacode.nic.in/handle/123456789/2188?sam_handle=123456789/136
- [vi]Order 18 rule 4 and 13 of code of civil procedure 1908 https://www.indiacode.nic.in/bitstream/123456789/11087/1/the_code_of_civil_procedure%2C_1908.pdf
- [vii]Section 164(1), 273 and 275(1) of code of criminal procedure 1973 https://indiankanoon.org/doc/445276/
- [viii]Chapter 3, rule 3, 6, 7, 8 and 15 of Telangana Guidelines for video conferencing for courts https://tshc.gov.in/documents/admin_17_2020_10_27_13_24_46.pdf
- [ix]2017 4 SCC 150 https://indiankanoon.org/doc/43287493/
- [x]2021 SCC online SC 38 https://indiankanoon.org/doc/152016905/
- Recording evidence by video conferencing. [Internet]. [cited7 August
2020]Available from: https://singhania.in/recording-evidence-by-video-conferencing.
- Dr. Prafulll desai v. state of maharastra https://tta.co.ke/case-brief-the-state-of-maharashtra-vs-dr-praful-b-desai-20034-scc-601/
- Twentieth Century Fox Film Corp. Vs. NRI Film Production Associates (P) Ltd
2003 AIR 2003 Kant 148, 2003 (5) KarLJ 98 https://indiankanoon.org/doc/212550/
- Amitabh Bagchi vs Ena Bagchi on 16 February, 2004 https://indiankanoon.org/doc/390051/
- Bodala Murali Krishna v. Smt. Bodala Prathima on 11 October, 2006 AIR 2007
College Name: ICFAI Law School