Dream11 IPL 2020 RCB Probable XI – Devdutt Padikkal, Aaron Finch, Virat Kohli (c), AB de Villiers (wk), Gurkeerat Singh Mann, Shivam Dube, Washington Sundar, Isuru Udana, Navdeep Saini, Adam Zampa, Yuzvendra ChahalCSK vs RCB in IPL 2020 LIVE: Where to catch CSK vs RCB Live Streaming?The match between CSK vs RCB will be live broadcasted on Star Sports Network in the Indian Sub-Continent. The CSK vs RCB will also be Live Streamed on Disney+ Hotstar.IPL 2020 CSK vs RCB Weather forecast TAGSChennai Super Kings and Royal Challengers BangaloreCSK vs RCB Dream11CSK vs RCB Fantasy Playing TipsCSK vs RCB LIVE at 7:30 PMCSK vs RCB Pitch ReportCSK vs RCB Probable XICSK vs RCB Toss TimingCSK vs RCB Weather forecastIPL 2020 SHARE By Kunal Dhyani – October 9, 2020 Euro 2020, Switzerland vs Turkey: Top 5 players to watch out for in SUI vs TUR Formula 1 Previous articleWWE Smackdown results and confirmed matches October 09th, 2020 episode: Women’s Championship match, WWE Draft, full Schedule, spoiler, match card, Predictions, SmackDown Live time; check details hereNext articleNadal in French Open finals, beats Schwartzman in straight sets Kunal DhyaniSports Tech enthusiast, he reports on Sports Tech industry and writes on sports products. by Taboolaby TaboolaSponsored LinksSponsored LinksPromoted LinksPromoted LinksYou May LikeIPL 2020: Bad news for Sunrisers Hyderabad’s Jonny BairstowUndoIPL 2020 : Srikanth and fans slams MS Dhoni, says ‘wasted 15 Cr on Jadhav & Chawla’UndoSuresh Raina issues statement after arrest, says the incident in Mumbai was ‘unintentional’UndoIPL 2020 Chennai Super Kings and Royal Challengers Bangalore (CSK vs RCB) LIVE Score– https://www.insidesport.co/sport-matches/?field=entity_cricket&id=45611&widget=match_centerIPL 2020 Chennai Super Kings and Royal Challengers Bangalore (CSK vs RCB) LIVE Commentary – https://www.insidesport.co/ipl-2020-match-no-25-chennai-super-kings-vs-royal-challengers-bangalore/IPL 2020 CSK vs RCB Dream11 Team Prediction IPL 2020 LIVE Match Details PSL 2021 Playoffs Live: How to watch PSL 2021 Playoffs LIVE streaming in your country, India Suggested Playing XI for CSK vs RCB Dream11 Fantasy Cricket: Football Euro 2020: Didier Deschamps offers Ousmane Dembele update ahead of Portugal match Football ATP Tour Football Euro 2020, North Macedonia vs Netherlands: Top 5 players to watch out for in MKD vs NED Euro 2020, Italy vs Wales: 3 key battles to watch out for in ITA vs WAL RELATED ARTICLESMORE FROM AUTHOR F1 French GP 2021: Max Verstappen pips Lewis Hamilton to win French GP, Perez finishes 3rd Euro 2020, Italy vs Wales LIVE: Verratti returns for Italy, Ampadu starts for Wales, check full line-ups; Follow Live Updates, Football IPL 2020 CSK vs RCB Dream11 Prediction: Chennai Super Kings and Royal Challengers Bangalore, Weather forecast, Pitch Report, Captain, Fantasy Playing Tips, Probable XI – CSK vs RCB LIVE at 7:30 PM IST Friday OCT 10 on Insidesport Captain and Vice-Captain Selection:Captain Options – Shane WatsonVice-Captain Options – Devdutt PadikkalSuggested Playing XI for CSK vs RCB Dream11 Fantasy Cricket:Wicketkeeper: AB de VillersBatsmen: Aaron Finch, Shane Watson(C), Faf du Plessis, Devdutt Padikkal(VC), Virat KohliAllrounders: Sam Curran, Ravinder JadejaBowlers: Shardul Thakur, Deepak Chahar, Yuzvendar Chahal IPL 2020 CSK vs RCB Dream11 Team: Fantasy cricket predictions and tips for Chennai Super Kings and Royal Challengers Bangalore IPL 2020: 24th match of the Indian Premier League (IPL) 2020 will be played between the Chennai Super Kings and Royal Challengers Bangalore (CSK vs RCB)IPL 2020 CSK vs RCB Live : Dream11 Prediction – Chennai Super Kings and Royal Challengers Bangalore Football Euro 2020, Switzerland vs Turkey LIVE: Switzerland to punish hapless Turkey; Follow Live Updates CricketIndian premier leagueIndian premier league 2020SportSport News Facebook Twitter YourBump15 Actors That Hollywood Banned For LifeYourBump|SponsoredSponsoredUndoPast Factory4 Sisters Take The Same Picture For 40 Years. Don’t Cry When You See The Last One!Past Factory|SponsoredSponsoredUndoDefinitionTime Was Not Kind To These 28 CelebritiesDefinition|SponsoredSponsoredUndoPost FunThese Twins Were Named “Most Beautiful In The World,” Wait Until You See Them TodayPost Fun|SponsoredSponsoredUndoFreight & Shipping Quotes | Search AdsResearch & Compare Freight & Shipping QuotesEnjoy Affordable Freight & Shipping Services With These Service ProvidersFreight & Shipping Quotes | Search Ads|SponsoredSponsoredUndoDaily FunnyFemale Athlete Fails You Can’t Look Away FromDaily Funny|SponsoredSponsoredUndo Football It’s going to be a sunny day with no chances of rain playing spoilsport for the CSK vs RCB IPL 2020 opener. The highest temperature will be around 38°C while the minimum temperature will be around 28°C.IPL 2020 CSK vs RCB Pitch Report The stadiums across UAE will be slow and spin friendly. Both CSK vs RCB will expect their spin stars to make the most of the conditions which will be in favour of them.IPL 2020 Dream11 Fantasy League CSK vs RCB PLAYING 11 Football Match: Chennai Super Kings and Royal Challengers Bangalore (CSK vs RCB)Date: 10th Oct 2020Time: 7:30 PM ISTDream11 IPL 2020 Chennai Super Kings and Royal Challengers Bangalore (CSK vs RCB) Probable XIDream11 IPL 2020 CSK Probable XI – Shane Watson, Ambati Rayudu, Faf du Plessis, MS Dhoni (C)(WK), Sam Curran, Kedar Jadhav, Dwayne Bravo, Ravindra Jadeja, Piyush Chawla, Shardul Thakur, Deepak Chahar. Queens Club Final: Matteo Berrettini beats Cameron Norrie in final to win title Share on Facebook Tweet on Twitter Euro 2020 LIVE broadcast in more than 200 countries, check how you can watch Live Streaming of EURO 2020 in your country Football
Tullow Oil Plc (TLW.gh) listed on the Ghana Stock Exchange under the Energy sector has released it’s 2019 presentation For more information about Tullow Oil Plc (TLW.gh) reports, abridged reports, interim earnings results and earnings presentations, visit the Tullow Oil Plc (TLW.gh) company page on AfricanFinancials.Document: Tullow Oil Plc (TLW.gh) 2019 presentation Company ProfileTullow Oil Plc is the largest independent oil and gas exploration and production company with operations in Africa, Europe, South Asia and South America. The company has a portfolio of over 120 licenses spanning 22 countries; including multi-well operations in Ghana and Uganda. Tullow Oil Plc was founded by Aidan Heavey in 1985 in Ireland as a gas exploration business operating in Senegal. Acquisitions of BP’s North Sea Gas Fields in 2000, Energy Africa in 2004 and Hardman Resources in 2007 greatly enhanced the Group’s operations in Africa and Mauritania and added high-impact exploration licenses in South America. The company head office is in London, United Kingdom. Tullow Oil Plc is listed on the Ghana Stock Exchange
8 Rhys Oakley16 Andy Titterrell17 Mike Macdonald18 Jesus Moreno Rodriquez19 James Craig20 Daniel Browne21 Alex Black22 Ceiron Thomas23 Oliver DentonYou can follow all the action from Bucharest at www.leedscarnegie.com throughout Saturday afternoon with a regularly updated match report throughout the game also there will be match updates appearing on the official club Twitter page at www.twitter.com/carnegierugbyLeeds Carnegie Head Coach Neil Back looks ahead to this Saturday’s Amlin Challenge Cup opening game at Bucharest Oaks, kick off 1pm GMT.How are you approaching this weekend’s game?We have made no secret that our focus this season is on consolidating and building on our achievements last season in the Aviva Premiership. However, the Amlin Challenge Cup gives us an chance to give some game time to players who have been desperate to play in the first five rounds of this season. European competition does bring with it different kinds of challenges that can help freshen things up and we are looking forward to the trip to Romania.Are Bucharest an unknown quantity for you?We haven’t been able to get hold of any footage of them from this season however we obviously played against them last season and the squad looks very similar so we have some idea. Their number eight, who ran the game for them the last time we were in Bucharest, is no longer at the club so that is one threat we do not need to worry about however I am sure they will be wanting to put in a strong performance in their opening game of the competition.In many ways this is similar to how rugby used to be before all the analysis and research on the opposition. You have to just worry about yourself and making sure you are ready to perform regardless of the side you face. You have to react and adapt to what is thrown up and that is what we will be looking for from the players on Saturday. LATEST RUGBY WORLD MAGAZINE SUBSCRIPTION DEALS Leeds Carnegie ShirtLeeds Carnegie coaching duo of Andy Key and Neil Back have named a strong line up for their side’s opening game in the Amlin Challenge Cup at Bucharest Oaks this Saturday, kick off 1pm GMT.Phil Nilsen and Jacob Rowan are the only two players in the starting line up who have not started a game already this season. Leeds Carnegie will be making their second trip to Bucharest in two seasons. Leeds won 10-6 at Bucharest last December.Scotland U20 scrum half Alex Black could make his debut off the bench along with centre Oliver Denton, who is the younger brother of second row Tom Denton. If Oliver comes on, it will be the second time that a pair of brothers have played for Leeds Carnegie, following in the footsteps of the Murphy brothers; Chris and Phil.The squad in full is:15 Leigh Hinton14 Michael Stephenson13 James Tincknell12 Luther Burrell11 Henry Faafili10 Christian Lewis Pratt9 Warren Fury1 Gareth Hardy2 Phil Nilsen3 Miguel Alonso4 Tom Denton5 Sean Hohneck6 Kearnan Myall7 Jacob Rowan How is your squad shaping up?Thankfully we have had some good news on Danny Paul after he came off injured last week against London Irish. He has suffered some damage to his ribs but we are confident he will be back fit for our next Aviva Premiership game against Sale at Headingley Carnegie. We have a few guys who have picked up some bumps and bruises in the first five rounds of the season and we will have to monitor them before we decide whether to take them on a long away trip in Europe especially as we do not know what conditions we will face. However, whatever team we field on Saturday we are sure they will produce a performance we can be proud of.
PLENTY OF headlines have been made by the big 15s players coming into sevens. We know of the All Blacks and Wallabies who have come in for this season, hoping to be in the mix when the medals are handed out at the Olympics. But for France captain Terry Bouhraoua, there are only so many 15s boys needed.“It’s difficult to have more than three of these guys in your squad,” Bouhraoua says. “The new players have an obligation to play in the sevens series so they’re ready for the Olympics at the end of the season. But I think three of them would be the maximum.“For France it’s a little different. We don’t have a Sonny Bill Williams or Quade Cooper to come straight into the sevens squad. We don’t have this problem because there aren’t superstars like them in France. And – this is just me talking – I don’t think this is the best solution for our team.”Of course, things can work the other way around. In the past, New Zealand have used sevens to get elite rugby experience for players who would go on to become All Blacks – think Liam Messam or Julian Savea. Scotland have done it too. Now France Sevens have seen their team-mate Virimi Vakatawa score a try on his Test debut against Italy.Big hand: Sonny Bill Williams carries ballBouhraoua says: “I’m very happy for Virimi – it’s good for him, for us and for the 15s. It’s good for everybody. I hope this shows how sevens youngsters can go into 15s.” High stepper: Terry Bouhraoua skips away from the English France’s charismatic captain Terry Bouhraoua tells RW’s Alan Dymock why his side won’t parachute in stars of the 15s game “I have also changed a lot as a player since my first tournament (in 2010). When you start you justgo straight and hard. I’ve learnt to think better during games.”This was first published in the April issue of Rugby World. For the latest subscription offers, click here. LATEST RUGBY WORLD MAGAZINE SUBSCRIPTION DEALS Bouhraoua insists that the French side is more like a club side now – they are more professional, more streamlined than in earlier years.So when there are injuries or drop-outs and players from outside their full-time sevens environment come in, they must catch up. There were only 14 French professional sevens players at the start of the season, and outsiders with Olympic dreams have had to be chucked into series rugby. It hasn’t been easy but Bouhraoua feels now is the time to experiment, before it’s too late.He’s had his own little injuries to overcome too, noticeably during the Wellington Sevens when he damaged his foot. He was cleared but sevens is not a game to hop through, and the fleet-footed skipper is key for France.“I’ve matured over the years,” he says. “Now, as captain, I must prepare the team because anticipation (of problems) is a big part of team success.
By Odessa American – May 7, 2021 Local News Facebook Mother’s Day luncheon WhatsApp Twitter Facebook Previous articleMother’s Day BreakfastNext articleNATIONAL VIEW: Push Congress to enact these sensible gun reform measures Odessa American Pinterest Twitter Pinterest TAGSBelmont Baptist ChurchlunchMother’s Day WhatsApp Belmont Baptist Church Men will prepare and serve the meal on Mother’s special day from noon to 1:30 p.m. Sunday following the morning worship service in the fellowship hall, 1200 W. Eighth St.The meal will be teriyaki chicken, rice, squash, sliced carrots, salad, rolls, and dessert.Visit tinyurl.com/jukr5u9s.
‘Prophets Of Doom’ & ‘Arm Chair Intellectuals’ Spreading Negativity; ‘Local Instigation’ Encouraging Migrants To Walk : Solicitor General
Top Stories’Prophets Of Doom’ & ‘Arm Chair Intellectuals’ Spreading Negativity; ‘Local Instigation’ Encouraging Migrants To Walk : Solicitor General Sanya Talwar28 May 2020 4:32 AMShare This – xTaking note of the miseries of stranded migrants across the country, the Supreme Court on Thursday passed a slew of significant interim directions.The bench comprising Justices Ashok Bhushan, S K Kaul and M R Shah took up for hearing its own Suo Motu case pertaining to the miseries and problems faced by migrant workers along with PILs and intervention applications filed for purposes…Your free access to Live Law has expiredTo read the article, get a premium account.Your Subscription Supports Independent JournalismSubscription starts from ₹ 599+GST (For 6 Months)View PlansPremium account gives you:Unlimited access to Live Law Archives, Weekly/Monthly Digest, Exclusive Notifications, Comments.Reading experience of Ad Free Version, Petition Copies, Judgement/Order Copies.Subscribe NowAlready a subscriber?LoginTaking note of the miseries of stranded migrants across the country, the Supreme Court on Thursday passed a slew of significant interim directions.The bench comprising Justices Ashok Bhushan, S K Kaul and M R Shah took up for hearing its own Suo Motu case pertaining to the miseries and problems faced by migrant workers along with PILs and intervention applications filed for purposes of safeguarding rights of Migrant workers during lockdown.Solicitor General Tushar Mehta appeared for the Centre and apprised the Court at length regarding measures taken by the Central & State Governments. During the hearing, Solicitor General stated that while the Centre is extremely grateful to the Supreme Court, he had a complaint which was imperative to come on record as his submission in capacity as “an officer of the Court”.Mehta emphasised that there were in fact some elements within the country who were adamant on spreading “misinformation” about the migrant crisis. “Some isolated, limited instances [of the migrant crisis] are being shown repeatedly. These tend to have a deep impact on the human mind” added the Solicitor General.Mr. Mehta reflected upon the “discourteous” behaviour and unpatriotic furore by certain segments in the society towards an unprecedented humanitarian crisis. He designated these individuals as “Prophets of Doom”.SG: I have something more to say as an officer of the court. Have a complaint. There are some media reports and some people – two complaints I want to register. “There are prophets of doom who keep spreading Misinformation. Not showing courtesy to the Nation.”Adding to the above, Solicitor General emphasised that the Centre was doing its level best to manage this “unprecedented crisis” but some naysayers have been spreading negativity. He stated that there was a complete lack of acknowledgement of the efforts of the Ministers and officials working day and night by “Arm Chair” intellectuals.SG: “Centre is doing a lot to prevent #COVID19 but there are Prophets of Doom in our country who only spread negativity, negativity, negativity. These ARM CHAIR intellectuals do not recognize the nation’s effort”Solicitor General Tushar Mehta:”Centre is doing a lot to prevent #COVID19 but there are Prophets of Doom in our country who only spread negativity, negativity, negativity. These arm chair intellectuals do not recognize the nation’s effort”— Live Law (@LiveLawIndia) May 28, 2020Further to this, the Solicitor General drew a corollary between the story of the famous photograph “The Vulture & the Little Girl” and the alleged “Prophers of Doom” in India.He stated that a photographer Kevin Carter went to a famine-stricken Sudan in 1983. Carter photographed a vulture who was waiting for the child to die. His photograph, after being published in New York Times was awarded the Pulitzer Prize. However, Carter committed suicide after four months.He added,”… a journalist had asked him – what happened to the child? He said I don’t know, I had to return home. Then the reporter asked him – how many vultures were there? He said one. The reporter said – no. There were two. One was holding the camera….”Highlighting the above instance and metaphorically drawing an analogy between Carter and people who were criticising the Government’s actions, Solicitor General urged that the Top Court must not not be used for perpetuating “political agendas”. Vehemently arguing against the intervenors who have drawn similarities between the ADM Jabalpur incident & the alleged lack of stronghold by the Government & Judiciary, SG Tushar Mehta added that the “Arm Chair Intellectuals” consider the Court neutral only if it abuses the executive. “For these arm chair intellectuals, Lordships are neutral only if they abuse the executive. If a handful of people want to control the institution, then it will become an ADM Jabalpur incident. All these people wanting to intervene need to apply the vulture and child story…”Urging the intervenors in the instant issue, Solicitor General called for an insight into their contributions during the migrant crisis.SG: “Those who come before your Lordships, let them establish their credentials. They earn in crores. Have they spent a penny? People are feeding people on the streets. Had any of them cared to come out of their AC offices?The question to ask is, What have they contributed? Your lordships must ask them to file an affidavit on their contribution? Except for writing on social media, penning articles, giving interviews? People are working tirelessly. From the safai karam charis to the PM”Subsequently, when Senior Advocate Kapil Sibal began arguing, Solicitor General interjected and prayed that the Humanitarian Crisis not be used for “Political agenda’s”It was here that Solicitor General asked Sibal about his contributions towards the crisis.Sibal to SG: It’s a humanitarian crisis. Nothing to do with politics. Don’t make it personal.SG: This forum should not become a political platform.Sibal: it’s a humanitarian crisis.SG: What’s your contribution in the crisis?Sibal: 4 Crores. That’s my contribution.The SG also said that there were “isolated incidents” of migrants crisis, which were being shown repeatedly in media. “Repeated reporting of isolated incident has a deep impact”, he remarked. He also added that “local instigation” led to the migrants’ walk in many cases. “In many cases there is local level instigation which is encouraging people to start walking. Those who started walking, when the state found them, the bus goes to them immediately and takes them to the nearest railway station”, he said.The SG also commented that some “High Courts were running parallel governments”.The matter(s) have been adjourned till June 5. SG: In many cases there is local level instigation which is encouraging people to start walking. Those who started walking, when the state found them, the bus goes to them immediately and takes them to the nearest railway station.#MigrantWorkers— Live Law (@LiveLawIndia) May 28, 2020It was on May 26 that the Supreme Court took suo moto cognizance of the migrants crisis, which had been on going since the announcement of country-wide lockdown on March 24. The Court said that there were “inadequacies and certain lapses” in the measures taken by the governments for migrants welfare.”We take suo motu cognisance of problems and miseries of migrant labourers who had been stranded in different parts of the country. The newspaper reports and the media reports have been continuously showing the unfortunate and miserable conditions of the migrant labourers walking on-foot and cycles from long distances”, the bench said.Shortly before that, a group of 20 leading advocates had submitted a representation before the CJI, complaining that the Court’s passivity in the issue resulted in the executive going unchecked amidst a grave humanitarian crisis. They said that the Court was showing “excessive deference” to the executive, by showing unwillingness to question the Central Government’s “patently false” claims.Several former judges, and senior advocates, including Senior Advocate Dushyant Dave, President of the Supreme Court Bar Association, have been vocal in criticizing the top court for its inaction on the migrants issue.Subscribe to LiveLaw, enjoy Ad free version and other unlimited features, just INR 599 Click here to Subscribe. All payment options available.loading….Next Story
Section 65B(4) Evidence Act : Despite SC Decision In ‘Arjun Panditrao’, Uncertainty Looms Around Electronic Evidence
ColumnsSection 65B(4) Evidence Act : Despite SC Decision In ‘Arjun Panditrao’, Uncertainty Looms Around Electronic Evidence Trisha Chandran21 July 2020 7:30 PMShare This – xOn 14 July 2020, a three judge bench of the Supreme Court delivered its judgment in Arjun Panditrao Khotkar, in what ought to have been an authoritative ruling on the law on electronic evidence. The judgment is borne out of a reference made by a two judge bench in the same matter, by an order dated 26.07.2019. The reference was made to address the inconsistencies between the decisions of…Your free access to Live Law has expiredTo read the article, get a premium account.Your Subscription Supports Independent JournalismSubscription starts from ₹ 599+GST (For 6 Months)View PlansPremium account gives you:Unlimited access to Live Law Archives, Weekly/Monthly Digest, Exclusive Notifications, Comments.Reading experience of Ad Free Version, Petition Copies, Judgement/Order Copies.Subscribe NowAlready a subscriber?LoginOn 14 July 2020, a three judge bench of the Supreme Court delivered its judgment in Arjun Panditrao Khotkar, in what ought to have been an authoritative ruling on the law on electronic evidence. The judgment is borne out of a reference made by a two judge bench in the same matter, by an order dated 26.07.2019. The reference was made to address the inconsistencies between the decisions of a two judge bench decision in Shafhi Mohammad (2018) and that of a three judge bench in Anvar PV (2014). For context, Section 65-B, Indian Evidence Act, was introduced in the beginning of this millennium, at a time when information technology and consequently digital evidence was making inroads into the law. This provision sought to admit copies of electronic records (print outs, CDs etc) as documentary evidence in court proceedings, while ensuring the authenticity of such records. The provision incorporated conditions meant to ensure that the electronic device used to generate the evidence was in regular use, and in working order. To this end, the section provided for a certificate that would authenticate the electronic device and the record. Over the years, judicial pronouncements have primarily disagreed on whether this certificate is mandatory. One view is that stricter procedures (such as a mandatory certificate) would prevent against tampered evidence being introduced. A contrary perspective views the requirement of a mandatory certificate as adding unnecessary procedural roadblocks, leading to delays in the judicial process, and potentially excluding important pieces of evidence. In such circumstances, Arjun Panditrao sought to introduce clarity to the law on electronic evidence. I argue that Arjun Panditrao’s quest to bring clarity to the law, has raised more questions than it has answered. Arjun Panditrao has failed to consider all preceding judicial decisions while laying down the law. As a result it has widened the gap between two views – one that the certificate is a mere procedural requirement and the other that it is at the root of admissibility of electronic records. Further the judgment contains several internal contradictions on issues such the stage at which such a certificate ought to be produced. Overall, I argue that the longstanding judicial ambiguity around the admissibility of electronic evidence, may be a sign for the legislature to intervene and bring clarity to the law. A background of judicial uncertainty In 2014, a three judge bench in Anvar had overruled a previous judgment in Navjot Sandhu and held that electronic records were a class on their own and had to be proved only in accordance with the procedure in Section 65-B. Significantly, Anvar held the production of a certificate under Section 65-B(4) to be a mandatory requirement for the admissibility of electronic evidence. Gradually the judiciary began to signal its discomfort with Anvar’s pronouncement on the mandatory nature of a certificate and viewed it as a technical impediment to the advancement of technological interventions in the legal system. A three judge bench in Tomaso Bruno, without reference to the judgment in Anvar held that the contents of an electronic record may also be proved under Section 65, Evidence Act, by treating it as ordinary secondary evidence. In 2018, a two judge bench in Shafhi Mohammad while relying on the judgment in Tomaso Bruno held that electronic evidence is admissible as long as it is “authentic and relevant” and deemed it fit to relax the ‘procedural requirement’ of a certificate when the person adducing such electronic evidence was not in custody of the device. The ruling in Arjun Panditrao Considering the ambiguity surrounding the mandatory nature of the certificate, the Court in Arjun Panditrao has held Shafhi Mohammad to be bad law and overruled it for being in contravention of the decision of the three judge bench in Anvar. Further, the decision in Tomaso Bruno has been declared per incuriam due to its ignorance of the law set down by Anvar – a previously pronounced judgment of a co-equal bench. Reaffirming the mandatory nature of the certificate, it is held that the certificate is a “condition precedent” to the admissibility of evidence by way of electronic record. To proffer solutions to the issue raised in Shafi Mohammed regarding the difficulty of producing a certificate by a party who is not in possession of an electronic device, the Court suggests that it is always possible for the trial court to exercise its power to summon the certificate from the requisite person. In fact, the opinion of Justice R.F. Nariman goes one step further, to place a positive obligation on the judge conducting the trial, to summon the certificate when an electronic record is produced in its absence. Arjun Panditrao – the uncertainty continues The Court’s ruling in Arjun Panditrao leaves several key issues pertaining to the admissibility and appreciation of electronic evidence unaddressed in its wake. One major issue emerges from the decision of a two judge bench of the Supreme Court in Sonu v. State of Haryana where it was held that pleas regarding the admissibility of electronic records on grounds of non-production of the certificate under Section 65-B, could not be entertained before an appellate court, if an objection had not been taken before the trial court. This ruling was based on the finding that the requirements of Section 65-B merely pertained to issues of mode of proof, as opposed to inherent inadmissibility of the document, which issue could be considered by an appellate court as well. However, Arjun Panditrao’s opinion that the mandatory certificate is a condition precedent and at the very core of the admissibility of electronic records casts doubt over the correctness of Sonu’s categorization of the issue as a procedural requirement. Arjun Panditrao does not engage with this proposition set down in Sonu. Further, if it is the trial court’s obligation to insist on the production of the 65-B certificate, the failure of the advocate to raise an objection regarding non-production (as required by Sonu) ought not to prejudice the objection at an appellate stage. The Court’s failure to engage with Sonu and delve into the ramifications that its judgment has on the said issue, has perhaps opened the doors to future litigation. Another issue the Court in Arjun Panditrao fails to deal with decisively is the relevant stage for the production of the certificate. On the one hand, the Court states that a party should ideally ensure that an electronic record, wherever possible, is accompanied by a certificate at the first instance. In criminal trials, as a matter of ‘general principle’ and true to the spirit of Section 207, Code of Criminal Procedure, the trial court should insist that the certificate be produced along with the charge-sheet. Notably, this finding deviates from the Court’s earlier view in State of Karnataka v. M.R. Hiremath that the certificate need not be produced with the charge-sheet and the need for the certificate arises during the production of evidence during trial. Having stated so, the Court shies away from laying down the law and instead holds that the trial court while exercising discretion, may in “appropriate cases” allow the prosecution to produce the certificate at a ‘later point of time’, while ensuring that the rights of the accused are not compromised. This position too, is later contradicted when the Court finally states that the certificate may be directed to be produced at any stage, before the completion of the trial. In practical terms, the judgment’s failure to conclusively indicate the relevant stage for the production of the certificate, could lead to grave uncertainty in the procedures followed by the Trial Court in admitting electronic evidence. At what stage of the trial must the court draw a conclusion that the party is incapable of producing the certificate and thus step in to exercise its power to summon the certificate? As Abhinav Sekhri contends, this process could lead to trials being severely delayed due the pendency of applications for the production of the certificate. The future of electronic evidence If Tomaso Bruno was declared bad law for failing to follow the law laid down by a previous judgment of a co-equal bench, Arjun Panditrao, (being a three judge bench) was equally constrained from travelling beyond the law set out in Anvar. However, the desirability (or lack thereof) of a mandatory certificate under Section 65-B is still topical and does not end with Arjun Panditrao. The separate opinion of Justice V. Ramasubramanian contains pertinent observations on the possibly out-dated nature of Section 65-B, which in substantial part is a reproduction of the erstwhile Section 5, UK Civil Evidence Act, 1968, that stood repealed in 1995 (ten years before its introduction in India). Jurisdictions such as Canada presume the integrity of the computer device and the information generated therein and allow parties to adduce evidence to rebut such presumptions. On a whole, the trend has been towards allowing parties to introduce electronic evidence in trials more easily. There is a prevailing view amongst even the defence counsels that stringent procedural requirements such as a mandatory certificate, may hinder accused persons from relying on digital evidence that is potentially exculpatory. The requirement of a certificate under Section 65-B as a precondition to the admissibility of electronic records, is rooted in the supposition that the process of creating a computer output (i.e. obtaining a print out, or creating a CD) continues for a large part to be susceptible to malfunctioning and tampering. The Supreme Court in Arjun Panditrao, instead of settling the judicial discordance on electronic evidence, has introduced more ambiguities in the law. One way or the other, it appears that until the legislature revisits the issue of the inherent trust-worthiness of electronic records, judicial pronouncements will oscillate between concerns of the authenticity of electronic evidence on the one hand (tampering, malfunctioning etc) and the ease of admitting electronic evidence, on the other.Views are personal only. (Trisha Chandran is a Litigation Associate at Project 39A, National Law University, Delhi) Subscribe to LiveLaw, enjoy Ad free version and other unlimited features, just INR 599 Click here to Subscribe. All payment options available.loading….Next Story
Community Enhancement Programme open for applications Facebook WhatsApp Google+ Loganair’s new Derry – Liverpool air service takes off from CODA Facebook Pinterest Arranmore progress and potential flagged as population grows Twitter Important message for people attending LUH’s INR clinic RELATED ARTICLESMORE FROM AUTHOR By News Highland – May 18, 2019 Homepage BannerNews News, Sport and Obituaries on Monday May 24th Pinterest WhatsApp Google+ Gardaí have renewed their appeal for information a week on from the disappearance of Derry man Aidan Baldrick.Searches are continuing in Letterkenny today for the missing man.The 33 year old was who has been missing since May 10th was last seen at the Station roundabout in Letterkenny on Saturday last.He is described as being approximately 5ft 8in in height of medium build and is believed to have been wearing blue jeans, a dark navy jacket and brown loafers. Previous articleFurther school climate strike planned in DonegalNext articleOperation to recover gold from sunken ship off Donegal News Highland Twitter Nine til Noon Show – Listen back to Monday’s Programme Gardaí renew appeal for man last seen in Letterkenny
Share via Shortlink On the latest episode of Coffee Talk, TRD’s Amir Korangy sat with wellness real estate CEO Paul Scialla, whose company Delos has raised over $230 million to further its mission of, as Scialla put it, “merging the health sciences with the building sciences.”The company has been valued at over $1 billion and attracted attention back in 2014 with a wellness-first development. The project’s residents, including Delos board members Deepak Chopra and Leonardo DiCaprio, enjoyed vitamin-C infused showers and cork floors engineered to provide lumbar support.But the company’s goals go beyond splashy luxe developments. Since 2014, it has garnered investments from the likes of Bill Gates, expanded into Asia and Australia, and made partnerships with major real estate players like Brookfield, Lendlease, and Marriott.Delos’ company includes subsidiary the International Well Building Institute, which provides a new set of standards for building owners and developers.“This is going way beyond removing what’s harmful or toxic and promoting what’s beneficial,” Scialla explained. That includes monitoring the quality of the water, examining the way a building’s lighting influences productivity and engineering spaces that encourage healthy lifestyles.The Well Building Institute “WELL certifies” buildings that provide healthy environs and practices. Delos’ various products — which include the plug-and-play air filters used in its partnership with the NYC Department of Education— provide solutions for the buildings that fall below the WELL standard. Scialla said WELL certification doesn’t require the use of Delos products. “[The standard] is about achieving outcomes,” he said.The science here is fueled by Delos’ Well Living Lab, a collaboration with the Mayo Clinic. And it seems especially prescient today. Scialla uses the term “health safety” to refer to the need driving many developers. “Unfortunately, it takes something like a pandemic for people to realize something very simple,” he said. “What surrounds us matters.”Still, Korangy wondered whether developers would push back against another cost add-on.“Like any movement, I think it takes a while. Green building and green principles did not just convert overnight,” Scialla said. “The WELL building proposition… has never been anything more than maybe a half a percent premium in construction costs.”So for Delos, the pandemic has brought a silver lining. “What we’ve seen is certainly a catalyst here for the wellness real estate movement.” Share on FacebookShare on TwitterShare on LinkedinShare via Email Share via Shortlink TagsCoronavirusDevelopmentWell Building