09 Jun 2026 08:27 AM

Suit for Recovery--Books of Account--Self-Generated Computerised Ledgers And Unverified Audit Reports Insufficient To Discharge Burden Of Proof

Entries in books of account are relevant under Section 34 of the Indian Evidence Act, 1872 — now Section 28 of the Bharatiya Sakshya Adhiniyam, 2023 — but are merely corroborative and cannot alone be sufficient to fasten liability upon another person. Being private and unilateral records maintained by one party, such entries require independent evidence of the underlying transactions to which they relate. A party cannot create evidence in its own favour through self-generated schedules, computerised ledgers, or unverified audit reports. The burden of proof under Section 101 of the Evidence Act remains on the plaintiff to establish the transaction by cogent and independent evidence.

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