DR. RAM MANOHAR LOHIYA

NATIONAL LAW UNIVERSITY,LUCKNOW

LAW OF EVIDENCE

Final Draft

“Secondary Evidence”

Under Supervision of Submitted by

Mr.Vipul Vinod Sudhanshu Kumar Viplava

Assistant Professor Roll No.-135

Dr.RMLNLU Section- B

Sem.-V

B.A.LL.B(Hons.)

ACKNOWLEDGEMENT

Apart from the efforts taken by me , the success of this project depends largely on the

encouragement and guidelines of many other people.I take this opportunity to express my

thanks to the people who have been instrumental in the successful completion of this

project.

My deepest thanks to our teacher without whose guidance this project would have been a

distant reality.I would also like to thanks the library staff for being the provider of

information about various books referred in the preparation of this project.I extend my

deepest regard to the institution and faculty members.

Table of Contents

Introduction

Secondary Evidence

Cases In Which Secondary Evidence May Be Given

Types Of Secondary Evidence And Judicial Decisions

Conclusion

Bibliography

Introduction

Secondary Evidence is a reproduction of, or substitute for, an original document or item of

proof that is offered to establish a particular issue in a legal action.

Secondary evidence is evidence that has been reproduced from an original document or

substituted for an original item. For example, a photocopy of a document or photograph

would be considered secondary evidence. Another example would be an exact replica of an

engine part that was contained in a motor vehicle. If the engine part is not the very same

engine part that was inside the motor vehicle involved in the case, it is considered secondary

evidence.

Courts prefer original, or primary, evidence. They try to avoid using secondary evidence

wherever possible. This approach is called the best evidence rule. Nevertheless, a court may

allow a party to introduce secondary evidence in a number of situations.

After hearing arguments by the parties, the court decides whether to admit secondary

evidence after determining whether the evidence is in fact authentic or whether it would be

unfair to admit the duplicate. However, when a party questions whether an asserted writing

ever existed, or whether a writing, recording, or photograph is the original, the trier of fact

makes the ultimate determination. The trier of fact is the judge if it is a bench trial; in a jury

trial, the trier of fact is the jury.1

INTRODUCTION OF SECONDARY EVIDENCE

S. 63 Secondary evidence means and includes –

1.Certified copies given under the provisions hereinafter contained;

2.Copies made from the original by mechanical process which in themselves ensure the

accuracy of the copy, and copies compared with such copies;

3.Copies made from or compared with the original;

4.Counterparts of documents as against the parties who did not execute them;

5.Oral accounts of the contents of a document given by some person who has himself seen it.1 Law of Evidence, Ratanlal & Dhirajlal, Wadhwa Publication Nagpur

Clause 1 to 3 deals with copies of document

This section is exhaustive in regards to the kinds of secondary evidence admissible under the

Act. The expression “means and includes in this section” make it clear that the five clauses

referring to secondary evidence are exhaustive.

 The most remarkable among the types of secondary evidence by the section is the oral or

parol evidence of the contents of a document. Thus, it follows the oral evidence of the

contents of a document can be given. There are two conditions of a relevancy of such

evidence. Firstly, party offering oral evidence must be entitled to give secondary evidence of

such document. The circumstances in which secondary evidence can be given are listed in

section 65 should exist so as to enable, the party to give secondary evidence of a document in

question. The second condition is that the oral account of the contents of a document must be

that of a person who has himself seen it. Once these conditions are satisfied, the party can

give oral evidence of the contents of the document even if he has attested copy in his

possession.

                                                                                                                                 “The rule is,

that if you cannot produce the original, you may give parol evidence of its contents if indeed

the party giving such parol evidence appears to have better secondary evidence in his power,

which he does not produce, that is a fact to go to the jury, from which they might sometime

presume that the evidence kept back would be adverse to the party without holding it. But the

law makes no distinction between one class of the secondary evidence and another.”2

However secondary evidence cannot be made admissible mechanically. Sufficient reason for

non-production of the original document must be shown. For e.g. tenant file Xerox copy of

money receipt in his plea without giving proper reason and Xerox is authentic then it will be

not admissible.

CASES IN WHICH SECONDARY EVIDENCE RELATING TO

DOCUMENTS MAY BE GIVEN

2 LORD ABINGER, C.B. in Doerd Gilbert v. Ross, (1840) 19 L.J. Ex.210

S. 65 deal with these kinds of cases and reads as-: Secondary evidence may be given of the

existence, condition or contents of a document in the following cases:

(a)   When the original is shown or appears to be in the possession or power of the

person against whom the document is sought to be proved, or

 of any person out of reach of, or not subject to, the process of the Court, or of

any person legally bound to produce it,

 and when, after the notice mentioned in Section 66, such person does not produce

it;

(b) When the existence, condition or contents of the original have been proved to be admitted

in writing by the person against whom it is proved or by his representative in interest;

(c) When the original has been destroyed or lost, or when the party offering evidence of its

contents cannot, for any other reason not arising from his own default or neglect, produce it

in reasonable time;

(d) When the original is of such a nature as not to be easily movable;

(e) When the original is a public document within the meaning of Section 74;

(f) When the original is a document of which a certified copy is permitted by this Act, or by

any other law in force in India to be given in evidence;

(g) When the originals consist of numerous accounts or other documents which cannot

conveniently be examined in Court and the fact to be proved is the general result of the whole

collections.

In cases (a), (c) and (d), any secondary evidence of the contents of the documents is

admissible.

In case (b), the written admission is admissible.

In case (e) or (f), a certified copy of the document, but no other kind of secondary evidence, is

admissible.

In case (g), evidence may be given as to the general result of the documents by any person

who has examined them, and who is skilled in the examination of such documents.

TYPES OF SECONDARY EVIDENCE AND JUDICIAL DECISIONS

As we have seen in the provision of this section that there are different types of secondary

evidence let us understand one by one and judicial view on it. Their 17 main type of

secondary evidence which are as follow:

1. Certified copies

2. Copies prepared by mechanical process

3. Counter foils

4. Photographs

5. Xerox copy

6. Photostat copy

7. Carbon copy

8. Typed copy

9. Tape records

10. Copies made from or compared with original copy

11. Counterparts

12. Oral accounts

13. Registration copy

14. Unprobated will

15. Age certificate

16. Voters list

17. Newspaper report

1. Certified copies

Under section 76 the certified copies is defined. The correctness of certified copies will be

presumed under section 79, but that of other copies will have to be proved. This proof may be

afforded by calling a witness who can swear that he had compared the copy tendered in

evidence with the original, or with some other person read as the contents of the original and

that such is correct.

A copy of the municipal record which is not issued in accordance with the requirements of

the Municipal Act, is not relevant.

Certified copies of the Rules of Business made under Article 166(3) of the constitution are

admissible in evidence and judicial notice has to be taken of those rules as they are statutory

rules.

Under section 63 read with 79 of the Act, a certified copy of a document can be admitted

without any formal proof.

In the case of a sale deed of 1896, when the party failed to prove the loss of the original but

produced a certified copy, for proving the contents of the document, it was held that mere

production of a certified copy would not be sufficient to justify the presumption of due

execution of the original under section 90.

Where the existence of a document was admitted, it was held that, by such admission,

secondary evidence furnished by a certified copy assumes the character of primary evidence.3

2. Copies prepared by mechanical process

The copies prepared by mechanical process and copies compared with such copies is

mentioned in clause 2 of this section. In the former case, as the copy is made from the

original it ensures accuracy. To this category belong copies by photography, lithography,

cyclostyle, carbon copies. Section 62 states that, where a number of document are made by

one uniform process, as in the case of printing, lithography, or photography, each is primary

evidence of the contents of the rest, but where they are all copies of a common original, they

are not primary evidence of the content of the original.

3 Ibid

Copies of copies kept in a registration office, when signed and sealed by registering officer,

are admissible for the purpose of proving the contents of the originals.

When prosecution does not establish that the copies in question were made from originals by

mechanical process, no reliance can be placed by prosecution on those copies.

Letter press copies and photographs of writings are secondary evidence.4

3. Counter foils

The counter foils of rent receipts being an admissible in favour of the landlord are not

admissible against the tenant.

4. Photographs

HALSBURY states “ Photographs properly verified on oath by a person able to speak to their

accuracy are generally admissible to prove the identity of persons, or of the configuration of

land as it existed at a particular moment, or the contents of a lost document”

x-ray photographs are admissible in evidence to determine the extent of a physical injury or

disease, provided it is proved that the photograph is a photograph of the person injured or

diseased. The person who took the photograph should be called, unless his evidence is

dispensed with by consent.

A photographic picture cannot be relied on as proof in itself of the dimensions of the depicted

object, and cannot be made properly available to establish the relative proportion of such

objects, except by evidence of personal knowledge or scientific experience to demonstrate

accurately the facts sought to be established.

The accuracy of the photographic copies, particularly of external objects, as shown in the

photograph, is to be establish on oath, to the satisfaction of the court, either by the

photographer or some one who can speak to their accuracy. Before admitting a photograph,

the person who took the photograph has to be examined, and he should produce the negative.

5. Xerox copy

4 Law of Evidence, Dr. V. Krishnamachari, S. Gogia & Company

A xerox copy of the forensic report sent by FSL after certifying the same as true copy, was

held to be admissible in evidence as officer of the FSL had no interest in concocting report

against the accused.

If any document is unregistered and its copy is produced in the court then it will not

admissible in the court as secondary evidence.

6. Photostat copy

A Photostat copy of a letter is a piece of secondary evidence, and it can be admitted in case

original is proved to have been lost or not immediately available, for given reason, it is not

conclusive proof in itself of the truthfulness of the contents contained therein. Photostat

copies of documents should be accepted in evidence after examining the original records as

genuineness of a document was a fundamental question. The witness can be shown and

questioned as regards the Xerox copy of the document on records and the same will not

amount to admission of the said document in evidence. If the witness admits the signature

thereon, an objection can be raised at that time before the court that the document, being a

copy, could not be exhibited. In a case where the Photostat copy of the original was

produced, and there was no proof of its accuracy or of its having been compared with, or its

being true reproduction of the original it was held that the Photostat copy cannot be

considered as secondary evidence, as necessary foundation for its reception was not laid. A

Photostat copy of a document is not admissible as secondary evidence unless proved to be

genuine or the signatory accepts his signature.

7. Carbon copy

A carbon copy of a signature is a piece of secondary evidence within the meaning of

section63(2) of this Act, being a copy made by a mechanical process which ensures its

correctness. In a claim petition, the original insurance policy was not filed by the owner of

the vehicle. He did not object to the geniuses of the printed copy of the policy giving

particulars filed by the insurance company. He could not be allowed to raise objection that

the same could not be read as evidence.

8. Typed copy

A typed copy of an alleged partition deed without alleging that the document falls under one

of categories enumerated in section 63 of this Act, could not be held to be a secondary

evidence.

9. Tape record

Supreme court has held in certain cases that the tape-recordings can be legal evidence by way

of corroborating the statement of a person who disposes that the other speaker and he carried

on that conversation, or even of the statement of the person who may depose that he

overheard the conversation between two persons and that what they actually stated had been

tape recorded. What weight is to be attached will depend on other factors which may be

established in a particular case.

In Yusuf Ali Ismail V. State of Maharashtra5, it was held that if a statement is relevant, an

accurate tape-record of the statement is also relevant and admissible; that the time and place

and accuracy of the recording must be proved by a competent witness and the voices must be

properly identified; that, because of this facility of erasure and re-use, the evidence must be

received with caution, and the court must be satisfied beyond reasonable doubt that the record

has not been tampered with.

The Supreme court held that the tape itself is primary and the direct evidence of the matter

recorded, that it is admissible not only to corroborate under section 156 of this act but also for

contradiction under section 155 (3) for testing the veracity of the witness under section

146(1), and for impeaching his impartiality, under exception (2) of section 153.

Where the voiceage denied by the alleged maker thereof, recording of a voice of a witness for

comparison with, and identification of earlier recorded voice is neither expressly nor

impliedly prohibited under any statute.

Statements in the tape recorded can be admitted after proving that they were accurately

recorded. A previous inconsistent statement recorded on the tape recorder is admissible for

the purpose of contradiction.

Where the cassette containing the speech of the returned candidate in the election, tape

recorded by the police officer, was tendered in evidence by the election petitioner but how

5 AIR 1968 SC 147

and why it came to be recorded and how the petitioner came to know about it, were not

explained by him, it was not relied upon as a piece of evidence.

The supreme court observed:

“the conditions for admissibility of a tape recorded statement may be stated as follows :----

1) the voice of the speaker must be duly identified by the maker of the record or by others

who recognize his voice, in other words, it manifestly follows as a logical corollary that the

first condition of the admissibility of such a statement is identification of the voice of the

speaker. Where the voice has been denied by the speaker, it will require very strict proof to

determine whether or not it was really his voice.

2) the accuracy of the tape recorded statement has to be proved by the maker of the record by

satisfactory evidence, direct or circumstantial.

3) Every possibility of tampering with or eraser of a part of a tape recorded statement must be

ruled out otherwise it may render the said statement out of context and , therefore,

inadmissible.

4) the statement must be relevant according to the rules of evidence act.

5) the recorded cassette must be carefully sealed and kept in safe or official custody.

6) The voice of the speaker must be clearly audible or not lost or distorted by other sounds or

disturbances “.

A taped conversation, not compared with the voice, was not allowed as evidence.

10. Copies made from or compared with original

COPY –

Copies made from the original or copies compared with the original are admissible as

secondary evidence. A copy of a copy then compared with the original , would be received as

secondary evidence of the original.

A copy of a certified copy of a document, which has not been compared with the original,

cannot be admitted in evidence, such a copy being neither primary or secondary evidence of

the contents of the original.

When a document is an accurate or true and full reproduction of the original, it would be a

copy.

To admit secondary evidence, it is not sufficient to so merely that the original document is

lost; the secondary evidence itself must be of the nature described in section 63.a “true copy”

of a document will not be admissible under section 63, unless it is shown that it had been

made from or compared with the original.

Ordinary copy of a sale deed cannot be admitted as secondary evidence but copies of sale

deeds of acquired land are admissible in evidence, provided the parties to the document are

examined to prove the document.

The supreme court dealing with section 14 of Arbitration Act, explained the meaning of

expression “signed copy of award” and observed;”Signing means writing one’s name on

some document or paper; so long as there is a signature of arbitrator or umpire on the copy of

the award filed in court, and it showed that the person signing, authenticated the accuracy or

correctness of the copy, the document would be a signed copy of the award; it would in such

circumstance be immaterial whether the arbitrator or umpire puts down the words “certified

to be true copy” before signing the copy of the award above his signature; when a document

is an accurate or true and full reproduction of the reproduction of the original it would be a

copy”.6

Where the plaintiff in a suit for ejectment, produced a copy of the notice to quit , in proof of

the fact that the notice was valid, and original was in possession of other party, and the

plaintiff swore that it was a true copy of the original, it was held that it was not necessary that

the scribe of the copy should be produced, and anyone who had heard the original and the

copy read out to him, might swear that the contents of the two are identical and it would be

admissible.

Where a handwritten copy of the adoption deed was tendered in evidence in the absence of

evidence as to who made the copy , from what it was made, or whether it was compared with

the original, it must be disregarded.7

Section 63(3) refers to those types of copies;

a copy made from original; 6 Hindusthan Construction v. UOI AIR 1967 Sc 5267 Ganesh Prasad vs Badri Prasad Bholanath And Ors. AIR 1980 All 361

a copy compared with the original.

A copy falling under wither of the two heads will be admissible as secondary evidence.

The original dying declaration was lost. A head constable who maintained a copy testified to

its accuracy. This was allowed as corroborative evidence.

A certificate as to date of birth, on the basis of an entry in the register of a church maintained

in the regular course, is not admissible.8 Where a copy of a report, which was typed by a

typist, was not a copy typed by him was nor was it a carbon copy it was held not admissible

as secondary evidence. An abstract translation or a complete translation of a document is not

‘ copy made from and compared with the original’ within the meaning of this clause a copy

of the original letter addressed by the government to the commissioner, prepared privately by

a party at the time of inspection of relevant file, was held not secondary evidence of the

original letter. Where a defendant did not state anywhere In his evidence or produce evidence

of the document tendered is a copy made from the original, or that it was compared with the

original , and when he failed to prove by evidence the conditions for invoking section 63 , it

was held that the document tendered could not be receiver under section 63 (1) or (2) or (3)

of the evidence act. Where a printed copy purports to bear the signature of the candidates

agent in an election, it was held that the candidates signature does not establish the fact that

he really signed it, when the original was not proposed by the printer and proprietor of the

press where the copies were printed,

When a document was admitted without objection, it was held that omission to object to it’s

omission implied that it was a true copy and it was not opened to the appellate court to

consider whether the copy was properly compared with the original or not.9

An entry in a deed-writers register , which contains all the essential particulars contained in

the document itself and is also signed or thumb marked by the person executing the document

amounts to a copy and is admissible in evidence.

Where a draft of a document is made and on that basis an original is prepared it was held that

the draft cannot be treated as secondary evidence but the Kerala high court has held that a

draft can be accepted in evidence if there is proof that the original has been prepared without

any corrections and that it is an exact copy of the draft.10

8 Lakshmi Kanta Roy v. Nishi Kanta Roy9 British India steam navigation Co. Ltd. v. shanmugha vilas cashew industries, ILR (1947) 2 Ker 15010 P. Kunhammad And Ors. vs V. Moosankutty And Ors. AIR 1972 Ker 76

The Allahabad high court has similarly held that section 63 is not exhaustive of all types of

secondary evidence. It, therefore, allowed the draft notice from which the final notice was

prepared to be produced as secondary evidence.

It is not necessary for the proof of the bye-laws of a company, that the original copy of the

bye-laws bearing any mark of the approval of the board of directors be produced. The bye-

laws can be proved by other evidence.

11. Counterparts

Execution of a document in counterparts has already been explained while dealing with

explanation 1 to section 62. counterpart of document are primary evidence as against the

parties executing them under section 62 whereas under this clause they are secondary

evidence as against the parties who did not execute the document.

12. Oral accounts

This is last clause enable oral account of the content of a document being as secondary

evidence. The oral account of the content of a document given by a person who has merely

seen it with his own eyes, but not able to read it is not admissible as secondary evidence. The

word seen in clause 5 of this section means something more than the mere sight of the

document, and this contemplates evidence of a person who having seen and examined the

document is in a position to give direct evidence of the content their of. An illiterate person

cannot be one who has seen the document within the meaning of the section. In Pudai Singh

v. Brij Mangal11, Allahabad HC held that as regards the letting in of secondary evidence the

word seen in this section includes read over in the case of a witness who is illiterate and as

such cannot himself read it, if it is read over to him, it will satisfy the requirement of the

section. But this ruling was not accepted by HC oral account of the content of a document by

some person who has himself sent it. Oral account given by an illiterate person will be

hearsay evidence and excluded by section 60.

13. Registration copy

11 73 Ind Cas 654

Where the plaintiff took step to produce original will but it was not produced by the parties in

whose possession it was, it was held that the registration copy of the will which she filed, was

admissible in evidence as secondary evidence.

Whereas in the cases of proof of will and Where all that the executor of a pronote said that he

was very old, infirm and could not understand the nature of the document, but offered no

evidence in support of his allegation, the Allahabad High Court held that this did not amount

to a specific denial of execution. There was no necessarily of calling an attesting witness.12

Where, in the case of a “will” the only attesting witness surviving and summoned was able to

prove nothing, the will was held to be not proved.13 Similarly, where the legal heir of the

executants of a denied execution and the opposite party did not produce the attesting

witness for the fear that he may not favour the, the requirements of the section were held to

be not satisfied.14The legal requirement is complied with when one attesting witness is

produced. Neither it is necessary to produce the other witness even if available, nor is there

any obligation to explain why the other witness has not been produced.15What is to be done if

no attesting witness is available? Section 69

provides the answer……..

S.69 deals with the Proof where no attesting witness found any lays down that “If no such

attesting witness can be found, or if the document purports to have been executed in the

United Kingdom, it must be proved that the attestation of one attesting witness at least is in

his handwriting, and that the signature of the person executing the document is in the hand

writing of that person.”

If no attesting witness is available or if the document is executed in the United Kingdom, two

things should be proved-:

a) It should be proved that the signature of the person executing the document is in his

handwriting, and

b) That the signature of at least one attesting witness is in his handwriting.

Where all the attesting witnesses of a will were dead the court allowed the will to be proved

in the manner of any other document.16Where the part to an attested document has admitted

that he executed the document that is sufficient proof of the execution even if the document is

required by law to be attested. This is laid down in section 70.

12 Chuttan Lal v. Shanti Prakash AIR 1981 All. 5013 Rameshwari Devi v. Shyam Lal AIR 1980 All 29214 Ram Ratan Mishra v. Bittan Kaur, AIR 1980 All. 39515 Mathepw Jacob v. Salestine Jacob, AIR 1998 Del, 39016 Balwant v. Minabai, AIR 1991 M.P .11, Jayanti Gogal v. Pranati Duara, AIR, 2004 Gau.23

Section 70 deal with the admission of execution by party to attested document and say that

The admission of a party to an attested document of its execution by himself shall be

sufficient proof of its execution as against him, though it be a document required by law to be

attested.

If the attesting witness denies or does not remember the execution of the document, its

execution should be proved by other evidence. Where the attestor was an illiterate person and

he attested by putting his thumb impression and though it was a conveyance by his

predecessor-in-interest, he was not bound by the document unless it could be shown that the

document was read out to him and he understood it.17 The Calcutta and the Allahabad high

court have held that the word ‘admission’ relates only to the admission of a party in the

course of the trial of a suit, and not to the attestation of a document by the admission of the

party executing it. In other words, it has no relation to any admission of execution made

before an attesting witness without reference to any suit or proceeding.18

Now the question here is that what if attesting witness denies the execution. Section 71 deals

with the same and says that if the attesting witness denies or does not recollect the execution

of the document its execution may be proved by other evidence.

If a document not requires by the law to be attested has in fact been attested, its execution

may be proved as if it were not an attested document. In a case before Madras High Court,19

the question related to the validity of a will alleged to have been made and signed by a lady

before her death. Of the attesting witnesses only one was alive and he denied having attested

any such will. There were two other witnesses only one was alive and he denied having

attested any such will. There were two witnesses only. One of them was the registrar who did

remember the woman executrix. The other witness was able to identify the signature of her

head father who was one of the attesting witnesses. In these circumstances the court held that

the execution the execution of the will could not be said to have been duly proved. Section 63

of the succession act, 1925 requires a will to be attested by the two or more witnesses. A

combined reading of sec.68 of the Evidence Act and S.63 of the succession Act would,

therefore, suggested that at least one attesting witness should be examined and he should

speak not only of the testator’s signature but also that the other the other witnesses signed the

will in his presence. Where this is not done, the will cannot be said to have been proved.20

17 Badri Narayanan v. Rajabajyathammal, (1996) 7 S.C.C. 10118 Abdul Karim v. Salimun, (1899) 27 cal. 190; Raj Man Gal Misir v. Mathura Dubain, (1915) 38 All 1.19 Doraiswami v. Rathnammal, AIR 1978 Mad 7820 Paramu Radha Krishnan v. Bharathan, AIR 1990 Ker. 146

14. Unprobated will

Unprobated will can be admitted in evidence for collateral purpose in any other proceeding

apart from probate proceedings.

15. Age certificate

The age certificate issued by head master of a school on the basis of admission form was held

to be not a primary but a secondary evidence.

16. Voters list

A voters list is not a primary evidence of date of birth but a secondary evidence which was

held in Mustafa v. Khurshida.

17. Newspaper report

A news item published in a news paper is at best a second-hand secondary evidence. A fact

has to be alleged and proved and then newspaper reports can be taken in support of it but not

independently.

The evidence embodied in a letter was held to be not reliable when the author of the letter

was not produced and the opposite party had no opportunity of cross-examining him.21Even

where a person against whom an item of news appears in the press has not denied it, it would

not constitute evidence against him. Facts contained in the report would have to be proved.22

Conclusion

21 Orential Fire & General Ins, co. Ltd v. Chandrawati, AIR. 1989 P. & H. 30022 S.A. Khan v. Bhajan Lal, AIR 1993 S.C. 1348

Secondary evidence is the evidence, which may be given under certain circumstances in the

absence of better evidence. The general rule is that the secondary evidence is not allowed to

be given until the non production of the primary evidence. This thing is discussed in above

mention types of secondary evidence whether they are admissible in which conditions.

The outcome of hypothesis is half true and remaining is not true. The secondary evidence is

admissible in certain conditions only but its evidential value does not change if admissible in

court.

Bibliography

Books referred

Law of Evidence, Ratanlal & Dhirajlal, Wadhwa Publication Nagpur

Law of Evidence, Dr. V. Krishnamachari, S. Gogia & Company

Indian Evidence Act., Justice A.K.Nandi, Kamal law house

Law of Evidence,Batuk Lal,Central Law Agency,Allahabad.