Guide · updated 1 September 2026

Challenging chat evidence: a checklist

Written for the party resisting a chat exhibit — and worth reading first by the party filing one. If a record survives everything below, it is worth filing. If it does not, better to know now.

1. The certificate

Start here, because it is the most commonly defective part of the filing.

• Is there a certificate at all, in the form of the Schedule — not a generic affidavit?
• Is Part A signed by the person who was in fact in charge of the device, and does that person depose to it?
• Are the device particulars filled in, or left blank?
• Is the hash value stated, and is the algorithm named?
• Is Part B completed? By whom, and on what stated qualification?

2. The hash

Recompute it. The commands are in the verification guide. If the hash of the file actually filed does not match the certificate, the certificate does not identify that file, and the party relying on it must explain the difference.

Note what a match does not settle. It fixes the file from the moment it was hashed. It does not show the file was produced by WhatsApp rather than composed in a text editor — which is the next question.

3. Provenance of the export

Ask how the file came to exist:

• Which device produced it, and who held that device?
• When was the export taken, and by what steps?
• Was the file altered, converted or repackaged between export and hashing?
• Does anything about the file itself corroborate that it is an export — the encryption preamble, timestamp shape, filename conventions, archive entry times?

These are structural features an application writes and an editor loses. Their presence corroborates; their absence is not proof of anything, since exports vary across app versions and locales.

4. Completeness

• Is the whole conversation produced, or an extract?
• Are there gaps in the sequence — dates or times with nothing between them?
• Does the transcript record deleted messages, and how many?
• Was the export taken with media? Entries reading media omitted mean the attachments are not in the record at all.
• Was the conversation long enough to have been truncated by the application’s own export limit?

5. Attribution

A transcript shows a display name and, in the export, a number. Neither establishes who was holding the phone. Where authorship is genuinely in issue, look for corroboration outside the chat — admissions, transactions, call records, conduct consistent with the messages — rather than treating the name as the answer.

6. Weight

Even a record admitted without objection may be worth little. Selective production, an unexplained gap at the material time, or an account of the export that shifts under cross-examination all bear on weight rather than admissibility, and are often the more productive line.

If you are the one filing

Run this list against your own exhibit before you serve it. The items that survive a hostile reading are the ones worth relying on, and the items that do not are better addressed in the certificate than in the witness box.

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This guide explains procedure and states the law as we understand it. It is not legal advice, and Aarohan Enterprises is not a law firm. Whether a court admits a particular record, and what weight it gives it, is for that court to decide. Have an advocate settle anything you intend to file.