Section63 Guides s.63 BSA 2023

Home · Guides · updated 3 September 2026

WhatsApp Business and company accounts

A Business account changes very little about the export and a great deal about the certificate. The question stops being “whose phone is this” and becomes “who, in this organisation, can honestly depose to it”.

The export is the same

The Business application exports through the same menus and produces the same artefacts: a .txt transcript, or a .zip with the attachments, taken from the handset rather than from the web or desktop client. Nothing about the procedure in exporting a chat for court changes because the account is a business one.

Who was in lawful control

Part A is a declaration by a person, not by a company, and the Schedule asks for particulars of the device the record came from. So the deponent is whoever actually held that device and operated that account — and in an organisation that is a question of fact worth establishing before the certificate is drafted:

Who signs Part A works through the general principle; the business case is the same principle applied to an organisation where lawful control is delegated and moves.

The ordinary-course-of-business conditions

Section 63(2) sets conditions on which a computer output is treated as a document: broadly, that the device was used regularly to create, store or process information for activities regularly carried on by the person having lawful control of it, that information of that kind was regularly fed into it in the ordinary course of those activities, that the device was operating properly over the material period, and that the output reproduces information so fed in.

Those conditions are often assumed to be about businesses. They are not confined to them — a personal handset used routinely for messaging satisfies them just as a shop counter phone does. What a business account adds is that the conditions are usually easy to depose to, because the regular use is the business itself.

What the Business app adds, and what it does not

Where these conversations actually decide cases

In commercial matters the chat is frequently not corroboration of the contract but the place the contract was made: the quantity agreed, the rate, the delivery date, the variation nobody papered afterwards. Contract and commercial disputes deals with that at length, and cheque bounce proceedings with the dealing behind a dishonoured cheque.

Two problems specific to company accounts

Attribution inside the organisation. A message from a business account is a message from an account. Which employee sent it is a separate question, and where it matters the answer comes from evidence about who operated the phone at that hour, not from the display name.

Continuity. Handsets are replaced, numbers are ported, staff leave, and accounts get migrated. Each of those is a break the certificate has to describe truthfully. Where the record spans a change of device, the safe course is two exports and two certificates rather than one declaration that quietly covers both.

The counterparty deserves the same care. A customer is a person on a number, and identifying that person is the ordinary attribution problem — see attribution and third parties.


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.

Prepare one now

Section63 builds this document from your export.

Drop in the .txt or .zip WhatsApp gives you and read the whole exhibit — transcript, Part A, Part B, Schedules and the integrity checks — before you pay.

More guides

The Section 63 certificate

The certificate formatThe form the Schedule to Section 63(4) BSA calls for, set out in full: Part A for the person producing the record, Part B for the expert, and the particulars of the record and the device.
Who signs Part AChoosing the right deponent for the Section 63(4) certificate: lawful control of the device, why an advocate or clerk should not sign, and what to do when the phone belonged to someone else.
Who can sign Part BThe expert certificate under Section 63(4) BSA, the Section 79A question, and what the Supreme Court decided — and expressly did not decide — in 2026.
From Section 65B to Section 63What the Bharatiya Sakshya Adhiniyam 2023 changed for electronic evidence certificates, and what carried over from Section 65B of the Evidence Act.

Preparing and filing the record

Exporting a chat for courtStep by step: exporting a WhatsApp conversation on Android and iPhone, with or without media, what the .txt and .zip contain, and how to get the file off the phone without changing it.
Filing a chat exhibitWhat goes on the court file when chat evidence is produced: the transcript, the Section 63(4) certificate, the native file, service on the other side, and when the certificate must be filed.
Screenshots vs an exportWhat a WhatsApp screenshot can and cannot establish in court, how it differs from an export, and how to produce a screenshot properly when it is genuinely all you have.
WhatsApp chat to PDF for courtHow to convert a WhatsApp chat to a PDF for court in India: what the rendered transcript has to contain, why the PDF is not the certified record, and what has to be filed alongside it.
The WhatsApp export .zipWhat WhatsApp puts inside the .zip it gives you, why unzipping and re-zipping breaks the hash, and how the transcript and the attachment files become a single Section 63 exhibit.
Preserving the conversationWhat to do the moment a WhatsApp conversation becomes evidence: stop the losses, take the export, keep the handset, and understand what preservation does and does not establish.
Verifying the hash, step by stepThe exact commands to recompute a SHA-256 hash on Windows, macOS and Linux, what a match proves, and what to do when it does not match.
“Media omitted”: what it meansWhy a WhatsApp export says media omitted, whether the files can be recovered, and how to take an export that includes them.
Photographs, voice notes and documentsHow attachments from a WhatsApp conversation are produced in Indian proceedings, why each file needs its own hash, and how media is tied back to the transcript.
Voice notes, audio and transcriptsHow WhatsApp voice notes and audio are produced in Indian proceedings: the .opus file, who prepares the transcript, translation into the language of the court, and what identifies the speaker.

What a chat can and cannot prove

Are chats valid evidence?Whether WhatsApp messages are admissible in Indian courts under the Bharatiya Sakshya Adhiniyam, what the Section 63(4) certificate requires, and the difference between admissibility, proof and weight.
Deleted messagesWhat happens to deleted WhatsApp messages, why an export cannot recover them, what a backup does and does not restore, and the routes that actually exist when the deleted content matters.
Challenging chat evidence: a checklistThe grounds on which chat evidence is attacked in Indian proceedings: certificate defects, provenance, completeness, attribution and alteration.
Group chats, attribution and third partiesThe particular problems of group conversations in evidence: who said what, participants who are strangers to the dispute, and what to redact.
The limits of a WhatsApp exportThe honest limits of chat evidence: deleted and disappearing messages, edited messages, forwarding, read receipts and what an export is not.
Timestamps, order and time zonesHow WhatsApp writes dates and times into an export, whose clock and time zone they come from, why 05/06 is ambiguous, and what a gap in the sequence does and does not show.

By proceeding

Divorce and matrimonialHow chat evidence is used in matrimonial proceedings in India, which conversation to produce, the problem with messages taken off a spouse’s phone, and what a transcript can and cannot establish.
498A cruelty proceedingsHow chat evidence is used in Section 498A IPC (now Section 85 BNS) proceedings by both sides, what a transcript can establish about demands and conduct, and how records are used at the quashing stage.
Maintenance proceedingsHow chat evidence is used to establish income, concealed earnings and standard of living in maintenance proceedings, alongside the affidavit of disclosure required by Rajnesh v. Neha.
Domestic violence (PWDVA)How chat evidence is used in proceedings under the Protection of Women from Domestic Violence Act, 2005 — verbal, emotional and economic abuse, interim relief, and producing the record properly.
Cheque bounce (s.138 NI Act)How chat evidence is used in Section 138 Negotiable Instruments Act proceedings: proving the underlying debt, rebutting the presumption, acknowledgment of liability and part payment.
Contract and commercial disputesHow chat evidence is used in commercial matters: formation and variation of contracts by message, purchase orders and delivery, admissions of dues, arbitration agreements, and business account records.

हिन्दी

WhatsApp चैट कोर्ट में कैसे पेश करेंWhatsApp चैट को भारतीय अदालत में सबूत के तौर पर पेश करने की पूरी प्रक्रिया: चैट एक्सपोर्ट, SHA-256 हैश, धारा 63(4) BSA का प्रमाणपत्र (भाग A और भाग B), और दाखिल करते समय क्या-क्या देना होता है।