Section63 Guides s.63 BSA 2023

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Converting a WhatsApp chat to a PDF for court

Converting a WhatsApp chat to a PDF is the easy half. WhatsApp gives you a text file, a court reads a paginated document, and getting from one to the other without quietly destroying the thing that made the record provable is the part worth reading about.

Start from the export, not from the screen

The order of work decides everything that follows. Export the conversation from the phone, keep that file untouched, hash it, and build the readable document from it. Every shortcut that skips the export — screenshots stitched together, text pasted into a word processor, a print taken from inside the app — produces a document that looks much the same and can be tested for nothing. Screenshots, and why an export is stronger sets out the difference in full.

If the export arrived as a .zip rather than a bare .txt, the WhatsApp export .zip deals with the archive itself — what is in it, and how not to damage it. This page is about the document built from it.

What a court-ready PDF has to carry

A transcript is not made useful by being neat. It is made useful by being checkable, which means the document has to say enough about itself for a stranger to test it:

The PDF is not the record

This is the point most guidance on the subject gets wrong, and it is worth being exact about. The certificate under Section 63(4) identifies an electronic record, and it identifies it by its hash. Converting that record into a PDF produces a second, different file. The PDF is a rendering — useful, readable, the thing the court will actually look at — but the hash in the certificate does not describe it.

So both go on the file: the PDF for reading, and the native export, delivered as the court directs, so that the hash means something. An exhibit filed without the file it certifies invites exactly one question in cross-examination, and there is no good answer to it. Filing a chat exhibit covers what physically reaches the court.

Three ways this gets done, and what each costs

What “chronological” actually means here

Rendering in order sounds like a formatting preference. It is a fidelity requirement: the sequence comes from the file, and nothing is re-ordered, grouped by sender, filtered or summarised on the way into the document. A transcript that silently reorganises the conversation is no longer a transcript of it.

The times themselves need explaining rather than merely reproducing. They come from one device, in one time zone and one locale, and they are read by people who assume all three are their own. Timestamps, order and time zones sets out what has to be stated so that the dates are not argued about later.

What to hand the court

  1. The rendered exhibit, paginated and numbered, with the hash and the verification commands on it.
  2. The native export itself, unmodified, on the medium the court accepts.
  3. The certificate in the form of the Schedule, describing that export — see the certificate format.
  4. The attachments, where the record has any, with a manifest listing each file and its own hash.
  5. The same set served on the other side, so that what they receive is what the court has.

Section63 renders the exhibit from the file in your browser, hashes the export before anything else touches it, prints the verification commands on the cover, and reconciles the attachments both ways. The document it produces is a rendering of your record and says so on its face — the export is still the thing that gets certified.


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.
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.
WhatsApp Business and company accountsProducing WhatsApp Business conversations in Indian proceedings: who was in lawful control of a company account, what the Business app adds to the record, and how orders and automated replies are read.
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।