Section63 Guides s.63 BSA 2023

Guide · updated 1 September 2026

Photographs, voice notes and documents

Most guidance on chat evidence treats the conversation as text. Often the text is the least of it — the photograph, the invoice, the thirty-second voice note is the evidence, and it needs producing properly.

Why attachments need their own treatment

A transcript is printable and a photograph is not. An exhibit that prints the words IMG-20240612-WA0007.jpg (file attached) and stops has recorded that a file existed, not what it showed. Meanwhile a bundle of loose image files with no connection to the conversation invites the question of where each one came from.

What is needed is both: the file itself, and an unambiguous link between the file and the entry in the conversation that produced it.

Hash each file, not only the archive

The archive hash in Part A fixes the whole export. That is necessary, but it is coarse: it cannot identify one photograph. Hashing each attachment separately means a single image can be produced, verified and put to a witness on its own, and its hash can be recomputed by anyone holding the file.

Tying media to the transcript

A reference has to work in both directions. From the transcript, a reader should be able to find the file; from the file, a reader should be able to find the entry it came from. In practice that means:

What can and cannot be printed

Delivering the originals

The exhibit is a document; the attachments are evidence in their own right. Both need to reach the court. Delivering the originals alongside the exhibit, with a manifest listing each file and its hash, means the court can open the actual photograph rather than a reproduction of it — and can confirm the file it opens is the file that was certified.

If an exhibit states that files are delivered with it, they must in fact be delivered. A document that says so and does not is a false statement on its own face.


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

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.
Challenging chat evidence: a checklistThe grounds on which chat evidence is attacked in Indian proceedings: certificate defects, provenance, completeness, attribution and alteration.
“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.
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.
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.
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.