Section63 Guides s.63 BSA 2023

Home · Guides · updated 3 September 2026

The WhatsApp export .zip, and what to do with it

Ask for media and WhatsApp hands you a .zip rather than a text file. It is not an obstacle to be cleared before the real work starts. The archive is the record, and most of the damage done to chat evidence is done in the first five minutes of opening one.

What is in the archive

That last point is what an exhibit has to fix. A transcript entry reading IMG-20240612-WA0007.jpg (file attached) is a pointer; the file it points at is somewhere in the same archive, and nothing but the exhibit ties the two together for a reader.

What the rendered document then has to carry — the range, the entry numbers, the hash, the verification commands — is set out in converting a WhatsApp chat to a PDF for court. What follows here is about the archive itself.

The one rule: do not repackage it

A hash is exact, and an archive is a file like any other. Unzip it and zip it again and the photographs are identical, the transcript is identical, and the hash is completely different — because compression settings, entry order and the timestamps recorded inside the archive have all changed. There is no way back to the original value.

The commands for hashing on Windows, macOS and Linux are in verifying the hash, and the ordinary causes of an innocent mismatch are set out there too.

Reconciling the archive against the transcript

An archive and a transcript can disagree, and a disagreement is always better stated than discovered in cross-examination. Two counts are needed, and they are counted separately:

Where the first number exceeds the second, attachments are missing from the record — usually because they were no longer on the device, which is what “media omitted” means. Where the second exceeds the first, there are files in the archive the transcript does not account for, and that wants explaining before somebody else asks.

What becomes of each kind of file

Each attachment also wants its own hash, not merely the hash of the archive around it. The archive hash fixes the whole export; it cannot identify one photograph, and a photograph put to a witness on its own has to be identifiable on its own. Photographs, voice notes and documents covers the mechanics.

When the archive is very large

WhatsApp caps the size of an export, and a long conversation with media is truncated from the older end rather than refused. Open the transcript and check where it begins. If it does not begin where the conversation did, say so on the exhibit rather than letting a reader assume the record is complete — a limitation stated is a limitation weighed, and a limitation found by the other side is something else entirely.

If all you got was a .txt

Then the export was taken without media, or the attachments were no longer on the device. If the conversation is still on the handset, take a fresh export with media; it will be a different file with a different hash, and it is that file which should be certified as the record. If the media is genuinely gone, what you hold is a record of a conversation in which attachments were sent, and their contents are not part of it.

Section63 reads the .zip without extracting it to disk, hashes the archive as it arrived, hashes each attachment inside it, and reconciles the two counts in both directions — then prints the result in the exhibit whether it is flattering or not.


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.
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।