Introduction:

In a recent judgment by the Delhi High Court, the admissibility of WhatsApp conversations as evidence came under scrutiny. Justice Subramonium Prasad presided over a case where Dell International Services India Private Limited challenged an order from the Delhi State Consumer Dispute Redressal Commission. The dispute arose when Dell attempted to submit a screenshot of WhatsApp conversations to support its defense in a consumer complaint filed by Adeel Firoz. The court’s decision centered on whether WhatsApp messages can be considered admissible evidence without proper certification under the Evidence Act, 1872.

Arguments of Both Sides:

Dell International Services India Private Limited argued that it had filed a screenshot of WhatsApp conversations to demonstrate that it did not receive the complete set of documents along with the summons from the District Commission within the stipulated time frame. The company contended that this justified its delay in filing the written statement, seeking condonation of the delay.

Dell’s submission emphasized the authenticity and relevance of the WhatsApp conversations in proving its case before the consumer dispute commission. The company asserted that the messages clearly indicated the timeline and circumstances under which it received the complaint documents, thereby justifying its plea for condonation of delay.

Adeel Firoz, the complainant, opposed Dell’s arguments, contending that the delay in filing the written statement was not bona fide. Firoz argued that Dell’s attempt to introduce WhatsApp conversations as evidence lacked proper certification under the Evidence Act, 1872. He emphasized that such electronic communications require specific legal validation to be admissible in court proceedings.

Firoz’s stance underscored the procedural and evidentiary requirements under Indian law, suggesting that without adherence to these standards, Dell’s reliance on WhatsApp conversations should not be accepted as valid evidence in the case.

Court’s Judgment:

Justice Subramonium Prasad of the Delhi High Court ruled that WhatsApp conversations cannot be considered as evidence in legal proceedings without proper certification as mandated by the Evidence Act, 1872. The court noted that Dell International Services India Private Limited failed to demonstrate that the WhatsApp conversations were produced before the State Commission or discussed in its order.

The judgment further highlighted that Dell’s submission of its written statement was delayed, and its claim of not receiving the complete set of documents along with the summons was unsubstantiated. The District Commission’s decision to reject Dell’s application for condonation of delay was upheld, as the court found no error in its reasoning.

Consequently, the Delhi High Court dismissed Dell’s writ petition challenging the orders of the lower consumer dispute resolution bodies. The decision reaffirmed the importance of procedural compliance and evidentiary standards in legal proceedings, particularly regarding the admissibility of electronic communications like WhatsApp messages.