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Anvar P V v P K Basheer (2014) and the subsequent Arjun Panditrao Khotkar (2020) hold that

ASection 65B certificate is purely a directory requirement
BSection 65B(4) certificate is a MANDATORY pre-condition for admissibility of secondary electronic evidence; this overrules Navjot Sandhu (2005) which had permitted oral evidence to substitute the certificate
CElectronic evidence is per se inadmissible
DSection 65B is unconstitutional
Answer & Solution
Correct answer: B. Section 65B(4) certificate is a MANDATORY pre-condition for admissibility of secondary electronic evidence; this overrules Navjot Sandhu (2005) which had permitted oral evidence to substitute the certificate
Anvar P V (3-judge bench) restored the strict Section 65B reading. Arjun Panditrao (3-judge bench, 2020) clarified the timing of the certificate and held the requirement mandatory.
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