UNIVERSITY INSTITUTE OF LEGAL STUDIES

PANJAB UNIVERSITY, CHANDIGARH

PROJECT REPORT
INDIAN EVIDENCE ACT, 1872

TOPIC: CONCEPT OF PRESUMPTIONS UNDER

INDIAN EVIDENCE ACT, 1872

SUBMITTED TO- SUBMITTED BY-

DR. SONAL PREET KAUR DIKSHA

UILS, PU B.COM LLB (HONS)

7th SEMESTER (E)

ROLL NO- 375/20

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 ACKNOWLEDGEMENT
The success and final outcome of this project required a lot of guidance and assistance from many
people and I am extremely fortunate to have got this all along the completion of my project report.
Whatever I have done is due to such guidance and I would never forget to thank them.

I take this opportunity to record my deep sense of gratitude to my teacher Dr. Sonal Preet Kaur,
UILS, PU, Chandigarh for her wonderful guidance, encouragement, and valuable suggestions
made during the preparation of the project and during the lectures which helped me to complete
my project successfully on the topic:

CONCEPT OF PRESUMPTIONS UNDER INDIAN EVIDENCE ACT, 1872

I owe my regards to the entire faculty of the Department of UILS for the intellectual support that
helped me in the entire duration of the project.

DIKSHA

7TH SEMESTER, B.COM LLB (HONS)

ROLL NO- 375/20 (E)

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 INDEX

SR. NO TOPIC PG NO.

1. Introduction 4

2. Presumption under the Indian Evidence Act, 1872 5-16

• Meaning and Definition
• Types of Presumption
• Provisions where the court may use the presumption of fact to
ascertain certain facts
• Provisions where the court may use the presumption of law to
ascertain certain facts
• Difference between presumption of fact and presumption of law

3. Section 4 of the Indian Evidence Act, 1872 17, 18

4. Conclusion 19

5. Bibliography 20

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 INTRODUCTION
The Indian Evidence Act, 1872 is an act that consolidates, defines, and amends the law of evidence
in India. The means which can be used to prove a fact are all controlled by the rules and principles
laid down by the law of evidence. The law of evidence does not affect substantive rights of parties
but only lays down the law for facilitating the course of justice. The Evidence act only lays down
the rules of evidence for the purposes of the guidance of the courts. This Act applies to all of the
judicial proceedings that are presented before any court within the territorial limits of India. It is
also applicable to Court Martials (not applicable to any proceedings which happen under the Air
Force Act/The Indian Navy Discipline Act/ The Army Act.) It is however not applicable to any
procedure carried out under an Arbitrator or to any affidavit presented before any court.

Evidence, according to Section 3 means and includes-

1. All statements which the court permits or requires to be made before it by witnesses, in
relation to matters of fact under inquiry,

Such statements are called oral evidence;

2. All documents produced for the inspection of the court

Such documents are called documentary evidence.

Presumption means to establish facts based on the possibility of certain acts, which have
toughened the possibility of such acts and when this possibility has a great value, then the facts
of certain activities can be understood. It means the inferences drawn by the court regarding the
facts. These inferences drawn by the court can be positive or negative and are derived by using
the best possible reasonable method of reasoning as per the situation.

This project has tried to lay down the presumptions in the Indian Evidence Act, 1872.

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 PRESUMPTION UNDER THE INDIAN EVIDENCE ACT, 1872
MEANING AND DEFINITION
Cambridge Dictionary defines it as “the fact of believing that something is true without having
any proof”.

Merriam Webster Dictionary defines it as “a legal inference as to the existence or truth of a fact
not certainly known that is drawn from the known or proved existence of some other fact”.

Cornell Law School defines it as a “legal inference that must be made in light of certain facts.
Most presumptions are rebuttable, meaning that they are rejected if proven to be false or at least
thrown into sufficient doubt by the evidence. Other presumptions are conclusive, meaning that
they must be accepted to be true without any opportunity for rebuttal”
A fact assumed to be true under the law is called a presumption. Presumptions are used to relieve
a party from having to actually prove the truth of the fact being presumed. Once a presumption is
relied on by one party, however, the other party is normally allowed to offer evidence to disprove
(rebut) the presumption. The presumption is known as a rebuttable presumption. In essence, then,
what a presumption really does is place the obligation of presenting evidence concerning a
particular fact on a particular party.
Presumptions are either legal and artificial, or natural.
Legal or artificial presumptions are such as derive from the law a technical or artificial, operation
and effect, beyond their mere natural tendency to produce belief, and operate uniformly, without
applying the process of reasoning on which they are founded, to the circumstances of the particular
case.
Legal presumptions are of two kinds:
1. Firstly, such as are made by the law itself, or presumptions of mere law;
2. Secondly, such as are to be made by a jury, or presumptions of law and fact.
Natural presumptions depend upon their own form and efficacy in generating belief or conviction
on the mind, as derived from these connections which are pointed out by experience; they are
wholly independent of any artificial connections and relations, and differ from mere presumptions
of law in this essential respect, that those depend, or rather are a branch of the particular system of
jurisprudence to which they belong; but mere natural presumptions are derived wholly by means
of the common experience of mankind, from the course of nature and the ordinary habits of society.

Section-114 of the Indian Evidence Act especially deals with the provisions that ‘the court may
presume the existence of any fact which it thinks likely to have happened, regard being had to the
common course of

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 a. natural events,
b. human conduct, and
c. public and private business, in their relation to the facts of the particular case’

TYPES OF PRESUMPTION

The traditional approach of common law system has classified presumption only under two
categories that are a presumption of law and presumption of facts but to avoid any ambiguity in
deciding any case the Indian legal system has adopted the third classification that is mixed
presumptions which includes both the aspects of facts as well as law. Hence the existing legal
system has three types of presumptions which are as follows:

PRESUMPTIONS

PRESUMPTIONS OF PRESUMPTIONS OF
MIXED
FACT, OR NATURAL LAW OR ARTIFICIAL
PRESUMPTION
PRESUMPTIONS PRESUMPTION

PRESUMPTION OF FACT: Presumptions of facts refer to those interpretations that are derived
logically and practically based on observations and surroundings in the course of basic human
conduct.

Also known as Natural/ Material Presumptions, they are illustrations of indirect pieces of evidence
as it believes that in the path of perception, it is easy to conclude from the other pieces of evidence.
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It would have been otherwise difficult to sort from the other pieces of evidence as the system of
law would then have to prove every detailed element to capture the legally conflicted members/
the lawbreakers.

Natural Presumptions usually are invalidated/ denied/ disapproved. In this classification of

presumption, the “shall presume” notion is applied. The courts presume that a fact which been
established before them will be considered to be a proven one unless the suspect disapproves of it.
This notion makes it compulsory for the court to admit some of the facts as proved until they are
challenged and disapproved.

PROVISIONS WHERE THE COURT MAY USE THE PRESUMPTION OF FACT TO

ASCERTAIN CERTAIN FACTS:

In law there exist some provisions which in a straight line express Natural Presumptions, and are
as follows:

• Section 86- Certified and True Duplicates of Judicial Records of Foreign Nations

This section explains the principle that the court has the discretionary power to make presumptions
with respect to the originality and accuracy of the certified copies of a different foreign country’s
judicial records and the called document should be consistent with the local or domestic rules. The
presumption explained under this Section has a very significant role, therefore, should be complied
with it. It is also observed that if the court does not feel that the foreign judgments are not consistent
with the local laws then these judgments lose the evidentiary values in the court.

• Section 87- Presumption related to Charts, Maps, and Books.

The court may presume that any book to which it may refer for information on matters of public
or general interest or any published chart or map, was written and published by the person, and at
the time and place by whom or at which it purports to have been written or published.

• Section 88- Presumption of Messages of Telegraphic Nature.

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If a telegram is produced before a court, it may presume that the message forwarded from the
telegraph office to the addressee corresponds with a message delivered for transmission; but the
court shall not make any presumption as to the person by whom such message was delivered. This
has to be proved by evidence. It is true that under Section 88, there is a presumption only that the
message received by the addressee corresponds with a message delivered for transmission at the
office of origin. There is no presumption as to the person who delivered such a message for
transmission. But proof of authorship of the message need not be direct and may be circumstantial.
The contents of the messages received, in the context of the chain of correspondence, may well
furnish proof of the authorship of the messages at the dispatching end.

• Section 90- Presumption of documents of 30 years old

Circumstances may arise when the documents are produced in a court long after they have been
executed and the time elapsed between the execution and the production of the document in the
court may he so long that all the persons in whose presence the document was executed might have
died. If the standard method of proof is strictly followed to such cases, a great hardship would be
caused and a number of genuine documents will remain unproved. Section 90 of the Evidence Act
is a provision for this kind of emergency.

The presumption discretionary - The power under Section 90 is only if discretionary, and not
compulsory. It depends upon the Court. It may presume the execution of a document under Section
90 or may demand the proof of the documents filed.

In Kripal Singh v. Aas Kaur and others1, the document was gift-cum-will. It was 30 years old
coming from custody of proper person. Same was registered. The court presumed its proper
execution.

• Section 113 A- Presumption as to the abetment of suicide by a woman who is married.

1
AIR 1997 P&H 240

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Section 113-A mandates that when a woman commits suicide within seven years of her marriage
and it is shown that her husband or any relative of her husband had subjected her to cruelty as per
the terms defined in Section 498-A IPC, the court may presume that such suicide has been abetted
by the husband or the relative2.

Essentials of this section are:

• That the woman had committed suicide within the period of seven years after date of her
marriage;
• That her husband or such relative of her husband had subjected her to cruelty;
• That the case of such suicide had been abetted by her husband or such relative of the husband.

Presumption under this section is rebuttable and is totally based on facts. Presumption of abetment
of suicide can be drawn only by the prosecution has discharged the initial onus of proving cruelty.
In such type of cases the court may call upon the prosecution to adduce sufficient evidence and to
prove that it was a case of suicide abated by the husband or his relation. The legal presumption
provided under this provision clearly includes the past inference of cruelty spread over a period of
seven years from the date of the marriage of the victim.

In, Mangal Ram & Anor v State of Madhya Pradesh, in this case, the wife of the accused was
living with her parents for many years and has no visited her matrimonial home for a long time.
But within one month of returning to her matrimonial home, she committed suicide. Therefore the
court presumed the circumstance that the accused is responsible for the death of the lady and the
case comes under Section 113B of Indian Evidence Act. But the husband and her in-laws proved
that the death was not caused because of the reasons subjected to cruelty. The court in that matter
said that the presumption was of rebuttable nature and the presumption can’t be sustained anymore,
hence the accused acquitted.

Section 113B- Presumption as to the abetment of suicide by a woman who is married with
relation to dowry death.

2
Pinakin Mahipatray Rawal v. State of Gujarat (2013) 10 SCC 48.

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This section deals with the principles of presumption related to abetment of suicide to married
women for the purpose of dowry. This Section empowers the court to presume that the husband
and his relative are the abettors of suicide and the wife was subjected to cruelty or any torture
related to demand of dowry.

The essentials of Section 113B are:

• That the presumption can be raised only if the accused is being tried for the offence under
section 304B, IPC.
• That the woman was subjected to cruelty or harassment by her husband or his relatives.
• That such cruelty or harassment was for or in connection with any demand for dowry.
• That such cruelty or harassment was soon before her death.

The presumption of dowry death arises only in cases when the prosecution proves that before
death, the victim was subjected to cruelty or maltreatment or harassment for dowry demand.
Hence, under this section when prosecution proves the case, it shall be presumed by the court
that the death is a dowry death.The Apex Court has observed that “there must be existence of a
proximate and live-link between the effect of cruelty based on dowry demand and the concerned
death.”
“A comparative study of Sections 11З-А and 113-В highlights that under Section 113-A the
court “may presume” having regard to all the other circumstances of the case, an abetment of
suicide as visualized by Section 306, IPC, but Section 113-B which is relatable to Section 304-
B, IPC the word “may” has been substituted by “shall’’ and there is no reference to the
circumstances of the case.”

In, Hem Chand V. State of Haryana3 the couple married on 24 May of 1962. The wife left her
husband’s home just after 2 months of her marriage and explained the reason to her parents that
her husband is demanding for a TV and a refrigerator. After listening to such demands her father
out of his hard money gave her around Rs. 6,000 and she left for her matrimonial home. But the

3
(1994) 3 Crimes 608 (SC)

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 husband’s desire was not finishing and he again asked her to get twenty-five thousand rupees
from her home as he is willing to buy some real estate property. Thereafter the accused took his
wife to her parents’ home and said that he’ll take back her only if he will be paid Rs. 25,000. One
year after she came back to her matrimonial home with Rs. 15,000 and promised the balance
amount will be paid soon. But on the same day, she died of strangulation in her husband’s home.
The trial court and both Supreme Court found accused to be guilty and convicted on carrying the
presumptions that her husband has performed cruelty against her and the reason for her death
could be the husband’s cruelty for the purpose of dowry.

PRESUMPTION OF LAW:

Presumptions of law are such inferences and beliefs which are established or assumed by the law
itself. It can further be divided into rebuttable presumptions of law and irrebuttable presumptions
of law.

PRESUMPTION
OF LAW

REBUTTABLE IRREBUTTABLE
PRESUMPTION PRESUMPTION

Rebuttable Presumption (praesumptio iuris tantum): Rebuttable Presumptions are certain

presumption which is regarded as evidence of good quality and does not lose their quality until
proven contrary to the presumption. Although it does not easily measure the extent of such
presumption as their validity only exists until they are not proven wrong.

EXAMPLE- if a person who is in possession of some stolen property than it is quite obvious that
he can either be a thief or a receiver.

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Matrimonial offences are one of the best examples to explain any presumption because in such
offence the possibility of getting evidence is nearly low as these offences that take place within the
closed area of matrimonial house. Hence the presumption is very important in such cases/offences.
There are broadly three important provisions regarding the presumption in matrimonial offences
which are:

• Presumption as to abetment of suicide by a married woman within seven years of marriage

covered under Section 113A of Indian Evidence Act.

• Presumption as to dowry death within seven years of marriage covered under Section 113B
of Indian Evidence Act.

• Birth during the marriage is the conclusive proof of legitimacy covered under Section 112
of the Indian Evidence Act.

In State of M.P. v. Sk. Lallu 4, a newly wedded wife was facing severe beating regularly by her in-
laws from the very first day of her marriage, and at last, she ends up dying with 100% of burn
injuries. The Court executed the application of presumption stated under Section 113A and
explained that such presumption can be invoked to punish the accused.

Ir-rebuttable Presumption (praesumptio iuris et de iure)- Such presumptions cannot be ruled out
by any additional probative evidence or argument. Therefore the presumption explained comes
under the roof of conclusive presumption which cannot be proven contrary.

EXAMPLE: A child under the age of seven years is presumed that he is not capable of committing
any crime.

PROVISIONS WHERE THE COURT MAY USE THE PRESUMPTION OF LAW TO

ASCERTAIN CERTAIN FACTS

• Section 114A: Presumption as to absence of consent in certain prosecution for rape

4
1990 Cri. L.J. 129

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 The essential conditions of this section are:

• It should be proved that there was sexual intercourse.

• The question before the court should be whether such intercourse was with or without the
consent of the woman
• The woman must have stated, in her evidence before the court that she had not consented to
the intercourse.

If the mentioned conditions are satisfied the Court shall presume the absence of consent and the
burden of proving consent will be on the accused. If he cannot prove consent he cannot be
acquitted.

• Section 112: Birth during marriage, conclusive proof of legitimacy:

The Latin maxim ‘pater est quem muptice demonstrat’, explains a basic assumption that the person
who marries women is the father of son/ daughter out of wife. Section112 of the Indian Evidence
Act deals with the legitimacy of a child born during the marriage. The Section implies that if a
child is born during the continuance of a valid marriage between the couple, then it is conclusive
proof of that the child is legitimate and the only ground which is available to either of the parties
to prove the illegitimacy is to prove any access to each other in such a way that their marriage was
not consummated.

The essential conditions for the presumption to arise are:-

1. The child should have been born during the continuance of a valid marriage, or if the marriage
was dissolved, within 280 days after its dissolution, the mother remaining unmarried.

2. The parties to the marriage should have had access to each other at any time when the child
could have been begotten.

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The main objective of the lawmaker institute is to provide legitimacy to the child born during a
valid marriage and the legislature also explains that such presumption is not only limited to provide
legitimacy to the child but also it is to maintain the public morality so that the legitimacy of the
child cannot be questioned.

In Gautam Kundu v State of West Bengal5, the Supreme Court in its observations expresses that-

• Courts have no authority to direct blood test to challenge the legitimacy of the child.

• The husband has only one possibility to get rid of such presumption and for that, he must
satisfy the court by proving no- access to consume the marriage.

• The Court should carefully examine the fact that what will be the consequences if the blood
test comes in favour of a husband who is challenging the legitimacy of the child. And what
if the further consequence has a serious impact on the child’s legitimacy or makes the
mother as an impure/ unchaste woman.

Section 110: Burden of proof as to ownership:

Section 110 deals with such presumption and explains it as when a person who is enjoying the
possession of anything and he claims himself as the owner then the court inferences that he is the
real owner. These are generally rebuttable presumptions and do not lose their substantiality until
they are proven contrary by the affecting party.

Presumption of Innocence (ei incumbit probatio qui dicit, non qui negat)-

According to this legal maxim, the burden of proof is with the person who declares the facts, not
the person who denies the fact. The presumption of innocence is the legal principle which means
every person should be considered as an innocent person unless it is proven guilty or until court
believes that the person is in charge of acts prohibited under law.

5
(AIR 1993 SC 2295)

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In, Chandra Shekhar v. State of Himachal Pradesh the High Court made great observations and
mentioned that freedom of any individual is the prime objective of the constitution and such right
cannot be dissolved by any means unless provided by the law itself. It is concluded that unless the
person is proved guilty, he must be presumed as innocent.

DIFFERENCE BETWEEN PRESUMPTION OF FACT AND PRESUMPTION OF LAW

Topic Presumption of Facts Presumption of Law

When presumptions are acknowledged

When presumptions are established
without the help of proof in certain situations
Definition on the basis of facts or groups of
or circumstances where court me presumes
facts or from the collection of facts.
some facts itself.

Position of
Uncertain position. Certain and uniform position.
Presumption

They are always rebuttable and can They are conclusive presumption unless

Performance be challenged after establishing proven with probative evidence.

probative evidence.

Court has no discretionary power, and they are

Discretionary Court enjoys discretionary power,
bound to presume some facts as such facts are
Power of Court either to presume any facts or not.
presumed itself by the law.

They are derived on the basis of Judicial customs & practices, the law under the
Source of
natural law, customary practices, statues are the only sources of presumption of
Presumption
and general mankind experiences. law.

Presumption of Foreign Judicial Presumption of Innocence, Presumption of

Examples
Records, Presumptions of Abetment declared death in absentia etc.

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 as to Suicide by a Married Women
etc.

MIXED PRESUMPTIONS (PRESUMPTION OF FACT AND LAW BOTH):

Mixed presumptions is a blend of different concepts explained above in this article. When the court
in its inferences uses such blend consists of different classification of presumption i.e.,
Presumption of Facts and Presumption of Law then the presumption is considered to be a Mixed
Presumption. The principles of such presumptions are only reflected in the English which
specifically deals with statute of real property. But in the Indian legal system, the principles of
presumptions are expressed specifically and The Indian Evidence Act deals with such principles.
The Indian Evidence Act has mentioned few provisions both for the presumption of law and for
presumptions of facts. The scope of this statute just does not end here rather it also has different
provisions which deal with the discretionary power of Indian Court in raising presumption such
as- Principles of May Presume, Shall Presume and Conclusive Proof.

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 SECTION 4 OF THE INDIAN EVIDENCE ACT, 1872

Section 4, IEA, defines may presume, shall presume and conclusive proof as:
“May presume”. –– Whenever it is provided by this Act that the Court may presume a fact, it may
either regard such fact as proved, unless and until it is disproved, or may call for proof of it.
It is a condition when the court enjoys its discretion power to presume any/ certain/ few facts and
recognize it either proved or may ask for corroborative evidence to confirm or reconfirm the
presumption set by the court in its discretion. Section 4 of the Indian Evidence Act provides that a
fact or a group of facts may be regarded as proved, until and unless they are disapproved. ‘May
Presume’ deals with rebuttable presumption and is not a branch of jurisprudence.

EXAMPLE:

1. The court may presume that an accomplice is unworthy of credit, unless he is corroborated in
material particulars [Section 114(b)]
2. The court may presume suicide by a married woman, having regard to all other circumstances,
that it had been abetted by her husband or by such relative of her husband. [Section 113A]

“Shall presume”. –– Whenever it is directed by this Act that the Court shall presume a fact, it
shall regard such fact as proved, unless and until it is disproved.
It denotes a strong assertion or intention to determine any fact and explains that the court does not
have any discretionary power in the course of presumption of ‘Shall Presume’, rather the court has
presumed facts or groups of facts and regard them as if they are proved until they are disproved by
the other party. Section 4 of the Indian Evidence Act explains that the concept of ‘Shall
Presume’ may also be called ‘Presumption of Law’ or ‘Artificial Presumption’ or ‘Obligatory
Presumption’ or ‘Rebuttable Presumption of Law’ and tells that it is a branch of jurisprudence.

EXAMPLE:

1. The court shall presume the genuineness of every government publication. [Section 84]
2. The court shall presume that the person has committed dowry death when it is shown that soon
before her death, she was subjected to cruelty, or harassment by such person. [Section 113 B]

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3. The court shall presume that the sexual intercourse was without the women’s consent when
she states in her evidence before the court that she did not consent. [Section 114 A]

“Conclusive proof”. –– When one fact is declared by this Act to be conclusive proof of another,
the Court shall, on proof of the one fact, regard the other as proved, and shall not allow evidence
to be given for the purpose of disproving it.
This can be considered as one of the strongest presumptions a court may assume but at the same
time the presumptions are not completely based on logic rather court believes that such
presumptions are for the welfare or upbringing of the society. The general definition of Conclusive
Proof is a condition when one fact is established, then the other facts or conditions become
conclusive proof of another as declared by this Act. The Court in its consideration shall regard all
other facts to be proved, only if one fact of the case is proven without any reasonable doubt. And
if the other facts are proved on the basis of proving of one fact that the court shall not allow any
evidence contrary to other facts which are presumed as conclusive proofs.

EXAMPLE:

1. Section 41 deals with relevancy of certain judgments in probate, etc; jurisdiction

2. Section 112 deals with birth during marriage, conclusive proof of legitimacy
Illustration- A and B married on June 1 and the husband left home to his work for 6 months
later he discovered that her wife is pregnant he divorced the wife and challenges that he is
not liable for paying damages either to his wife or to his illegitimate son. And also explains
that he never consummated his marriage as just after one day of marriage he left his home for
his work. But in this case, the court will conclusively presume that the son born out of his
wife is legitimate because he was with his wife for at least 1 day and shall not allow any
proof contrary to the conclusive proof even if he provides probative evidence.
3. Section 113 deals with proof of cessation of territory.

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 CONCLUSION

Presumptions are arbitrary annexations in law that obviate the necessity of proving a fact. When a
court presumes a fact then there is no need to prove such fact. Thus, we can see that the Indian
Legal System relies upon presumptions that help to give judicial decisions in a better manner.
These presumptions are classified into Presumptions of Law, Presumptions of Fact, and Mixed
Presumptions. The Court also has the power which is discretionary to decide where a presumption
would lie in Law/Fact/ Mistake respectively. To decide this the courts take the help of the Principles
of “Conclusive Proof, May Presume, and Shall Presume”.

A stark difference between English Law and Indian Law, concerning mixed presumptions, is that
while in the case of the former, mixed presumptions lie only in real property statutes, and in the
case of the latter, they are specifically mentioned in the Indian Evidence Act and governs all types
of cases.

In Tukaram v State Of Maharashtra6, This case was decided on considering the facts of Mathura
Rape Case and while adjudicating the case the Court justified the need and necessities of such
presumptions. The Court also explained that Presumptions has a wider scope as they don’t only
help the victim in the fast trial but it also helps in giving direction to the case. Therefore, such
presumption can effectively help the judiciary in providing quick and complete justice to society.

6
1979 2 SCC 143

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 BIBLIOGRAPHY
BOOKS
➢ RATANLAL & DHIRAJLAL, THE LAW OF EVIDENCE, Updated 23’ Enlarged
Edition covering, the criminal law (amendment) act, 2013, lexis nexis

➢ BATUKLAL THE LAW OF EVIDENCE Central Law Agency

➢ Dr. Avtar Singh. PRINCIPLES OF THE LAW OF THE EVIDENCE, Central law Agency

WEBSITES
➢ www.blogipleaders.in
➢ Naivedya Kumar, “Presumption Of Facts And Presumption Of Law”, Legal Services
India, available at: https://www.legalserviceindia.com/legal/article-9250-
presumption-of-facts-and-presumption-of-law.html
➢ Presumptions as to Indian Evidence Act Documents”, Law Teacher,26 August 2021,
available at: https://www.lawteacher.net/free-law-essays/contract-law/presumptions-as-
to-indian-evidence-act-documents-contract-law-
essay.php#:~:text=Presumptions%20are%20inferences%20which%20are,proof%20with
%20respect%20to%20it.
➢ www.livelaw.com

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