University Institute of Legal Studies

THE INDIAN EVIDENCE ACT, 1872

PROJECT REPORT

ON

PRIVILEGED COMMUNICATIONS

SECTION 122-129

SUBMITTED TO: SUBMITTED BY:

Ms. Priya Vishakha Chaudhary

UILS, PU 224/16, 7TH SEMESTER

Chandigarh B. Com LLB(Hons)

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ACKNOWLEDGEMENT

Making a project is not an easy task and cannot be done alone, there is
always some help given by friends family etc. I would like to take this
opportunity to thank all the people due to which this project has been
Completed. Firstly, I would like to thank the teacher of this subject
Ms. Priya for giving me this project and explaining the topic very well
due to which I had a complete understanding of the topic of the project.
Secondly, I would like to thank my friends who helped me in their small little
ways in order to complete this project.
Thank You Everyone!!!

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INDEX

Contents

1) TABEL OF CASES ……………………………………………………4

2) INTRODUCTION ………………………………….………………….5

3) PRIVILEGED COMMUNICATION …….………………….………...6

4) SPOUSAL COMMUNICATION ………..……………………………..7

 SECTION 122 …………………………………………………..7

5) STATE COMMUNICATION…………………………………………10

 SECTION 123 …………………………………………………..10

 SECTION 124 …………………………………………………..12

 SECTION 125 …………………………………………………..12

6) PROFFESIONAL COMMUNICATION………………………………14

 SECTION 126 …………………………………………………..14

 SECTION 127 …………………………………………………..15

 SECTION 128 …………………………………………………..16

 SECTION 129 …………………………………………………..16

7) CONCLUSION………………………………..…………………………18

8) BIBLIOGRAPHY ………………………………………………………19

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TABLE OF CASES

1. Ayesha v. Peerkhan,(1954) Mad 741.

2. Bhalchandra Namdeo Shinde v. The State Of Maharashtra 2003(2) MhLj 580
3. Calcraft v. Guest (1898)1 QB 759.
4. D. Veeraseharan v. State of Tamil Nadu (1992) Cr. L.J. 2168 (Mad).
5. Dagiram Pindilal v. Trilok Chand Jain,(1992) SC 990.
6. Gurunanak Provisions Stores v. Dalhonumal Savanmal, (1994) Guj 31.
7. Jones v. Great Central Railway (1910) AC 4.
8. Kameshwar Pershad v. Amanutulla,(1898) 26 Cal 53
9. Khwaja Nazir Ahmad v. The Crown,(1944) 26 Lah 219
10. M.C.Verghese v. T.J.Ponnam ,AIR 1970 SC 1876.
11. Mandesan v. State of Kerala,(1995) Cr LJ 61.
12. Menaka Sanjay Gandhi v. Ram Jethmalani AIR 1979 SC 468
13. Miajan v. emperor,(1933) Cal 5.
14. Munchershav Bezanji v. The new Dhurumsey S. & W. Company (1880)04 Bom 576.
15. Punjab v. S.S Singh(1961) SC 493.
16. Queen Empress v. Donaghue,(1898)Mad 1,4.
17. R.Ramana v. State, (1971) AP 196.
18. Ram Bharose v. State of UP AIR 1975 SC 704.
19. S.J. Choudhary v. The State 1985 CriLJ 622
20. SP Gupta vs Union of India (1982) SC 149
21. State of U.P. v. Chandra Mohan Nigam, (1977) 4 SCC 345
22. Tukaram v. King Emperor,(1946) Nag385

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INTRODUCTION

The term “law” is used in different senses. In the plain sense, it means any rule, regulation or
canon, a dogma or a norm to which the human actions are required to conform. The entire
corpus juris (body of laws) is broadly classified into two categories:

 Substantive laws, and,

 Adjective laws.

The law of evidence doesn’t come under the purview of substantive or procedural law, but
under ‘adjective law’, which defines the pleading and procedure via which substantive laws
are brought into practice. It is the machinery by which substantive laws are set and kept in
motion. So it can be said that the law of evidence deals with rights, as well as, procedures.

‘Evidence’ is a word derived from the Latin word ‘evidera’ which means to discover clearly,
to ascertain or to prove. The general meaning of the term “evidence” is “the available body of
facts or information indicating whether a belief or proposition is true or valid”.

It has been observed that a sound system of the administration of justice should possess three
ingredients, namely a well-planned body of law based on wise concepts of social justice, a
judicial hierarchy comprised of the Bench and the Bar, learned in the law and inspired by
high principles of professional conduct and existence of suitable generation to ensure fair
trial.

The private communication and protection thereof is another important area in relation to the
right to privacy. The legal rules provided from Section 122 to 129 under The Indian Evidence
Act,1872, which accord protection to communications made between some parties have been
analysed here.

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PRIVILIGED COMMUNICATIONS

Privileged communication is the communication between individuals who are in a protected

relationship by the virtue of which, the details of their communication cannot be disclosed.1
Privileged communication exists to protect the disclosure of information during the
subsistence of confidential or protected relationships. These communications are such that
they may not be used as evidence in a court of law against the persons communicating due to
the specific nature of their relationship. The Indian Evidence Act recognizes various forms of
privileged communication, namely:

1. Spousal Communication

2. Professional Communication

3. State Communication

The privilege of a witness means the right of a witness to withhold evidence to disclose
certain matters. There are certain circumstances in which certain persons are not compelled to
testify (to give evidence). The right is based on the convenience and public policy.  Section
122 to Section 129 of Indian Evidence Act 1872 provide for privileged Communications

There may not be any disclosure of any exchange of information between parties in such a
relationship without consent of the other party to the court or any other person. This protects
the sanctity of these protected relationships.

1
Namit Halakandi, “Privileged communication”, iPleaders  <https://blog.ipleaders.in/privilege-communication-
between-husband-and-wife>

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SPOUSAL COMMUNICATION

Husbands and wives are competent witnesses in all civil proceedings; and in criminal
proceedings against an accused, his or her wife or husband is a competent witness, whether
for or against. Section 122 contains a rule of privilege protecting the disclosure of all
communications, between persons married to one another, made during marriage, except in
certain cases.

“122. Communications during marriage

No person who is or has been married shall be compelled to disclose any communication
made to him during marriage by any person to whom he is or has been married ; nor shall he
be permitted to disclose any such communication , unless the person who made it, or his
representative in interest, consents, except in suits between married persons, or proceedings
in which one married person is prosecuted for any crime committed against the other.”

Spousal communication refers to the communication between a man and his wife. Any
communication between a married couple is considered confidential. Either party is
disallowed from divulging any such information to any third party made within the confines
of a valid, existing marriage. The origin of this principle may be traced back to English
common law which formalized it in the English Evidence (Amendment) Act, 1853. This
concept has been characterized in Indian Jurisprudence as the embodiment of the
“expectation” of secrecy between spouses and the damage such disclosure may have upon the
familial structure.2

Marital privilege or spousal privilege seems to have originated from common law
jurisprudence. The fundamental principle behind this privilege is mentioned in the case of
S.J. Choudhary vs The State,3 which was decided on 26 July 1984, where Justice Khanna
observes-

“So much of the happiness of human life may fairly be said to depend on the inviolability of
domestic confidence that the alarm and unhappiness occasioned to society by invading its
2
S.J. Choudhary v. The State 1985 CriLJ 622.
3
Ibid.

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sanctity and compelling the public disclosure of confidential communications between

husband and wife would be a far greater evil than the disadvantage which may occasionally
arise from the loss light which such revelations might throw on the questions in dispute hence
all communications between them should be held privileged.”

This section ‘ rests on the obvious ground that the admission of such testimony would have a
powerful tendency to disturb the peace of families and to weaken, if not to destroy, that
feeling of mutual confidence which is the most enduring solace of married life.

Conduct may be disposed- Section 122 however, must be interpreted narrowly because it
reduces the scope of admissibility of evidence which may be crucial to the case of the
prosecution. This may be seen as the rationale for the interpretation of section 122 by
Vagyani, J. to mean that only the words said by a spouse can be treated as privileged
communication. If in case a spouse is acting or behaving in a particular manner, his activities,
deviation from any regular practice etc are not covered under section 122. This was affirmed
when a wife was called on to give testimony against her husband in a murder case wherein
she was allowed to testify as to his conduct but not to the conversation that ensued between
the spouses.4

In Ram Bharose v. State of UP,5 the wife’s was that on the early hours of day of murder,
while it was still dark she saw her husband coming down from the roof and then going to
Bhus Kothari and coming again and having naked bath and thereafter wore the same clothes.
She also stated that her husband presented her ornaments. She asked as from the place where
he got them. He told that he had gone to a house to get ornaments. It was the house where the
deceased lived. Justice Venkatramma Iyyer held that the wife could testify the conduct of the
husband but not what he said to her.

EXCEPTION-

Under this section a married person shall not be –

1) Compelled to disclose any communication made to him during marriage by person to

whom he is married, and,
2) Permitted to disclose any such communication, except-
a) When the person who made it or his representative in interest consents, or
b) In suits between married person,
4
Bhalchandra Namdeo Shinde v. The State Of Maharashtra 2003(2) MhLj 580.
5
AIR 1975 SC 704.

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c) In proceedings in which one married person is prosecuted for any crime

committed against the other.

Compelled to disclose any communication- this expression implies that the party concerned
is made or allowed to say or do something by way of disclosing a communication made
during marriage6. A document, even though it contains a communication from husband to a
wife or vice versa, in the hands of third party, is admissible in evidence for in producing it
there is no compulsion on or permission to the wife or husband to disclose communication.

During Marriage – The protection conferred by the section is limited to such matters as
have been communicated during marriage. The Supreme Court has also clarified that any and
all communication between spouses must remain confidential if the communication happened
during the subsistence of the marriage. Whilst determining the admissibility of the evidence
brought by the way of spousal testimony, the date of the communication must be the deciding
parameter and not the date when the communication was sought by the court. In the event
that said communication happened during the marriage but now the marriage has subsided,
the communication would still be privileged.7

Permitted to disclose any such communication – even if one of the spouse is willing to
disclose a communication, he or she will not be permitted to disclose it unless the person who
made it or his representative in interest consents, except in suits or prosecutions between
married persons. the exception to the provisions of section 122 is when the dispute is between
the married parties. The parties may be allowed to bring communication between them as
evidence.

STATE PRIVILIDGE

6
Queen Empress v. Donaghue,(1898)Mad 1,4.
7
M.C.Verghese v. T.J.Ponnam ,AIR 1970 SC 1876.

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The Indian Evidence Act alongside the Constitution of India likewise perceives this right of
privilege. Such benefits can be followed in the majority of the advanced lawful frameworks
of the world. It has been named as 'Crown or Prerogative benefit' in the common law of
United Kingdom and as 'Executive Privilege' in the United States of America.

Section 123. Evidence as to affairs of State.—No one shall be permitted to give any evidence
derived from unpublished official records relating to any affairs of State, except with the
permission of the officer at the head of the department concerned, who shall give or withhold
such permission as he thinks fit.

The ‘privilege’ under Section 123 of the Indian Evidence Act is claimed frequently by the
Government to authorize them not to produce its unpublished records in courts. As per this
section a witness cannot be permitted to give any evidence which is derived from
unpublished records relating to any affairs of state without permission of the officer at the
head of department concerned. The court is bound to accept without question the decision of
the public officer.

‘Unpublished official records relating to any affairs of state’- It is for the court to decide
whether a document falls within the category of “unpublished” official records relating to any
affairs of state. “Affairs of state” is a very wide expression. The earliest interpretation of the
word affairs of the state emphasized on a wider reading of the term to include all State secrets
such as State papers and communication between the governmental departments and its
officials with regards to which privilege can be granted to the State with respect to guardian
of public interest. This view was watered down in the Tukaram8 case wherein only those
matters whose disclosure would-(i) prejudicial to public interest (ii) relating to security of
state (iii) diplomatic ties with the government and (iv) efficient working of administration
could be included in the ambit of affairs of the State.

Another significant decision in India regarding privilege of public documents was State of
Punjab v. S.S Singh,9 which involved a combined reading of Section 123 and Section 162 of
the Indian Evidence Act. The government for this situation asserted benefit as for information
identifying with the minutes of meeting between the Council of Minister and the State Public
Service Commission for the reestablishment of a legal officer. The courts amid this period

8
Tukaram v. King Emperor,(1946) Nag385.
9
(1961) SC 493.

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received the 'Hands-off' approach, holding that the Court can't hold an enquiry into the
assessment of open intrigue which may emerge from the revelation of archives and the sole
referee for this assessment is the specialist which has the guardianship of the records. The
court accentuated on the way that the courts could just hold a preparatory enquiry as for the
question if the records identified with the undertakings of the State. The court in this case
also introduced the doctrine of ‘class’ doctrine, which meant that a class of documents could
be restrained from production simply not because of the information present in them but
because of them being classified so.

the privilege claims came in the much acclaimed case of SP Gupta vs Union of India10 case.
The court in this case specifically overruled the earlier position in Sukhdev and brought the
legal provision with respect to privilege close to the English position. The court talking
through Justice Bhagwati examined long the significance of appropriate to know and ideal to
free discourse and expression in the working of the majority rule government. The court
likewise communicated worry over the teaching of 'class cases' holding it to be against the
fundamental idea of open Government.

Who shall give or withhold permission as he thinks fit- the Head of the Department, who
is in possession of the document is the exclusive judge of the fact whether the unpublished
records are protected, from production on the ground of their being related to affairs of state.
The court simply gives effect to the decision of the Head of the Department by adding its
own command to it but the court has no power to examine the document in order to verify the
correctness of the allegations or the ground on which the privilege was claimed.11

Section 124. Official communications.—No public officer shall be compelled to disclose

communications made to him in official confidence, when he considers that the public
interests would suffer by the disclosure.

if a communication was made to an official of the Indian government in “official

confidence”; such communication would also be privileged if the officer believes its
disclosure to be against public interest.

There are two matters involved in Section 124.-

10
(1982) SC 149.
11
Khwaja Nazir Ahmad v. The Crown,(1944) 26 Lah 219.

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1) Where the document is a communication made to a public officer in official

confidence:
2) Where public interest would suffer by its disclosure.

The first question is for the court to decide and as for the second the public officer is the sole
judge as to whether by disclosure, public interest would suffer.12

Foundation of the claim of the privilege rests on consequences of disclosure of

communication made in official confidence whose publication the officer to whom it is made
considers contrary to the public interest.13 A party in a civil suit sought production of the
income tax returns of the opposite party. The court refused to summon the document asked
for considering it to be a privileged document. This was held to be not justified. It was up to
the commissioner to claim privilege when a document has been summoned. It is then for the
court to decide whether the privilege is to be granted or not.14

the Supreme Court has clarified that in matters such as that of dismissal of a public servant
due to mal-fide activities, the state cannot claim privilege when the court requests the
production of his service records.15

Section 125. Information as to commission of offences.—No Magistrate or Police officer

shall be compelled to say whence he got any information as to the commission of any offence,
and no Revenue officer shall be compelled to say whence he got any information as to the
commission of any offence against the public revenue." Explanation.—"Revenue officer” in
this section means an officer employed in or about the business of any branch of the public
revenue

Section 125 entitles a police officer to refuse to disclose the source of his information as to
the commission of any offence. On grounds of public policy, the source of information of
offence against the laws should not be divulged. If the names of the informers and the
channel of communication are not protected from disclosure, no one would be forthcoming to
give such information. This privilege is necessary for creating confidence and offering
encouragement to informants. It is the duty of every citizen to communicate to his
government any information which he has of the commission of an offence against the laws.
12
Dr. V Nageswara Rao, The Indian Evidence Act 1sted., 2012).
13
R.Ramana v. State, (1971) AP 196.
14
Dagiram Pindilal v. Trilok Chand Jain,(1992) SC 990.
15
State of U.P. v. Chandra Mohan Nigam, (1977) 4 SCC 345.

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To encourage him in performing this duty without fear of consequences, the law holds such
information to be among secrets of state. Courts of justice, therefore, do not compel or allow
the discovery of such information, either by the subordinate officer to whom it is given or by
any other person, without the permission of the government16 .

Any information about the commission of an offence given to a police or revenue officer is a
privileged. One of the circumstances in which police may be compellable to disclose the
source of their information is when the police power is being abused in league with the
informer, as , for example, where the witness for the prosecution was himself the person who
invited the accused to his house where the police was waiting for him and he was arrested on
the charge of possessing of drugs which was then and there planted.

PROFFESIONAL PRIVILEDGES

Professional privileged communication refers to the communication between a legal advisor

and his client. The communication between two such persons in furtherance of the
professional employment of the advisor is protected and the legal advisor cannot be made to
disclose such information.

Section 126. Professional communications.—No barrister, attorney, pleader or vakil shall

at any time be permitted, unless with his client’s express consent, to disclose any
communication made to him in the course and for the purpose of his employment as such
16
Sudipto Sarkar and V. R. Manohar, Sarkar on Evidence, 14'11 Ed., 1993, Vol2, 1809.

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barrister, pleader, attorney or vakil, by or on behalf of his client, or to state the contents or
condition of any document with which he has become acquainted in the course and for the
purpose of his professional employment, or to disclose any advice given by him to his client
in the course and for the purpose of such employment: Provided that nothing in this section
shall protect from disclosure—

(1) Any such communication made in furtherance of any 1[illegal] purpose; 2[illegal]
purpose;"

(2) Any fact observed by any barrister, pleader, attorney or vakil, in the course of his
employment as such, showing that any crime or fraud has been committed since the
commencement of his employment. It is immaterial whether the attention of such barrister,
2[pleader], attorney or vakil was or was not directed to such fact by or on behalf of his
client. Explanation.—The obligation stated in this section continues after the employment has
ceased

A lawyer is under a moral obligation to respect the confidence reposed him and not to
disclose communications which have been made to him in professional confidence, i.e.,

1) in the course and for the purpose of his employment, by or on behalf of his clients, or
2) to state the contents of conditions. of documents with which he has become
acquainted in the course of his professional employment, without the consent of his
client.

Section 126 gives legal sanction to this obligation.

This section does not protect from disclosure –

1) any communication made in furtherance of any illegal purpose:

2) any fact observed in the course of employment showing that any crime or fraud has
been committed since the commencement of the employment.

The section not only protects the legal advisers from disclosing communication made to
him by his client when interrogated as a witness, but he is not permitted to do even if he is
willing to give evidence unless with the express consent of his client.17 This principle is
based on the fact that its inexistence would render advocates incapable of defending their

17
Mandesan v. State of Kerala,(1995) Cr LJ 61.

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clients. Clients would constantly worry about being exposed by their attorney and would
not be inclined to share the entirety of details of their case. In the absence of such a
prohibition, the solicitation of the best possible legal advice would not be possible.18

English and Indian Law- The law relating to professional communication between legal
practitioners and client is the same in India as in England with the exception that in England
the word ‘ criminal purpose’ are used for the words ‘illegal purpose’.

The rule is limited to legal advisers. Barristers, attorneys, pleaders, vakil and mukhtars are all
prevented from disclosing the communication.19 No privilege attaches to communication to
an attorney or pleader consulted as a friend and not as an attorney or pleader.

During the existence of the relationship- The bar does not apply to communications made
before the relationship came into existence or after it has ceased. But if the communication is
made during the existence of the relationship the privilege does not het terminated by the
termination of the litigation or the death of the parties.20

Section 127. Section 126 to apply to interpreters, etc.—The provisions of section 126 shall
apply to interpreters, and the clerks or servants of barristers, pleaders, attorneys, and vakils.

The privilege given by Section 126 to legal advisers is, by the provisions of Section 127,
extended to interpreters and the clerks or servants of barristers, pleaders, attorneys, and
vakils. As it is not possible for lawyers to transact all their business in person and they have
to employ clerks or agents, the privilege necessarily extends to facts coming to their
knowledge in the course of their employment. The protection extends to all the necessary
organs by which such communications are effected and therefore an interpreter, or an
intermediate agent is under the same obligations as the legal adviser himself.

Section 128. Privilege not waived by volunteering evidence.—If any party to a suit gives
evidence therein at his own instance or otherwise, he shall not be deemed to have consented
thereby to such disclosure as is mentioned in section 126; and if any party to a suit or
proceeding calls any such barrister, 1[pleader], attorney or vakil as a witness, he shall be
deemed to have consented to such disclosure only if he questions such barrister, attorney or
vakil on matters which, but for such question, he would not be at liberty to disclose.—If any
party to a suit gives evidence therein at his own instance or otherwise, he shall not be

18
Menaka Sanjay Gandhi v. Ram Jethmalani AIR 1979 SC 468
19
Miajan v. emperor,(1933) Cal 5.
20
Ayesha v. Peerkhan,(1954) Mad 741.

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deemed to have consented thereby to such disclosure as is mentioned in section 126; and if
any party to a suit or proceeding calls any such barrister, 1[pleader], attorney or vakil as a
witness, he shall be deemed to have consented to such disclosure only if he questions such
barrister, attorney or vakil on matters which, but for such question, he would not be at
liberty to disclose."

Section 128 refers to implied waiver;, and says that the privilege is not waived if a party to
suit gives evidence therein at his own instance or otherwise. Section 128 further says that the
privilege is not also lost by merely calling the legal adviser as a witness unless a party
questions him on the particular point. The privilege belongs to the client and therefore he
alone can waive it.

It is clear that that the privilege can be waived by the client if his legal adviser acting as his
agent. Where an explanation of the basis for that advice was given, either by the defendant or
his solicitor, privilege was waived and the crown would not be prevented from questioning
the defendant on the advice or the background to that advice.21

Section 129. Confidential communications with legal advisers.—No one shall be compelled
to disclose to the Court any confidential communication which has taken place between him
and his legal professional adviser, unless he offers himself as a witness, in which case he
may be compelled to disclose any such communications as may appear to the Court
necessary to be known in order to explain any evidence which he has given, but no others.

Sections 126, 127 and 128 prevent a legal adviser or his clerk, servant, etc., from disclosing
confidential communications made in the course of professional employment. By Section 129
a similar protection is afforded to the client which says that no one shall be compelled to
disclose confidential communication which has taken place between himself and his legal
adviser, unless he himself offers as a witness ; in which case he can be compelled to disclose
any such communication which the court thinks necessary to explain the evidence which he
has.

Section 129 applies where a client is interrogated, whether he is a party to a suit or not.
Section 129 states that no person shall be compelled to disclose in the Court any
communication between him and his legal adviser unless he offers himself as witness. Thus,
Section 129 makes a person immune from compulsory process. This immunity may extend to
third parties, such as consultant who are recruited to help with the preparation of the case for
21
Kameshwar Pershad v. Amanutulla,(1898) 26 Cal 53.

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trial. However, once the material has got out, it should not be kept out of Court on account of
its confidential nature any more than would any other confidential matter.22

Also, if a party becomes a witness of his own accord he shall, if the Court requires, be made
to disclose everything necessary to the true comprehension of his testimony.23In a recent case,
an unsigned and undated letter which was allegedly written by the advocate-accused to his
client-terrorist to remain absconding was held to be professional communication and not ‘
abetment' and thus could not be used against the advocate.24

But in another case, the Gujarat High Court held that disclosure was allowed where the client
desired to obtain decree for money on basis of forged promissory note.25The rule is
established for the protection of the client, not of the lawyer, and is founded on the
impossibility of conducting legal business without professional assistance, and on the
necessity, in order to render that assistance effectuated, of serving full and unreserved
intercourse between the two.26

CONCLUSION

Privacy is a necessary element for the protection of organisational autonomy, gathering of

information and advice, preparation of positions, internal decision-making, inter-
organisational negotiations, and timing of disclosure. Privacy is thus not a luxury for
organizational life; it is a vital lubricant of the organisational system in free societies. Privacy
of communication received legal protection in India under Sections 122 - 129 of the Indian
Evidence Act, 1872.

The Indian Evidence Act protects certain communications from being disclosed due to the
nature of the relationship between the parties to whom such communications are being made.
The act distinguishes between them upon the basis of the relationships. This privilege

22
Calcraft v. Guest (1898)1 QB 759.
23
Munchershav Bezanji v. The new Dhurumsey S. & W. Company (1880)04 Bom 576.
24
D. Veeraseharan v. State of Tamil Nadu (1992) Cr. L.J. 2168 (Mad).
25
Gurunanak Provisions Stores v. Dalhonumal Savanmal, (1994) Guj 31.
26
Jones v. Great Central Railway (1910) AC 4.

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however, is not absolute. It may be violated in various cases that have either been specified in
the statute itself or in various instances by the courts in Indian Jurisprudence.

BIBLIOGRAPHY

1) Avatar Singh, Principles of the Law of Evidence (2008) Central Law Agency, New
Delhi.
2) Sarkar And Manohar, Sarkar on Evidence (1999), Wadhwa and Co. Nagpur.
3) Batuk Lal, The Law Evidence, (2018), Central Law Agency, New Delhi.

Webliography

1) https//indiacode.nic.in
2) www. Wikipedia.org
3) www. Legalservice.com
4) www. Maupatrafast.com

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