Section 63 BSA: The 65B Certificate Is Gone — Hash Values, Part B and the Questions Nobody Has Answered

Evidence Law Comment by Akinchan Aggarwal, Advocate — B.A. (Hons.) Gold Medalist, LL.B., LL.M. (Disputes Resolution), UGC–NET, Ph.D. (pursuing)

For ten years the answer to "how do I prove this CCTV footage?" was a single sentence: get a certificate under section 65B(4). One page, one signature, from whoever was in charge of the device.

That answer is now wrong.

Since 1 July 2024, section 65B has been replaced by section 63 of the Bharatiya Sakshya Adhiniyam, 2023, and the certificate is no longer a page you draft. It is a statutory form set out in the Schedule, in two parts. Part A is signed by the party. Part B must be signed by "an expert" — a word the Adhiniyam nowhere defines. Both parts must state the hash value of the record. And the certificate must be filed "at each instance where it is being submitted for admission".

In May 2026 the Supreme Court was asked to strike the whole thing down as manifestly arbitrary. It refused — and then, in the same breath, expressly left open the question that actually decides cases.

Where this leaves you. The provision is constitutionally safe. Who may sign Part B is partly answered. Whether Part B is mandatory at all is answered by nobody. And in every trial and appeal that was pending on 30 June 2024 — which will be many of them for years yet — you must still file the old section 65B(4) certificate, not this one.

Contents

1. What Changed on 1 July 2024
2. The Schedule — Part A and Part B
3. Pune Bar Association (2026) — and What It Did Not Decide
4. Who Is "an Expert"?
5. Is Part B Mandatory at All?
6. Does Anvar and Arjun Panditrao Survive?
7. The Back Door: Section 57 and Primary Evidence
8. "At Each Instance" — the Unlitigated Phrase
9. The Transitional Trap
10. What to Actually Do — a Checklist
11. Frequently Asked Questions

1. What Changed on 1 July 2024

Sub-sections (1), (2), (3) and (5) of section 63 are close to a verbatim re-enactment of section 65B. The change is concentrated in sub-section (4) and in the Schedule it introduces.

Point	s 65B, Evidence Act	s 63, BSA
Who signs the certificate	A person occupying a responsible official position in relation to the device, or the management of the relevant activities	That person and an expert
Form	None prescribed	The Schedule, Part A and Part B
Hash value	Not required	Required — MD5, SHA1, SHA256 or other legally acceptable standard, with the hash report enclosed
How often	Not specified	"At each instance where it is being submitted for admission"
Devices covered	"Computer"	"Computer or any communication device" — phones are now beyond argument
Storage media	Optical or magnetic media	Optical, magnetic or semiconductor memory
Configurations	Silent	Standalone, computer system, computer network, computer resource, or through an intermediary — s 63(3)(a) to (e). Cloud storage is expressly covered.
Regular use	Used regularly to "store or process"	Used regularly to "create, store or process"

Two drafting points worth knowing

First, a dropped Explanation. Section 65B(5) had clauses (a), (b) and (c), plus an Explanation defining "derived from" as derivation "by calculation, comparison or any other process". Section 63(5) has only clauses (a) and (b). Clause (c) and the Explanation are gone — but the words "derives from" survive in s 63(2)(d), now undefined. That is a live interpretive gap.

Second, an old error repeated. Section 65B(4) required the certificate to state matters "to the best of the knowledge and belief" of the person stating them. In Arjun Panditrao, Nariman J observed that "the word 'and' between knowledge and belief in Section 65B(4) must be read as 'or', as a person cannot testify to the best of his knowledge and belief at the same time." Section 63(4)(c) repeats the same phrase verbatim. The Schedule, meanwhile, has the deponent "solemnly affirm and sincerely state" — an unqualified affirmation that sits awkwardly with the sub-section's lower standard.

2. The Schedule — Part A and Part B

The Schedule is headed CERTIFICATE [See section 63(4)(c)] and is in two parts.

Part A — to be filled by the Party

The deponent identifies himself, then ticks the source: Computer / Storage Media, DVR, Mobile, Flash Drive, CD/DVD, Server, Cloud, Other. He gives make, model, colour, serial number and IMEI / UIN / UID / MAC / Cloud ID. He then declares that the device was under lawful control, was working properly, that information was regularly fed in during the ordinary course of business, and that any malfunction did not affect the record or its accuracy. He states whether the device is owned, maintained, managed or operated by him. Then the key line:

"I state that the HASH value/s of the electronic/digital record/s is ___________, obtained through the following algorithm: SHA1 / SHA256 / MD5 / Other (Legally acceptable standard)."

(Hash report to be enclosed with the certificate)

Name and signature, date, time in IST to the hour in 24-hour format, and place.

Part B — to be filled by the Expert

Here is the thing nobody expects on first reading. Part B is almost entirely a duplicate of Part A. The same identification block. The same device tick-boxes. The same make, model, colour, serial number and identifiers. The same hash-value line with the same algorithm boxes. The same enclosure requirement.

What it adds is: a signature line reading "Name, designation and signature" — where Part A says only "Name and signature".

That is the whole of the difference on the face of the form.

Why this matters to the argument. Part B contains no independent attestation of methodology, chain of custody, imaging process, write-blocking, or the integrity of the extraction. It asks the expert to certify the same facts the party has just certified. If the object were genuine forensic assurance, Part B would ask what the expert did. It does not. That is the strongest textual argument that Part B is a drafting redundancy rather than a substantive safeguard — and it is the argument being made in the commentary.

One further gap. Section 63(4)(a) requires the certificate to describe the manner in which the record was produced, and s 63(4)(b) requires device particulars showing production by a s 63(3)(a)–(e) device. Neither Part of the Schedule asks for that in narrative form. The Schedule is narrower than the sub-section it implements. The prudent course is to file the Schedule form plus a short narrative covering (4)(a) and (4)(b), rather than relying on the form alone.

3. Pune Bar Association (2026) — and What It Did Not Decide

Pune Bar Association v. Union of India, W.P. (C) No. 599 of 2026, decided 22 May 2026 by a Bench of Chief Justice Surya Kant, Joymalya Bagchi and Vipul M. Pancholi JJ, is at present the only decision of the Supreme Court on section 63.

The challenge was that s 63(4) read with the Schedule is manifestly arbitrary, because the hash value and the expert signature impose an onerous precondition on ordinary litigants.

What the Court held

On the rationale for tightening the regime:

"Electronic record is a unique species of evidence which is liable to continuous mutation and modification affecting its authenticity, integrity and intrinsic evidentiary value. Challenges to admissibility and probative value of electronic records are further accentuated with the advent of artificial intelligence and deepfake technology."

On the hash value, in a sentence that will be quoted for years:

"Hash value of an electronic data is synonymous with an electronic fingerprint and provides a sure way of identifying and verifying digital data. The necessity of incorporating the hash value of the electronic record in the certificate is thus to ensure its authenticity and integrity, and cannot be said to lack a rational nexus with the object of the Act. Similarly, certification by an expert in Part B provides an additional layer of authenticity to the secondary electronic evidence. For these reasons, we are of the considered view that the new provision has a clear and rational nexus with the object of the law and cannot be said to be either arbitrary or unreasonable so as to suffer from the vice of manifest arbitrariness."

What the Court did not do — and this is the part the reporting skips

Four things should temper how heavily this judgment is leaned on.

1. It was disposed of at the admission stage without notice to the Union of India. The Court said so itself. This is not a reasoned constitutional adjudication after full adversarial argument.
2. It expressly kept the question of law open. On the expert issue the Court said in terms: "As we are not inclined to admit the matter and issue notice upon the Union of India, we refrain from giving any conclusive opinion on this issue and keep the question of law open."
3. It does not cite Anvar P.V. or Arjun Panditrao at all. The two decisions that govern this field are simply not discussed.
4. It does not address whether Part B is mandatory, and it does not address "at each instance".

So the correct statement of its effect is narrow: section 63(4) survives constitutional challenge, and the Madras High Court's restrictive reading of who may sign Part B is no longer binding. Beyond that, it settles less than the headlines suggest.

4. Who Is "an Expert"?

The Adhiniyam does not say. Section 63 uses the word and defines nothing. There are three candidate readings, and the courts have now closed off one of them.

Reading	Status
(i) The Part A deponent signs both parts	Textually awkward — the Schedule contemplates two persons — but not judicially excluded
(ii) Any person with genuine expertise in computer science and cyber forensics	Supported by Pune Bar Association, on the Court's own reasoning, but as an open question rather than a binding ratio
(iii) Only an Examiner of Electronic Evidence notified under s 79A of the IT Act, 2000	No longer binding. The Madras High Court so held in R v. B; the Supreme Court has said that finding "shall not be treated as a binding precedent"

The argument that won

It turns on a single drafting feature, and it is worth having at your fingertips.

Section 39(1) BSA is the general expert provision — the successor to s 45 of the Evidence Act — and it now extends to "a point of foreign law or of science or art, or any other field". Section 39(2) makes the opinion of a s 79A Examiner of Electronic Evidence a relevant fact, with an Explanation that such an Examiner "shall be an expert".

The Supreme Court's reasoning:

"If the two sub-sections are read harmoniously, it is possible to hold, in addition to entities notified as Examiner of Electronic Evidence under Section 79A, if the Court is satisfied, on the basis of unimpeachable material, that any other person has special skill and expertise in computer science and cyber forensics, opinion of such person may be held relevant as an expert with regard to electronic/digital record and such person may sign Part B of the Schedule as an expert. We are further fortified to make such observation as sub-section (2) of Section 39 (unlike 63(4) and erstwhile 65B) is not prefaced by a non-obstante clause so as to exclude the operation of sub-section (1) from the arena of electronic records."

In short: s 39(2) adds Examiners to the class of experts; it does not restrict the class to them. That is the argument to run when you tender a Part B certificate signed by an unnotified forensic specialist, and you should expect to lead "unimpeachable material" on his qualifications.

Why this was not an academic problem

Reading (iii) was unworkable on the ground. Section 79A notifications are issued entity by entity, and for years there were only about fifteen notified Examiners in the entire country. The Madras High Court, directing MEITY to act, recorded that it was "surprising to note that no expert has been notified in the State of Tamil Nadu" and that the absence of experts "would result in denial of the right of access to justice which is a fundamental right".

MEITY has since moved. Six further Examiners were notified on 9 July 2026 — including CFSL New Town Kolkata, the Directorate of Forensic Science Laboratories at Santacruz Mumbai, the National Forensic Sciences University at Curti in Goa, the Navy Cyber Group's laboratory in New Delhi, the Cyber Forensic Division of the State FSL Jaipur, and the BSF Central Drone Forensic Lab at Chhawla. That is real improvement. It is still nothing like national coverage.

5. Is Part B Mandatory at All?

No court has decided this. Not the Supreme Court in Pune Bar Association, which did not address it. Not the Madras High Court, whose observations were obiter and are now stripped of precedential force. This is the single biggest open question in the area.

What we do have is practice, and the practice is instructive.

In Ashutosh Gupta v. M/s Hemant Sahai Associates, CS(COMM) 148/2026, decided 13 February 2026, the plaintiff before the Delhi High Court filed a declaration on oath under s 63 read with Order XI Rule 5 CPC together with a Part A hash-value certificate, and applied for exemption from filing the Part B expert certificate. The application was allowed, subject to just exceptions. The order anchors the practice in Rule 24, Chapter XI of the Delhi High Court (Original Side) Rules, 2018, which already required electronic records to be encrypted with a hash value disclosed in a memorandum on affidavit.

That is not an isolated order. Since July 2024 there has been a steady line of Delhi High Court orders granting time — typically two to six weeks — to file the s 63(4)(c) certificate at the filing stage, and in some matters granting outright exemption.

How to read this. These are interlocutory orders, not reasoned judgments. They bind nobody. But they tell you what actually happens: in commercial and IP practice the Delhi High Court is treating the certificate as a filing formality capable of being deferred, and is willing to accept Part A plus a hash affidavit without Part B. Whether that survives a contested trial where authenticity is genuinely in issue is a different question, and it has not yet been tested.

6. Does Anvar and Arjun Panditrao Survive?

Almost certainly yes — but note that no decision squarely so holds.

The chain that got us here is worth restating, because it is still the framework:

Case	Held
Anvar P.V. v. P.K. Basheer, (2014) 10 SCC 473 (3 judges)	ss 65A and 65B are a complete code; the certificate is a condition precedent. Navjot Sandhu overruled.
Tomaso Bruno v. State of U.P., (2015) 7 SCC 178	Allowed secondary evidence of electronic records under s 65. Later held per incuriam.
Sonu @ Amar v. State of Haryana, (2017) 8 SCC 570	Absence of the certificate is a defect in the mode of proof, not per se inadmissibility — so a belated objection may be shut out.
Shafhi Mohammad v. State of H.P., (2018) 5 SCC 311 (2 judges)	Certificate not always mandatory where the party is not in possession of the device. Overruled.
Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal, (2020) 7 SCC 1 (3 judges)	The certificate is mandatory. Tomaso Bruno per incuriam; Shafhi Mohammad overruled. See below.

Arjun Panditrao did four things that still matter under s 63:

1. The certificate is a condition precedent, and oral evidence is no substitute. "Oral evidence in the place of such certificate cannot possibly suffice as Section 65B(4) is a mandatory requirement of the law."
2. No certificate is needed if the original is produced. The owner of a laptop, tablet or phone may step into the witness box and prove the device is owned or operated by him. Where the computer is part of a system or network that cannot physically be brought to court, the certificate route is the only route.
3. The certificate can be produced at any stage before the hearing concludes, and where a third party will not give it, the party applies to the Judge, who may compel production. Lex non cogit ad impossibilia.
4. The signatory may be any one of several persons occupying a responsible official position in relation to the device or in management of the relevant activities.

That machinery transposes intact. The Judge's power under s 165 of the Evidence Act is now s 168 BSA, in substantively identical terms. Section 91 CrPC is now s 94 BNSS — and materially wider, since it expressly covers "electronic communication, including communication devices, which is likely to contain digital evidence" and permits the order to issue in electronic form. Section 311 CrPC is s 348 BNSS and s 207 CrPC is s 230 BNSS.

The clearest judicial signal came on 10 March 2026. In Pooranmal v. State of Rajasthan, 2026 INSC 217, a Bench of Vikram Nath, Sandeep Mehta and N.V. Anjaria JJ set aside a conviction because call detail records had gone in without a certificate, holding again that oral evidence of telecom officials was no substitute. Throughout, the Court referred to "the certificate under Section 65-B of the Evidence Act [Section 63 of the BSA]" — bracketing the two provisions as corresponding.

That is not a holding that the old law governs s 63. But given that sub-sections (1), (2), (3) and (5) are near-verbatim re-enactments, the orthodox inference is that the Anvar and Arjun Panditrao jurisprudence carries over, subject to whatever the genuinely new words independently require. State it that way in court; do not overstate it.

7. The Back Door: Section 57 and Primary Evidence

This point deserves far more attention than it is getting, and it may end up doing more work than anything in section 63.

Arjun Panditrao held that no certificate is required if the original is produced — because then the record is primary evidence, and s 65B is a secondary-evidence provision.

Now look at section 57 BSA, the successor to s 62 of the Evidence Act. It carries four new Explanations (4 to 7) which deem certain electronic records to be primary evidence, including where multiple files are created simultaneously or sequentially, where a record is produced from proper custody, each stored copy of a simultaneously transmitted video recording, and each automated storage location including temporary files.

Put the two together. If a record qualifies as primary evidence under s 57, then on Arjun Panditrao's own logic no s 63 certificate is needed at all — no hash value, no Part B, no expert. The s 57 Explanations may have quietly created a very large exemption from the regime that s 63 was tightening. The commentary has flagged that the Explanations "appear to bypass the mandatory requirement of satisfying the preconditions" and "fall foul of Section 63".

There is a further difficulty. "Proper custody" is not defined. Grounding the authenticity of a record in the identity of its custodian rather than in the integrity of the record itself is a real departure from principle — and it sits oddly beside a section whose whole design is to authenticate the record by its hash.

Against that, s 61 BSA says an electronic record has the same legal effect as any other document "subject to section 63". Those three words are the textual hook for arguing that s 63 remains a complete code and that s 57 cannot be used to sidestep it. Expect this to be litigated. It has not been yet.

8. "At Each Instance" — the Unlitigated Phrase

Section 63(4) requires the certificate to be submitted along with the electronic record "at each instance where it is being submitted for admission". These words have no counterpart in s 65B(4).

On their face they require a fresh certificate every time the record is tendered — not once per case. If the same CCTV footage is filed at the charge stage, again in the trial court, and again in an appeal, the words suggest three certificates.

No court has construed the phrase. Not one judgment, order or reported observation that I have been able to find. Until one does, the cautious course is obvious: file a fresh certificate at each tendering, and do not assume the one on the trial court record carries forward.

9. The Transitional Trap

This is where practitioners are most likely to go wrong, and the error is not recoverable by amendment.

Section 170(2) BSA provides that where, immediately before 1 July 2024, any application, trial, inquiry, investigation, proceeding or appeal was pending, it "shall be dealt with under the provisions of the Indian Evidence Act, 1872 ... as if this Adhiniyam had not come into force."

Three consequences follow.

1. The trigger is the pendency of the proceeding, not the date of the record. A video shot in 2019 tendered in a suit filed in 2025 is governed by the BSA. A video shot in 2025 tendered in a trial that was pending on 30 June 2024 is governed by the Evidence Act.
2. Appeals are expressly saved. An appeal pending on 1 July 2024 continues under the old Act.
3. So in an old trial you must file a section 65B(4) certificate — not a Schedule certificate. If in 2027 you file a supplementary certificate in a trial that began in 2021, the correct instrument is the old one-page certificate, with no hash value and no expert signature.

The Madras High Court applied the rule cleanly in R v. B, 2024 SCC OnLine Mad 6084 (30 October 2024): "The matrimonial petition was filed in 2019 itself. Therefore, the Indian Evidence Act, 1872 would apply and not the Bharatiya Sakshaya Adhiniyam, 2023."

The consequence for the profession is that two certification regimes will run side by side in the same courtroom for years — for the life of every trial and appeal pending on 30 June 2024. The commentary makes the sharper point that a BSA-compliant certificate filed to cure a defect in an old trial would not be a cure at all but a fresh evidentiary submission, which is not what Arjun Panditrao contemplated when it permitted late production.

One question remains open and unlitigated: whether a Schedule certificate voluntarily filed in a pre-July 2024 proceeding is bad (wrong statute) or merely surplusage (it contains everything s 65B(4) requires, and more). Common sense and the "as if this Adhiniyam had not come into force" language favour surplusage. But that is argument, not authority.

10. What to Actually Do — a Checklist

Before you file

1. Fix the regime first. Was the proceeding pending on 30 June 2024? If yes, s 65B(4). If no, s 63 and the Schedule. Get this wrong and nothing else helps.
2. Ask whether you need a certificate at all. If you can produce the original device and put its owner or operator in the witness box, Arjun Panditrao says you do not. Consider also whether s 57 makes the record primary evidence — but do not rely on that alone while the point is untested.
3. Generate the hash before anything else touches the file. Compute MD5, SHA1 or SHA256 on the copy you will actually tender, record the algorithm, and enclose the hash report. The Schedule requires the report, not merely the value.
4. Record the device particulars while you have the device. Make, model, colour, serial number, and IMEI, MAC or Cloud ID. Going back for these months later is painful and sometimes impossible.

Drafting the certificate

1. Use the Schedule form itself. Do not paraphrase it. Courts are being handed the form, and a bespoke certificate invites an objection you do not need.
2. Add a narrative annexure covering s 63(4)(a) and (b) — how the record was produced, and particulars showing production by a device within s 63(3)(a) to (e). The Schedule does not ask for these; the sub-section does.
3. For Part B, lead the expert's credentials. After Pune Bar Association the signatory need not be a s 79A Examiner, but the Court must be satisfied on "unimpeachable material" of special skill and expertise in computer science and cyber forensics. Annex the CV and qualifications. Do not simply have somebody sign.
4. Date and time in IST, 24-hour format. The form asks for it; omissions are the kind of thing opponents notice.

If you cannot get the certificate

1. Apply to the Court — promptly and in writing. Arjun Panditrao holds that once you apply, you have done all you can. The application is what shifts the burden; an oral grumble at the hearing is not.
2. Ask under s 168 BSA (Judge's power to order production) and, in a criminal matter, s 94 BNSS for a summons to produce, with s 348 BNSS if a witness must be recalled.
3. Move before the hearing concludes. The certificate may be produced at any stage up to that point, and courts have permitted late production on the footing that it causes no irreversible prejudice — but do not test the limits.

If you are opposing

1. Take the objection at the tendering stage. Sonu @ Amar treats the missing certificate as a defect in the mode of proof, which means a belated objection can be shut out. Raising it first in appeal may be too late.
2. Check the hash actually matches the record on the file. That is what the hash is for, and it is the one thing on the form nobody verifies.
3. Check "each instance". If the record is being tendered afresh, ask whether a fresh certificate accompanies it.

11. Frequently Asked Questions

What replaced section 65B of the Evidence Act?

Section 63 of the Bharatiya Sakshya Adhiniyam, 2023, read with THE SCHEDULE. Section 65A is now s 62. The certificate is no longer free-form: it must be in the Schedule's Part A and Part B, must disclose the hash value, and must be signed by the person in charge and an expert.

Is the section 63 certificate mandatory?

For an electronic record led as secondary evidence, yes. The sub-section says the certificate "shall be submitted", and the Supreme Court has repeatedly held under the corresponding s 65B(4) that oral evidence is no substitute. No certificate is required if you produce the original device and prove it through its owner or operator.

Who can sign Part B?

An Examiner of Electronic Evidence notified under s 79A of the IT Act, 2000 — or, on Pune Bar Association, any person the Court is satisfied on unimpeachable material has special skill and expertise in computer science and cyber forensics. The Madras High Court's contrary view is no longer binding. The Supreme Court kept the question of law open, so lead the expert's credentials properly.

Is Part B required in every case?

Nobody has decided. The Delhi High Court has in practice granted exemption from Part B where Part A and a hash affidavit are on record, but those are interlocutory orders, not precedent. Assume it is required, apply for exemption if you cannot obtain it, and do not build a case on the assumption that it will be excused.

Do I need a certificate for a WhatsApp screenshot?

If you tender it as a printout or copy, yes — that is a computer output within s 63(1), and a phone is expressly a "communication device". If you produce the handset itself and step into the witness box to prove it is yours, Arjun Panditrao says no certificate is needed. The practical difficulty is that a screenshot proves the screen, not the message; consider whether the underlying record is what you actually need.

My trial started in 2022. Which certificate do I file?

The old one — section 65B(4). Under s 170(2) BSA a proceeding pending immediately before 1 July 2024 continues under the Evidence Act as if the Adhiniyam had not come into force. That applies to appeals too.

What is a hash value, and how do I get one?

A hash is a fixed-length string computed from a file — the Supreme Court called it "an electronic fingerprint". Change one bit of the file and the hash changes completely, so it proves the copy on the record is the copy that was certified. MD5, SHA1 and SHA256 are the algorithms named in the Schedule. Any competent forensic examiner will generate one, and the hash report must be enclosed, not just the value written in.

Is section 63 constitutionally valid?

Yes, so far as it goes. In Pune Bar Association (22 May 2026) the Supreme Court held that the hash requirement and expert certification have a rational nexus with the object of the Act and are not manifestly arbitrary. But the writ was disposed of at the admission stage without notice to the Union, and the Court expressly kept the expert question open.

Conclusion

The old certificate had one virtue above all others: you could get it. A one-page document, one signature, from the person who ran the machine. Ten years of litigation established when it was needed, who could give it, and what to do when the person who could give it would not.

Section 63 keeps the whole of that architecture and adds two things on top — a hash value, which is a genuine improvement and answers a real problem about tampering and deepfakes, and a second signature from an "expert" the statute does not define, on a form that asks that expert to certify nothing the party has not already certified.

The Supreme Court has now said the design is rational and constitutional. That is right on the hash. On Part B it is harder to defend, and the Court, tellingly, upheld it without deciding what it requires, who can satisfy it, or whether it is required at all.

Until that is decided, the safe advice is unglamorous. Fix your regime by the date the proceeding began. Compute the hash before you do anything else. File the Schedule form and annex a narrative. Lead your expert's credentials. And if you cannot get the certificate, apply to the Court and do it in writing.

The rest is being worked out one order at a time.

---

Disclaimer: This comment is prepared for educational and professional discussion and does not constitute legal advice. It is based on the enacted text of the Bharatiya Sakshya Adhiniyam, 2023 as reproduced on bare-act sources, on the reported decisions cited, and on published commentary; readers must consult the authenticated Gazette text of Act 47 of 2023 and the full reports of the judgments before relying on any proposition here in argument. The exact punctuation of THE SCHEDULE has been transcribed from a secondary source and should be checked against the Gazette before a certificate is settled. Several questions discussed above — whether Part B is mandatory, the meaning of "at each instance", the interaction of section 57 with section 63, and the status of a Schedule certificate filed in a pre-July 2024 proceeding — are open and unlitigated, and the views expressed on them are argument rather than authority. Pune Bar Association v. Union of India was disposed of at the admission stage without notice to the Union of India and expressly kept the question of law open. Statutory references should be verified against the enacted texts.