Indian Evidence Act Section 6: Relevancy of facts forming part of same transaction

Facts which, though not in issue, are so connected with a fact in issue as to form part of the same transaction, are relevant, whether they occurred at the same time and place or at different times and places.

Illustrations

(a) A is accused of the murder of B by beating him. Whatever was said or done by A or B or the by-standers at the beating, or so shortly or after it as to form part of the transaction, is a relevant fact.

(b) A is accused of waging war against the 11[ Government of India] by taking part in an armed insurrection in which property is destroyed troops are attacked and goals are broken open. The occurrence of these facts is relevant, as forming part of the general transaction, though A may not have been present at all of them.

(c) A sues B for a libel contained in a letter forming part of a correspondence. Letters between the parties relating to the subject out of which the libel arose, and forming part of the correspondence in which it is contained, are relevant facts, though they do not contain the libel itself.

(d) The question is, whether certain goods ordered from B were delivered to A. The goods were delivered to several intermediate persons successively. Each delivery is a relevant fact.

Simplified Explanation

Section 6 of the Indian Evidence Act, 1872 deals with the concept of the “Relevancy of Facts Forming Part of the Same Transaction.” This section is based on the principle of “res gestae,” which means “things done.” According to this section:

Text of Section 6:

“Facts which, though not in issue, are so connected with a fact in issue as to form part of the same transaction, are relevant, whether they occurred at the same time and place or at different times and places.”

Explanation:

• Facts Forming Part of the Same Transaction: This section allows for the admission of evidence concerning facts that are so closely connected to the fact in issue that they form part of the same transaction. Even if these facts are not directly in issue, they are still relevant because they help to explain or provide context to the fact in issue.
• Same Transaction: The term “transaction” refers to a series of acts or events that are connected in such a way that they are considered a single transaction. The events must be interlinked to an extent that they form a continuous narrative.
• Relevancy: The facts forming part of the same transaction are considered relevant because they can provide insight into the nature, cause, or effect of the fact in issue. The connection between the facts must be such that they explain or clarify the circumstances surrounding the fact in issue.

Example:

Imagine a situation where a person, X, is accused of murdering Y.

• Fact in Issue: Whether X murdered Y.
• Relevant Facts Forming Part of the Same Transaction:
  1. X and Y’s Argument: Suppose X and Y were seen arguing shortly before the murder. This argument is part of the same transaction because it could explain the motive or the events leading up to the murder.
  2. The Shouting Heard by Witnesses: If witnesses heard Y shouting for help, followed by gunshots, this sequence of events forms part of the same transaction. The shouting and the gunshots are closely connected, and both help in understanding the circumstances of the murder.
  3. X Fleeing the Scene: If X was seen running away from the crime scene immediately after the gunshots, this fact, though not the act of murder itself, is relevant because it is closely connected to the fact in issue and forms part of the same transaction.

In this scenario, the argument, the shouting, the gunshots, and X fleeing the scene are all interconnected events that form a single transaction. Although not every individual fact is the direct act of murder, they are all relevant under Section 6 because they help to construct a complete picture of the crime.

Significance:

Section 6 is crucial in legal proceedings because it allows the court to consider all facts that are part of the same transaction, even if they are not directly in issue. This provides a more comprehensive understanding of the events, helps establish the context, and aids in determining the truth. By considering these interconnected facts, the court can avoid isolating individual incidents and instead view the entire sequence of events as a whole, leading to a more accurate and just decision.