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Difference Between Relevancy And Admissibility

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Understanding the difference between relevancy and admissibility is crucial for interpreting evidence under the Indian Evidence Act, 1872. These two concepts, although closely connected, play distinct roles in determining the facts that can influence a legal case. While relevancy is based on logic and human experience, evaluating how evidence relates to the facts in issue, admissibility relies on legal standards to decide whether such evidence can be presented in court.

For instance, evidence may be relevant to a case but deemed inadmissible if it violates legal protocols or procedural safeguards. This blog explores the intricate relationship between relevancy and admissibility, with reference to key sections of the Indian Evidence Act, 1872, judicial discretion, and landmark judgments, providing a comprehensive overview of how these principles ensure a fair trial process.

By delving into the difference between relevancy and admissibility, we aim to clarify their significance in evidence law and their role in shaping judicial outcomes.

Relevancy:

Sections 5 to 55 of the Indian Evidence Act, 1872 explain relevancy.Relevancy is based on logic and human experience, and it determines which facts are necessary to prove or disprove an issue. Relevancy refers to the relationship between evidence and the facts of a case. According to the Federal Rules of Evidence, Rule 401 states, “Evidence is relevant if: (a) it has any tendency to make a fact more or less probable than it would be without the evidence; and (b) the fact is of consequence in determining the action.”

For instance, in a theft case, evidence showing the defendant's presence at the scene during the crime is relevant. It helps establish a connection between the defendant and the alleged act. However, not all relevant evidence is necessarily admissible.

The concept of relevancy is primarily based on logic and human experience, meaning that it is determined by the common course of events and human conduct. However, not all relevant facts are admissible in court, as the law may exclude certain relevant evidence for various reasons, such as prejudice or confusion

Admissibility:

Section 56 and onwards of the Indian Evidence Act, 1872 explain admissibility.Admissibility is based on law, and it decides which relevant facts can be admitted as evidence and which cannot. Admissibility, on the other hand, pertains to whether evidence can be presented in court. Even if evidence is relevant, it must meet certain criteria to be admissible. Factors like reliability, legality, and potential to cause unfair prejudice come into play. The Federal Rules of Evidence, Rule 402 states, “Relevant evidence is admissible unless any of the following provides otherwise: the United States Constitution; a federal statute; these rules; or other rules prescribed by the Supreme Court.”

For example, evidence obtained through illegal means, like an unlawful search, may be relevant but is typically deemed inadmissible in court. This ensures that the legal process upholds the rights of individuals.

In the Indian Evidence Act, 1872, admissibility is primarily addressed in Section 136, which grants judges the discretion to admit evidence based on its relevance and the way it was obtained.

Difference Between Relevancy And Admissibility:

  Relevancy Admissibility
Definition Refers to the degree to which evidence relates to the facts of the case. It assesses whether the evidence contributes to proving or disproving a fact in issue. Concerns whether that relevant evidence can be legally presented in court. It evaluates the legal standards that must be met for evidence to be considered acceptable.
Nature Relevancy is based on logic and the connection between facts. Admissibility is based on a legal determination
Legal Framework Relevancy is governed by Section 5 of the Indian Evidence Act, which specifies that only relevant evidence is admissible and is defined by the relationship between facts (Sections 5-55 of the Indian Evidence Act). Admissibility is governed by specific legal rules (Section 136), Determined by various provisions within the Indian Evidence Act that outline specific criteria for evidence to be deemed admissible, including legality and reliability.
Outcome Affects the weight and significance of the evidence in relation to the case. Determines whether the evidence can influence the court's decision.
Judicial Discretion Relevancy is assessed based on logical connections between facts Judges have discretion in determining admissibility
Application Evidence can be relevant but not necessarily permissible in court. For example, a witness's testimony about a past incident may relate to the case but could be excluded due to hearsay rules. Evidence must meet legal standards to be presented, regardless of its relevance. For instance, evidence obtained through unlawful means may be relevant but ruled inadmissible.

 

Cases Of Relevancy And Admissibility

Ram Bihari Yadav vs. State of Bihar, (2000) 2 SCC 453

In the case of Ram Bihari Yadav vs. State of Bihar, (2000) 2 SCC 453, the Supreme Court of India clarified the distinction between relevancy and admissibility. The Court noted that relevancy pertains to the logical connection between evidence and the facts in issue, meaning that relevant evidence can influence the determination of those facts. Conversely, admissibility refers to the legal criteria that determine whether that relevant evidence can be presented in court. The judgment emphasized that while all admissible evidence must be relevant, not all relevant evidence is admissible, highlighting the distinct legal implications of these concepts under the Indian Evidence Act, 1872.

State of Uttar Pradesh v. Rajesh Gupta, (2008) 5 SCC 362

In the case of State of Uttar Pradesh v. Rajesh Gupta, (2008) 5 SCC 362, the Supreme Court of India clarified the distinction between relevancy and admissibility in the context of evidence law. The court emphasized that relevancy pertains to the connection of evidence to the facts at issue, determining whether it can influence the case's outcome. Conversely, admissibility addresses the legal standards that must be met for that relevant evidence to be presented in court. This judgment reinforced the principle that not all relevant evidence is admissible if it violates legal criteria or procedural rules, highlighting the importance of both concepts in ensuring a fair judicial process.

Conclusion

The difference between relevancy and admissibility is a cornerstone of evidence law that plays a pivotal role in judicial proceedings. Relevancy determines how closely evidence relates to the facts in issue, influencing its potential impact on the case. Conversely admissibility assesses whether that relevant evidence can be legally introduced in court, subject to various legal standards and rules. Understanding these distinctions is essential for legal practitioners, as it not only guides the presentation of evidence but also safeguards the integrity of the judicial process.

FAQS

Below are some of the most frequently asked questions about the concepts of relevancy and admissibility of evidence:

Q1. What is the difference between relevancy and admissibility of evidence?

Relevancy refers to whether a piece of evidence has a logical connection to the facts in issue in a case, whereas admissibility determines whether that evidence can be legally presented in court based on rules, including its relevance, legality, and reliability.

Q2: Can all relevant evidence be admitted in court?

No, not all relevant evidence is admissible. Even if evidence is relevant to the case, it might still be excluded if it violates certain legal standards, such as being illegally obtained or prejudicial.

Q3. How does the Indian Evidence Act distinguish between relevancy and admissibility?

The Indian Evidence Act separates these concepts by stating that evidence must first be relevant (connected to the case) and then satisfy other conditions under the Act, such as not being hearsay, to be admissible in court.

Q4. What are the criteria for determining whether evidence is relevant?

Relevance is determined by whether the evidence can help prove or disprove a fact in issue. It involves a logical connection between the evidence and the matter at hand, as per the rules outlined in the Indian Evidence Act, particularly Section 5 to Section 55.

Q5. Can irrelevant evidence ever be admitted in court?

Irrelevant evidence is generally inadmissible in court. However, there are exceptions, such as when it is necessary to establish the context of a case or when the court permits evidence based on its potential to clarify the facts.