Sunday, 30 January 2022

Whether court can direct accused to surrender his mobile phone to investigating officer for forensic examination?


 Bound, as I am, by the law laid down on Oghad (supra) and being in respectful agreement with the view taken by Suraj Govindraj.J in Virendra Khanna (supra) and also having regard to the provisions of Section 45-A of the Evidence Act and Section 79A of the Information Technology Act (for short, “the IT Act”), I hold that

the prosecution has every right to seek that the accused hand over the mobile phones in question for the purpose of forensic examination by an agency identified by the Central Government as ‘Examiner of Electronic Evidence’ under Section 79-A of theInformation Technology Act, 2000. { Para 8}

 IN THE HIGH COURT OF KERALA AT ERNAKULAM

BAIL APPL. NO. 248 OF 2022

 P.GOPALAKRISHNAN ALIAS DILEEP Vs  STATE OF KERALA 

PRESENT

 MR. JUSTICE GOPINATH P.

Dated: 29th day of January 2022


I had by order dated 22.1.2022 in the above bail applications granted an interim

order, protecting the petitioners from arrest on a specific condition (among others) that

the petitioners shall fully co-operate with the investigation. On 28.1.2022, an application

numbered as Crl.M.A. No.2 of 2022 was filed in BA No. 248 of 2022, alleging that the

petitioners were not cooperating with the investigation. Primarily, it is pointed out that

despite demand, certain mobile phones which were being used by the petitioners were

not handed over to the investigation team. The prayer in Crl.M.A. No.2 of 2022 is for a

direction to the petitioners in these bail applications to forthwith produce the following

mobile phones: -

(1) Mobile Phone bearing IMEI No.356723080949446 of Apple Company;

(2) Mobile Phone bearing IMEI No.356728111838724 of Apple Company;

(3) Mobile Phone bearing IMEI No.868409043310506 of VIVO Company;

(4) Mobile Phone bearing IMEI No.352544473256346;

(5) Mobile Phone bearing IMEI No.864644032210833 of Huawei-Honor;

(6) Mobile Phone bearing IMEI No. 868384058791806 of Redmi Company; and

(7) Mobile Phone bearing IMEI No.863607031095365 of Huawei Company.

When Crl.M.A. No.2 of 2022 was taken up for consideration yesterday, the learned counsel

appearing for the petitioners sought time to place an objection and also for time to argue

this matter. In view of the urgency pointed out by the learned Director General of

Prosecutions, this matter was directed to be listed today.


2. I have heard Sri.T.A.Shaji, Senior Advocate and Director General of

Prosecutions, assisted by Sri.P.Narayanan, Senior Public Prosecutor for the State and

Sri.B. Raman Pillai, Senior Advocate appearing for the petitioners in BA Nos. 248/2022,

288/2022 & 300/2022, assisted by Sri.Philip T. Varghese.

3. The learned Senior Counsel for the petitioners would point out that a

notice had been issued to the petitioners under Section 91 of the Code of Criminal

Procedure (for short, “Cr.P.C.”), calling upon them to produce the aforesaid mobile

phones. It was submitted with reference to the decision of the Supreme Court in State

of Gujarat v. Shyamlal Mohanlal Choksi & Another; AIR 1965 SC 1251 and the

decisions of this Court in Gopalakrishnan Nayanar & Another v. Sasidharan Nambiar

& Another (1996) 1 KLT 83 and Kurian v. Joseph & Others, 2021 (2) KHC 124 that the

notice under Section 91 of Cr.P.C. was illegal and unsustainable. It is also suggested

that any direction to produce the mobile phones would amount to the violation of the

right against self-incrimination guaranteed under Article 20(3) of the Constitution of

India. It is submitted that some among the phones have been sent to a forensic expert

by the petitioners themselves for analysis and data retrieval. It is submitted that the

data so retrieved can be handed over for the purpose of investigation. It is also

submitted that the petitioners are facing a mighty Police force in a case where the defacto

complainant is himself a part of the very agency which is investigating the

alleged offence and that the petitioners have no faith in handing over the phones to

the investigating agency. It is submitted that personal information (having no relation to the case on hand) and privileged communications may also be revealed if the

phones are directed to be handed over. It is submitted that the phones had been sent

for data retrieval, in order to show the falsity of the allegations now raised against the

petitioners and that the phones had been sent for data retrieval even before the

present case was registered.

4. The learned Director General of Prosecutions vehemently submits that

there is no question of violation of Article 20(3) of the Constitution of India as the

direction to produce a document or a thing does not amount to self-incrimination. It is

submitted that the investigating agency has every power to ask for the production of

the mobile phones in question as the data contained in the same has to be verified for

the purpose of investigation. It is further submitted that the Karnataka High Court had

recently considered this issue with reference to all the earlier judgments of the

Supreme Court in Virendra Khanna v. State of Karnataka and Others, 2021 SCC

Online Karnataka 5032.

5. Having considered the rival submissions, I am of the view that the issue

raised is no longer res integra in the light of the law laid down in State of Bombay v.

Kathi Kalu Oghad, AIR 1962 SC 1809. In that case two sets of appeals were considered

by the Supreme Court. In one, namely Criminal Appeal 146 of 1958 the question was

whether the obtaining of specimen handwritings from the accused to prove the case

against him would amount to self-incrimination while in the other appeals namely

Criminal Appeal Nos. 110 & 111 of 1958, the question was whether the taking of

impressions of palms and fingers of the accused for comparison with images of palms

and fingers retrieved from a shop that was burgled would amount to selfincrimination.

The issue was considered with reference to Article 20(3) of the

Constitution of India. It would not be out of place to mention that Oghad (supra) was

decided by a bench of 11 Judges, particularly to re-examine some of the propositions

laid down in M.P Sharma v. Satish Chandra, AIR 1954 SC 300. To the extent it is

relevant, it was held: -

“(1) An accused person cannot be said to have been compelled to be a

witness against himself simply because he made a statement while in

police custody, without anything more. In other words, the mere fact of

being in police custody at the time when the statement in question was

made would not, by itself, as a proposition of law, lend itself to the

inference that the accused was compelled to make the statement, though

that fact, in conjunction with other circumstances disclosed in evidence in

a particular case, would be a relevant consideration in an enquiry whether

or not the accused person had been compelled to make the impugned

statement.

(2) The mere questioning of an accused person by a police officer,

resulting in a voluntary statement, which may ultimately turn out to be

incriminatory, is not “compulsion”.

(3) “To be a witness” is not equivalent to “furnishing evidence” in its

widest significance; that is to say, as including not merely making of oral

or written statements but also production of documents or giving

materials which may be relevant at a trial to determine the guilt or

innocence of the accused.

(4) Giving thumb impressions or impressions of foot or palm or fingers or

specimen writings or showing parts of the body by way of identification

are not included in the expression “to be a witness”.

(5) “To be a witness” means imparting knowledge in respect of relevant

facts by an oral statement or a statement in writing, made or given in

court or otherwise.

(6) “To be a witness” in its ordinary grammatical sense means giving oral

testimony in court. Case law has gone beyond this strict literal


interpretation of the expression which may now bear a wider meaning,

namely, bearing testimony in court or out of court by a person accused of

an offence, orally or in writing.

(7) To bring the statement in question within the prohibition of Article

20(3), the person accused must have stood in the character of an accused

person at the time he made the statement. It is not enough that he should

become an accused, any time after the statement has been made.”

Oghad (supra) was considered and relied on by Ashok Bhushan J. in K.S. Puttaswamy

(Aadhaar-5J.) v. Union of India, (2019) 1 SCC 1 to hold that Section 33 of the Aadhaar

Act was constitutionally valid. It has also been relied upon and followed by a three-

Judge Bench in Ritesh Sinha v. State of U.P., (2019) 8 SCC 1 in considering the

question as to whether the giving of a voice sample would amount to selfincrimination

under Article 20(3) of the Constitution.

6. The High Court of Karnataka in Virendra Khanna (supra) considered the

issue both in the context of Article 20(3) of the Constitution and also in the context of

the Right to Privacy and held:-

“Would providing a password, passcode or Biometrics amount to selfincrimination

or testimonial compulsion?

As regards the contention that providing of the password/pass code will

amount to testimonial compulsion, I am of the considered opinion that

there is no testimony which is given by the accused by providing the said

password, passcode or biometrics by which the document is being

accessed by the Investigating officer.

The XI Judge Bench of the Apex Court in Kathi Kalu Oghad's case has

categorically held that providing of a thumb impression or impression of

the palm or foot or fingers or specimen in writing or exposing a part of

the body of an accused person for the purpose of identification would not

amount to testimonial compulsion. Mere providing of an access of to

smartphone or e-mail account would not amount to being a witness, the information that is accessed by the Investigating officer on the

smartphone and or the e-mail account being only access; to the data

and/or documents, it is for the Investigating officer to prove and establish

the same in a Court of law by following the applicable Rules of evidence.

Merely because any document is present or available on the smartphone

and or the e-mail account would not by itself establish the guilt or

innocence of an accused. Both the prosecution, as also the

accused/defence would be required to prove the said document or data

by other evidence also.

If the submission of Mr. Hasmath Pasha, learned Senior counsel would be

accepted, the same would result in a chaotic situation:

No blood samples can be taken;

no sample for DNA analysis could be taken;

no handwriting samples can be taken;

no other body sample for the purpose of DNA analysis could be

taken

No search of a house or office could be undertaken.

The data of a laptop or computer or server cannot be accessed by

the Investigating officer.

Offences like cyber crime could never be investigated.

Offences like pornography, child pornography which are more

often than not, on the internet, could not be investigated.

A direction to provide a password, passcode, biometrics would not

amount to testimonial compulsion. It is only in the nature of a direction

to produce a document. Mere providing access to a smartphone or e-mail

account would not amount to self-incrimination since it is for the

investigating agency to prove its allegation by cogent material evidence.

The data available on a smartphone or e-mail account would also have to

be proved by the investigating agency in accordance with Law. Mere

providing of password, passcode or biometrics would not amount to

answering any question put forward by the Investigating Officer, and as

such, it would not amount to a violation of Section 151(2) of the Cr.P.C.

As contended by Sri. Veranna Tigadi, learned counsel providing of the

password, passcode, pin biometrics is akin to finger printing and/or

taking imprints of the shoes, soles and or taking sample of the clothes,

biological samples, chemical samples, etc, same cannot amount to forced

testimony on part of the accused. On the examination of the data in the

telephone/mobile and or on the computer, etc, prosecution would have to

prove the same by cogent evidence.

By providing of password, passcode or biometrics, there is no oral

statement or a written statement being made by the accused like the

Petitioner herein, therefore it can not be said to be testimonial

compulsion.

Would providing of password, passcode or Biometrics violate the right

to privacy of a person providing the said password, passcode or

Biometrics?

Once the investigating agency has an access to a electronic equipment

more particularly smart phones and/or laptops, the Investigating Officer

has a free access to all data not only on the said equipment but also any

cloud service that may be connected to the said equipment, which could

include personal details, financial transactions, privileged

communications and the like

The rules which are applicable to physical document where a particular

document could be classified as a privileged communication and/or

strictly private and confidential cannot apply to the data which is stored

on a smartphone or any other electronic equipment since once an

investigating officer has an access to the said smartphone, electronic

equipment or e-mail account, he would have complete access to the data.

Such data though may not be incriminatory, may be very private or secret

to the person or such data could incriminate the said person in any

particular offence.

The use of such data during the course of the investigation would not

amount to a violation of the right to privacy and would come within the

exceptions carved out in Justice Puttaswamy's case supra, however, the

disclosure, making public or otherwise in court proceedings would have to

be determined by the concerned judge by passing a judicial order. In no

case could such details or data be provided by the investigating officer to

any third party during the course of investigation without the written

permission of the court seized of the matter. The responsibility of

safeguarding the information or data which could impinge on the privacy

of the person will always be that of the investigating officer, if the same is

found to have been furnished to any third party the investigation officer

would be proceeded against for dereliction of duty or such other

delinquency as provided.”

7. In exercise of the power under Section 79-A, the Central Government

has notified certain agencies as ‘Examiner of Electronic Evidence’. In my view, only

such agencies can be allowed to conduct a forensic analysis of a mobile phone and the

petitioners cannot entrust the phones to any person of their choice to examine or

extract data from the phones in question. Following the introduction of Section 79-A,

the Indian Evidence Act, 1872 has also been amended and Section 45A has been

inserted making the opinion of the ‘Examiner of Electronic Evidence’ a relevant fact.

Section 79-A of the Information Technology Act, 2000 reads as follows:-

“Central Government to notify Examiner of Electronic Evidence. -The

Central Government may, for the purposes of providing expert opinion

on electronic form evidence before any court or other authority specify,

by notification in the Official Gazette, any Department, body or agency

of the Central Government or a State Government as an Examiner of

Electronic Evidence.

Explanation. -For the purposes of this section, "electronic form

evidence" means any information of probative value that is either

stored or transmitted in electronic form and includes computer

evidence, digital audio, digital video, cell phones, digital fax machines.”

8. Bound, as I am, by the law laid down on Oghad (supra) and being in respectful agreement with the view taken by Suraj Govindraj.J in Virendra Khanna (supra) and also having regard to the provisions of Section 45-A of the Evidence Act and Section 79A of the Information Technology Act (for short, “the IT Act”), I hold that

the prosecution has every right to seek that the accused hand over the mobile phones in question for the purpose of forensic examination by an agency identified by the Central Government as ‘Examiner of Electronic Evidence’ under Section 79-A of theInformation Technology Act, 2000.

9. At this point, the learned counsel appearing for the petitioners would

submit that in respect of the phone mentioned as Sl. No.(4) above, bearing IMEI

No.352544473256346, the make of the phone in question is not indicated. It is

submitted that the petitioners are unable to identify the phone with the aforesaid

IMEI number alone.

10. Taking into account the submission of the learned counsel for the

petitioners, there will be a direction that the mobile phones mentioned as Sl.Nos. (1),

(2), (3), (5), (6) & (7) above shall be produced in a sealed box before the Registrar

General of this Court by 10.15 am on 31.01.2022. The Learned Senior Public

Prosecutor shall get instructions from the investigating officer regarding the phone

with IMEI No.352544473256346.

Post these matters at 1.45 P.M on 31.01.2022.

Sd/-

GOPINATH P.

JUDGE

29.01.2022

Print Page

No comments:

Post a Comment