Relevancy of fact and a general evaluation


Introduction

In the law of evidence, ‘relevancy of facts’ can be considered as a tool to identify facts, appropriate to the case, from a plethora of them. These facts are called ‘Facts in Issue’ and help in steering the case towards a justifiable judgment. Only through evidence can they be proved and evidence has been defined as: All statements which the Court permits or requires to be made before it by witnesses, in relation to matters of fact under inquiry; such statements are called oral evidence and All documents including electronic records produced for the inspection of the Court; such documents are called documentary evidence.



Fact-finding is the job of a person or group of persons in a judicial or administrative proceeding that has or has the responsibility of determining the facts relevant to decide a controversy.  Not everything holds value in the court of law, only certain events, and physical or abstract that is brought to court’s notice, through legal means, hold relevancy. Every event is a fact in itself and is made up of a number of facts. The law of Evidence was developed to chalk out the rule and principles to prove “facts.” The legal meaning of fact, as under the Evidence Act: Anything, state of things, or relation of things, capable of being perceived by the senses; and Any mental condition of which any person is conscious.



This Latin term means, ‘things done.’ It is adopted from the English doctrine offers gestate, though the term is not used directly in Section 6 of the act, it is applied in law, As Peter Murphy puts it, “To state a fact or event in isolation without reference to its antecedents in time, place or surrounding circumstances, may render the fact, difficult or even impossible to comprehend.” Hence, supporting facts are used to prove or give meaning to the facts in issue and these forms the part of res gestate. It is an exception to hearsay evidence.



Relevant facts could include both acts and omissions, and they could be isolated or contiguous but they should form a part of the transaction in question. In Milne v Leisler (7 H.&N. 796: 126 RR 704), the fact that the contractor wrote a letter to his broker to make enquiries was held to be a part of res gestae; in deciding whether a contract was made as an agent or in a personal capacity.



Uncertainty regarding instant statements and a false narrative of a detached prior event was cleared in the case of Ratten v Reginam (3 All ER 801), where Lord Wilberforce said that it should be up to the Judge to satisfy himself that whether the statement was made in spontaneity and instantly or is a constructed narrative and hence, shall be excluded.





Relevancy of Fact           

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. Each delivery is a relevant fact..



A fact that is raised by the pleadings directly and is necessary to be determined by the decision so that it will become res judicator —distinguished from fact in controversy — compare issue of law.



In law, a question of fact, also known as a point of fact, is a question that must be answered by reference to facts and evidence as well as inferences arising from those facts. Such a question is distinct from a question of law, which must be answered by applying relevant legal principles.



Evidence Act Provisions Regarding - Relevancy of Fact

(i) When facts have been declared to be legally relevant under I.E. Act, they become admissible. (ii) It is founded on law not on logic. For practical purpose, relevant fact means what is legally admissible in evidence. Only the evidence which is legally admissible should be received by the court.

 


Evidence to Prove Conspiracy


This part covers the following sections:

Section 10


This section states that whenever there is a reasonable ground to believe that two or more persons have conspired and a co-conspirator says, does or writes something, the evidence is relevant on a condition that the act must have a reference to their common intention. It is important to have a reasonable ground because conspiring against the government or nation is itself a crime.

 


Section 11


It gives relevancy to those facts which are irrelevant as such but become relevant because they are inconsistent with relevant facts and their existence in themselves or in connection with other facts make some fact in issue or a relevant fact highly probable or improbable. In Dudh Nath Pandey v State of UP (1981 2 SCC 166), the Supreme Court said that the plea of alibi must be proved with absolute certainty, so as to make the presence of accused at the crime scene, impossible. In Baij Lal v Ram Pratap (AIR 1982 Delhi 149), a seller divided his land in two and sold it in two different transactions to two different persons. The court held that the first sale deed will be considered and it was highly probable that the rest of the land was intended to be sold to the second buyer.   

Section 12


As civil cases are not dealt with as seriously as the criminal cases, this section gives relevancy to any fact which will enable the court to determine the amount of damages to be awarded.

Section 13


This section was laid out to consider facts when a custom or a right is in question. Facts and evidence regarding the origin, modification, assertion, claiming or denial of a custom and those instances where the custom or right was practised, recognized, claimed or denied are admissible.

Section 14


Section 14 is of importance as it accepts mental or bodily feelings as relevant. Mens rea or intention forms an important ingredient of a crime and hence, plays a vital role in determining the extent of liability of an accused. It leaves the finding out of mental or bodily feeling at the discretion of the court since it is impossible to find out what a man is thinking. It could be found out by other related facts and could help in proving intention, negligence or innocence. In Emperor v Wahiddin Hamiddin (1929 32 Bombay LR 324), the Bombay high court held that tendency to commit thefts could not prove an intention to commit dacoity or conspiring to commit dacoity. Previous convictions are excluded as evidence under Section 54 of the act but if the same offence is repeated, again and again, it may lay a ground for clearing the intention of the accused, as was held in Emperor v Allcomiya Husan (1903 ILR 28 Bombay 129).

Evidence of Similar Facts


The general principle is to exclude the evidence of similar facts or past prosecution (as stated above), this principle is applied as an exception, only in those cases where there is a striking similarity between the fact on which the case is based and the fact of which the evidence is offered.

Section 15


Through this section, the court establishes whether an act is incidental or accidental. This is done by checking whether such event was a part of similar occurrences and in each, the person concerned was executing the act. This was rightly explained in the case of R v Smith (1915 11 Cr App 233): If you find an accident which benefits a person and you find that the person has been sufficiently fortunate to have the accident happened to him a number of times, benefitting him each time, you draw a very strong, frequently an irresistible inference, that the occurrence of so many accidents benefitting him is such a coincidence that it cannot have happened unless it was designed.

Section 16


“When there is a question whether a particular act was done, the existence of any course of business, according to which it naturally would have been done, is a relevant fact.” This attaches evidentiary value to a normal course of business as people adhere to their routine of business and officials to the routine of office.

Offence and Punishment

Act, any Court of competent jurisdiction may compound offences, other than offences for which the punishment for life or imprisonment for a term exceeding three years has been provided under the Act. The person alleged of an offence under this Act may file an application for compounding in the Court.

 


Punishment is the imposition of an undesirable or unpleasant outcome upon a group or individual, meted out by an authority in contexts ranging from child discipline to criminal law as a response and deterrent to a particular action or behavior that is deemed undesirable or unacceptable. The reasoning may be to condition a child to avoid self-endangerment, to impose social conformity (in particular, in the contexts of compulsory education or military discipline), to defend norms, to protect against future harms (in particular, those from violent crime), and to maintain the law and respect for rule of law under which the social group is governed. Punishment may be self-inflicted as with self-flagellation and mortification of the flesh in the religious setting, but is most often a form of social coercion.



The unpleasant imposition may include a fine, penalty, or confinement, or be the removal or denial of something pleasant or desirable. The individual may be a person, or even an animal. The authority may be either a group or a single person, and punishment may be carried out formally under a system of law or informally in other kinds of social settings such as within a family. Negative consequences that are not authorized or that are administered without a breach of rules are not considered to be punishment as defined here. The study and practice of the punishment of crimes, particularly as it applies to imprisonment, is called penology, or, often in modern texts, corrections; in this context, the punishment process is euphemistically called "correctional process" .Research into punishment often includes similar research into prevention.



Justifications for punishment include retribution, deterrence, rehabilitation, and

Incapacitation. The last could include such measures as isolation, in order to prevent the wrongdoer's having contact with potential victims, or the removal of a hand in order to make theft more difficult. Of the four justifications, only retribution is part of the definition of punishment and none of the other justifications is a guaranteed outcome, aside from obvious exceptions such as an executed man being incapacitated with regard to further crimes.\



Punishment for offences

Whoever commits any offence described in column 1 of the Table below shall, in addition to and not in derogation of any punishment to which he may be liable under any other law, be liable to the punishment mentioned against that offence in column 2 thereof:-

If any person contravenes any provision of this Act or any rule made there under, or abets any such contravention or fails to comply with any provision of this Act or any such rule with which it was his duty to comply, where no express penalty has been provided elsewhere for such contravention or failure,


(i) If any goods imported by sea or air be unloaded or attempted to be unloaded at any place other than a customs-port or customs-airport declared under section 9 for unloading of such goods;

ii) if any goods be imported by land or inland water through any route other than a route declared under clause (c) of section 9 for the import of such goods; or

(iii) if any goods be attempted to be exported by sea or air from any place other than a customs-port or customs-airport appointed for the loading of such goods; or

iv) if any goods be attempted to be exported by land or inland water through any route other than a route declared under clause (c) of section 9 for the export of such goods; or

(v) if any imported goods be brought into any bay, gulf, creek or river for the purpose of being landed at a place other than a customs-port; or

vi) if any goods be brought near the land frontier or the coast of Bangladesh or near any bay, gulf, creek or river for the purpose of being exported from a place other than a customs-station where any place has been approved under clause (b) of section 10 for the loading of such goods, from any place other than the place so approved;

3. (i) If any person exports or lands goods, or aids in the export or landing of goods, or knowingly keeps or conceals or knowingly permits or procures to be kept or concealed, any goods exported or landed, or intended to be exported or landed, contrary to the provisions of this Act; or

(ii) If any person be found to have been on board any conveyance liable to confiscation on account of the commission of the offence under clause 4 of this Table, while such conveyance is within any place which is not a customs-station for the export and landing of goods;

4. If any conveyance which has been within the limits of any customs-station in Bangladesh with goods on board, be afterwards found anywhere in Bangladesh with the whole or any portion of such goods missing, unless the person-in-charge of the conveyance be able to account for the loss of, or deficiency in, the goods;

5. (i) If any goods are unloaded from any conveyance inward bound, without the authority of the appropriate officer into any other conveyance at any place other than a place declared under section 9 for the unloading of goods; or if any goods are loaded into any conveyance outward bound from any other conveyance, without such authority, from or at any place other than a place declared under section 9 for the loading of goods; or

(ii) If any goods on which drawback has been granted are put, without such authority, on board any conveyance for the purpose of being re-landed;





Communication of Offence

The Malicious Communications Act 1988 section 1, see Stones 8.20830, deals with the sending to another of any article which is indecent or grossly offensive, or which conveys a threat, or which is false, provided there is intent to cause distress or anxiety to the recipient.

Communications is fundamental to the existence and survival of humans as well as to an organization. It is a process of creating and sharing ideas, information, views, facts, feelings, etc. among the people to reach a common understanding. Communication is the key to the Directing function of management. A manager may be highly qualified and skilled but if he does not possess good communication skills, all his ability becomes irrelevant. A manager must communicate his directions effectively to the subordinates to get the work done from them properly.

 


Communications Process


Communications is a continuous process which mainly involves three elements viz. sender, message, and receiver. The elements involved in the communication process are explained below in detail:

1. Sender


The sender or the communicator generates the message and conveys it to the receiver. He is the source and the one who starts the communication

2. Message


It is the idea, information, view, fact, feeling, etc. that is generated by the sender and is then intended to be communicated further.

3. Encoding


The message generated by the sender is encoded symbolically such as in the form of words, pictures, gestures, etc. before it is being conveyed.

4. Media


It is the manner in which the encoded message is transmitted. The message may be transmitted orally or in writing. The medium of communication includes telephone, internet, post, fax, e-mail, etc. The choice of medium is decided by the sender.


5. Decoding


It is the process of converting the symbols encoded by the sender. After decoding the message is received by the receiver.

6. Receiver


He is the person who is last in the chain and for whom the message was sent by the sender. Once the receiver receives the message and understands it in proper perspective and acts according to the message, only then the purpose of communication is successful.

7. Feedback


Once the receiver confirms to the sender that he has received the message and understood it, the process of communication is complete.

8. Noise


It refers to any obstruction that is caused by the sender, message or receiver during the process of communication. For example, bad telephone connection, faulty encoding, faulty decoding, inattentive receiver, poor understanding of message due to prejudice or inappropriate gestures, etc.

 


Importance of Communication


1. The Basis of Co-ordination


The manager explains to the employees the organizational goals, modes of their achievement and also the interpersonal relationships amongst them. This provides coordination between various employees and also departments. Thus, communications act as a basis for coordination in the organization.

2. Fluent Working


A manager coordinates the human and physical elements of an organization to run it smoothly and efficiently. This coordination is not possible without proper communication.

3. The Basis of Decision Making


Proper communication provides information to the manager that is useful for decision making. No decisions could be taken in the absence of information. Thus, communication is the basis for taking the right decisions.


4. Increases Managerial Efficiency


The manager conveys the targets and issues instructions and allocates jobs to the subordinates. All of these aspects involve communication. Thus, communication is essential for the quick and effective performance of the managers and the entire organization.

5. Increases Cooperation and Organizational Peace


The two-way communication process promotes co-operation and mutual understanding amongst the workers and also between them and the management. This leads to less friction and thus leads to industrial peace in the factory and efficient operations.

6. Boosts Morale of the Employees


Good communication helps the workers to adjust to the physical and social aspect of work. It also improves good human relations in the industry. An efficient system of communication enables the management to motivate, influence and satisfy the subordinates which in turn boosts their morale and keeps them motivated.

Types of Communication


1. Formal Communication


Formal communications are the one which flows through the official channels designed in the organizational chart. It may take place between a superior and a subordinate, a subordinate and a superior or among the same cadre employees or managers. These communications can be oral or in writing and are generally recorded and filed in the office; Formal communication may be further classified as Vertical communication and Horizontal communication.

Vertical Communication


Vertical Communications as the name suggests flows vertically upwards or downwards through formal channels. Upward communication refers to the flow of communication from a subordinate to a superior whereas downward communication flows from a superior to a subordinate. Application for grant of leave, submission of a progress report, request for loans etc. are some of the examples of upward communication. Sending notice to employees to attend a meeting, delegating work to the subordinates, informing them about the company policies, etc. are some examples of downward communication.

Horizontal Communication


Horizontal or lateral communication takes place between one division and another. For example, a production manager may contact the finance manager to discuss the delivery of raw material or its purchase.



Provisions and Punishment of Penal Code       

Punishment for attempting to commit offences punishable with imprisonment for life or imprisonment:


511. Whoever attempts to commit an offence punishable by this Code with 2[ imprisonment for life] or imprisonment, or to cause such an offence to be committed, and in such attempt does any act towards the commission of the offence, shall, where no express provision is made by this Code for the punishment of such attempt, be punished with 3[ imprisonment of any description provided for the offence, for a term which may extend to one-half of the longest term of imprisonment provided for that offence], or with such fine as is provided for the offence, or with both.



Illustrations

a)      A makes an attempt to steal some jewels by breaking open a box, and finds after so opening the box, that there is no jewel in it. He has done an act towards the commission of theft, and therefore is guilty under this section.

b)       A makes an attempt to pick the pocket of Z by thrusting his hand into Z's pocket. A fails in the attempt in consequence of Z's having nothing in his pocket. A is guilty under this section.























Conclusion

For the purposes of any penal provisions of this Act, the offence of contravening, in respect of any goods, any of the provisions of this Act or the rules or any other law for the time being in force, shall be deemed to have been committed when, in the case of import, any vessel containing such goods arrives within twelve nautical miles of the sea coast of Bangladesh (each nautical mile measuring six thousand and eighty feet) or when, in the case of export, such goods have been loaded on any conveyance for transport to any destination outside Bangladesh, or when, in either case, the connected customs documents have been presented to the appropriate officer.



The provisions of the act are exhaustive in themselves but the act is not exhaustive in itself. The relevancy of facts is an important chapter which deals with the substance of the trials as, without facts; nothing can be proved to have happened. The act was developed during the rule of the Bruisers and hence leaves a huge room for improvements which might have not yet been discovered. The evident changing nature of law should be continuously applied in updating this act to ensure fair judgments.

































References 

1.      Law Dictionary: Fact-Finder. Accessed 17 November 2008.

2.      General Information on Fact-Finding. Colorado University. Accessed 17 November 2008.

3.      Ramcharan, B. G. (1983). International Law and Fact-finding in the Field of Human Rights. Martinus Nijhoff Publishers. pp. VII. ISBN 978-90-247-3042-1.


5.       Lyal S. Sunga, "How Can UN Human Rights Special Procedures Sharpen ICC Fact-Finding?" 15(2) The International Journal of Human Rights (2011) 187–204.

6.      Schultz, Norman. Fact-Finding. Accessed 17 November 2008

7.       "Resolution 46/59 Declaration of fact-finding missions". New York: UN. 9 December 1991. Fact-finding should be comprehensive, objective, impartial and timely.

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