On 5 February 2015 a two-judge bench of the Supreme Court — Dipak Misra and Prafulla Pant JJ., the principal opinion authored by Dipak Misra J. — held that a candidate's non-disclosure of pending criminal cases in the Form 26 nomination affidavit, where charges have been framed or cognizance has been taken, amounts to 'undue influence' within Section 123(2) of the Representation of the People Act 1951 and is therefore a corrupt practice rendering the election liable to be set aside under Section 100(1)(b). The judgment elevates ECI Form 26 disclosure to constitutional and statutory significance and extends the framework to local-body elections.
A three-judge Bench in 2014 overruled the looser reading of Section 65B that had governed electronic-evidence admissibility for nine years, and held that a certificate under sub-section (4) is a condition precedent. The reasoning, the overruling of *Navjot Sandhu*, and the question of how the doctrine now travels onto Section 63 of the Bharatiya Sakshya Adhiniyam.
Six years after Anvar P.V., the three-judge Bench of Nariman, Bhat and Ramasubramanian JJ. returned to Section 65B — to settle a doctrinal drift that had crept in through *Shafhi Mohammad* and to clarify the certificate framework at the boundaries. A digest of the holding, the relaxation that wasn't, and how the framework now travels onto Section 63 BSA.