On 6 April 2026, a three-judge bench held that the inherent powers under section 528 BNSS can be invoked to quash criminal proceedings where unimpeachable material displaces the prosecution's factual foundation; the Bhajan Lal framework carries through unbroken into the BNSS era.
On 19 May 2026, a two-judge bench held that a directed crime-scene re-enactment limited to physical movements does not per se amount to testimonial compulsion under Article 20(3); such material is admissible as corroborative — not substantive — evidence. Conviction restored on circumstantial proof; death sentence commuted to life.
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.
Section 63 of the BSA is the successor to Section 65B of the Indian Evidence Act. It carries forward the *Anvar P.V.* / *Arjun Panditrao Khotkar* doctrinal architecture — certificate mandatory, no general secondary-evidence backdoor — and adds explicit recognition of hash values and a two-certificate framework (party + expert). A practitioner's consolidated reading of the section, the doctrinal continuity, and the operational architecture for evidence collection and adduction under the new code.