To provide a comprehensive case study, we must first address a critical legal update. Under the Bharatiya Sakshya Adhiniyam (BSA), 2023, which replaced the Indian Evidence Act in July 2024, Section 63 is now the primary provision governing the admissibility of electronic records.

The “Section 63 Certificate” (previously known as the 65B certificate) is the “golden key” for admitting WhatsApp chats, emails, and recordings in divorce proceedings.