Public document presumption accepted for market rate evidence; conjecture cannot displace a certified committee certificate in assessment.

A certified certificate issued by a Market Committee was treated as a public document under the Indian Evidence Act, 1872, and therefore carried a statutory presumption of genuineness. In the absence of contrary departmental evidence or effective rebuttal, the certificate was accepted as legal proof of the prevailing rates of gram and gram dal for assessment purposes. The Assessing Authority could not replace such evidence with conjecture or surmise, and the higher rates adopted were not supported by legal evidence. The question was answered in favour of the assessee-petitioner.

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Issues: Whether the certificate issued by the Market Committee, Tohana, constituted legal evidence and a public document to determine the prevailing rates of gram and gram dal for assessment purposes.

Analysis: The certificate was treated as the only legal evidence on record showing the prevailing rates of gram and gram dal. A document forming the record of an official body falls within the definition of public documents under the Indian Evidence Act, 1872. Market Committees are constituted under the Punjab Agricultural Produce Markets Act, 1961, and the certified copy of such a public document attracts the statutory presumption of genuineness under the Evidence Act. The contrary departmental material was not produced or confronted, and a conclusion based merely on conjectures and surmises could not displace the certified market certificate.

Conclusion: The certificate of the Market Committee had to be accepted as genuine and authentic, and the higher rates adopted by the Assessing Authority were not supported by legal evidence. The question was answered in favour of the assessee-petitioner.

Ratio Decidendi: A certified public document issued by an official body carries a statutory presumption of genuineness and, unless rebutted by contrary evidence, must be accepted as proof of the fact stated therein; assessment cannot rest on conjecture in place of legal evidence.

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