Electronic evidence must satisfy authenticity and statutory certificate requirements before voice sample comparison can be ordered.

Electronic recordings may be relevant to a fact in issue, but they cannot be acted upon unless the requirements for proving electronic records are first satisfied. Sections 65A and 65B of the Indian Evidence Act govern proof of computer output and require the statutory conditions, including the Section 65B(4) certificate, unless lawful authentication is otherwise established. Here, the alleged pen drive and CD lacked foundational material showing when and how the recording was made or that it was authentic, so the trial court was justified in treating it as unreliable and refusing to direct comparison with the complainant's voice sample.

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Issues: Whether the accused was entitled to a direction for obtaining the complainant's voice sample for comparison with the alleged electronic recording, and whether the trial court erred in refusing to act upon the pen drive and CD in the absence of proof of authenticity and the statutory certificate for electronic evidence.

Analysis: Electronic recordings can be relevant if they relate to a fact in issue, but admissibility depends upon compliance with the special rules governing electronic records. Sections 65A and 65B of the Indian Evidence Act provide the governing code for proving computer output and require satisfaction of the statutory conditions, including the certificate contemplated by Section 65B(4), unless the record is shown to be duly authenticated in a manner recognised by law. The alleged recording in this case was not supported by pleadings or evidence showing when it was made, by what device it was recorded, or that the recording was authentic. In the absence of such foundational material, the trial court was justified in declining to treat the recording as reliable evidence and in refusing to direct comparison with the complainant's voice sample.

Conclusion: The refusal to direct voice sampling was , and the petition seeking interference with that order failed.

Ratio Decidendi: An electronic recording cannot be acted upon for evidentiary purposes unless its authenticity and the statutory requirements for proving electronic records are first established.

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