Exhibit marking does not equal proof; admitted documents still require judicial appraisal of proof and admissibility.

Marking a document as an exhibit under Order 13 Rule 4 CPC concerns admission in evidence and identification, not conclusive proof of its contents. A document may be admitted in evidence yet still remain open to challenge on the question whether it was actually proved on the record. The distinction between filing, admission, and proof is reinforced by the rules governing proof of wills and by Original Side practice directions on exhibit endorsement. The contrary practice was disapproved, and documents tendered and admitted in evidence were directed to be marked with numerical serial numbers rather than treated as proved merely by exhibit marking.

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Issues: Whether marking a document as an exhibit amounts to proof of the document, and whether a document admitted in evidence can be treated as proved merely because it bears an exhibit mark.

Analysis: Documents pass through distinct stages: filing, admission in evidence, and proof or disproof on judicial appraisal of the whole record. Endorsement of an exhibit mark under Order 13 Rule 4 of the Civil Procedure Code is concerned with admission in evidence and identification, not with final proof. Admission may in some situations affect admissibility objections, but it does not extinguish the right to contend that the document was not proved. This distinction is reinforced by the rule relating to proof of wills and by the practice directions governing numbering and endorsement of exhibits on the Original Side.

Conclusion: Marking a document as an exhibit does not amount to proof of the document, and a document cannot be treated as proved merely because it has been exhibited. The practice contrary to this position was disapproved, and documents tendered and admitted in evidence were directed to be marked with numerical serial numbers.

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