WhatsApp service of notice accepted as valid under CPC where delivery and opening were shown.

Bombay HC treated WhatsApp delivery of a notice, including the PDF attachment, as sufficient service under Order XXI Rule 22 CPC where the record showed the message had been delivered to and opened on the respondent's verified mobile number and the notice had been evaded. On those facts, electronic communication was accepted as valid service of notice, and the execution notice was made absolute.

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Issues: Whether service of notice under Order XXI Rule 22 of the Code of Civil Procedure, 1908 could be accepted through a WhatsApp message sent to the respondent's mobile number.

Analysis: The notice had been evaded. The record showed that the PDF and message sent by WhatsApp were delivered to the respondent's number and opened. On those indicators, service through WhatsApp was treated as sufficient for the purpose of notice under Order XXI Rule 22.

Conclusion: Service through WhatsApp was accepted as valid service of notice under Order XXI Rule 22 of the Code of Civil Procedure, 1908, and the notice was made absolute.

Final Conclusion: The execution notice proceeded on the basis that electronic delivery on WhatsApp satisfied the service requirement.

Ratio Decidendi: Where electronic communication to a respondent's verified mobile number shows delivery and opening of the message and attachment, the Court may accept WhatsApp service as sufficient service of notice for the purpose of Order XXI Rule 22 of the Code of Civil Procedure, 1908.

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