When Facts Not Otherwise Relevant Become Relevant – A Detailed Analysis

The Indian Evidence Act, 1872 creates a clear framework around what constitutes relevant facts and admissible evidence. However, the law also recognizes that certain facts which may appear irrelevant at first glance may become relevant due to special circumstances. This principle is vital because courts often face situations where direct evidence is absent, and the truth can be discovered only by evaluating surrounding facts and conduct. Sections 6 to 55 of the Evidence Act outline several exceptions where facts not otherwise relevant acquire relevance due to their connection with the fact in issue. This article explains the major circumstances under which irrelevant facts become relevant, supported by statutory language, illustrations, and judicial principles.

Res Gestae – Facts Connected With the Same Transaction (Section 6)

One of the most important situations in which irrelevant facts become relevant is the doctrine of res gestae. Section 6 says that facts forming part of the same transaction are relevant, even if they would otherwise be inadmissible. The principle is based on the spontaneity and contemporaneous nature of events. Statements or actions closely linked to the main occurrence shed light on the fact in issue because they are considered natural and instinctive responses.

For example, a victim shouting “he stabbed me!” immediately after an attack may not be a dying declaration, but it still becomes relevant under Section 6. The law accepts such statements because they are made without time for fabrication. This exception plays a crucial role in cases of sudden crimes such as assaults, robberies, riots, and mob violence where eyewitnesses may not always be available.

Facts Showing Motive, Preparation, and Conduct (Section 8)

Section 8 provides another pathway for facts not inherently relevant to gain relevance. Motive may not directly prove the commission of the crime, but it helps the court understand why a person may have behaved in a certain way. Similarly, preparation—such as purchasing weapons, planning a meeting, or withdrawing money—may not be independently relevant, but it becomes highly significant in establishing a sequence of events.

Conduct is equally important; both before and after the incident, it can reveal intention, consciousness of guilt, or innocence. For example, an accused fleeing the scene immediately after the crime may not prove guilt, but this conduct becomes a relevant fact. Courts frequently rely on Section 8 to supplement weak or indirect evidence and build a coherent narrative around the behaviour of the accused or victim.

Facts Explaining or Introducing Relevant Facts (Section 9)

Section 9 widens the scope of relevancy by including facts that help the court identify persons, things, places, or circumstances connected with the fact in issue. These include:

• Identification of an accused or stolen property
• Details explaining a situation
• Information that clarifies inconsistencies

Even though these facts may not relate directly to the act, they assist in drawing a clear picture. For instance, identification parades held by police become relevant under this section. Section 9 supports the evidentiary chain by ensuring that the court has the contextual details required to evaluate the main evidence.

Facts That Form the Cause or Effect of a Fact in Issue (Section 7)

Facts that constitute the cause of an act or reflect its effects also become relevant under Section 7. For example:

• Injury marks
• Broken objects
• Bloodstains
• Damage caused by an incident

These may seem irrelevant standing alone but become relevant because they help reconstruct the scene of the crime. Courts consider physical effects as vital circumstantial evidence, especially in cases lacking direct testimony.

Facts Showing Conspiracy or Common Intention (Section 10)

Under Section 10, anything said, done, or written by any member of a conspiracy becomes relevant against all conspirators as long as it is done in furtherance of the common intention. Although statements of co-accused are normally inadmissible, they gain relevancy due to the legal bond created by conspiracy.

For example, text messages exchanged between conspirators may ordinarily be personal communications, but they become relevant when they advance unlawful design. Courts apply strict scrutiny to ensure that the conspiracy existed prior to admitting such facts.

Facts That Alter the Nature of a Contract or Dispute (Sections 92–94)

Under contract and property disputes, certain facts that appear irrelevant may actually change the interpretation or enforceability of a document. For instance, ambiguity in a contract may permit external evidence to clarify meaning. These exceptions allow the court to accept facts that would otherwise be barred under the rule of evidence relating to written instruments.

Facts Showing the Existence of State of Mind (Section 14)

Section 14 allows courts to consider facts that illustrate the intention, knowledge, good faith, negligence, or ill-will of a party. These mental states may not be independently verifiable, so external facts—such as prior behaviour, historical interactions, or expert testimony—become relevant by association.

This provision is crucial in cases involving fraud, defamation, rash driving, and criminal intention where the mental element (mens rea) must be established.

Facts About Habit, Business Practices, and Customs (Sections 15, 13)

A person’s regular course of conduct, organizational routine, or family custom may seem irrelevant in isolation. But when a dispute arises regarding how something typically occurs, these historical patterns become important to prove or disprove claims.

Courts accept evidence of:

• Business transactions
• Family customs
• Repeated behaviours
• Local customs

Such facts help determine whether a specific action aligns with established norms.

Facts Necessary in Special Circumstances (Sections 32, 33 & 47–51)

Certain facts become relevant solely due to a special condition:

• Dying declarations (Section 32) – admissible even without cross-examination
• Evidence from deceased or unavailable witnesses (Section 33)
• Expert opinion on handwriting, fingerprints, or foreign law (Sections 47–51)

These facts may not ordinarily be allowed, but necessity makes them relevant to ensure justice.

Mnemonic to Remember – “SCAM PIC-MR”

S – Section 6 (Same transaction / Res gestae)
C – Conduct, motive, preparation (Section 8)
A – Acts explaining facts (Section 9)
M – Mental state (Section 14)
P – Physical effects & cause (Section 7)
I – Identification (Section 9)
C – Conspiracy (Section 10)
M – Material customs & habits (Sections 13, 15)
R – Relevant due to special necessity (Sections 32, 33, 47–51)

Mnemonic sentence:
“Same Conduct And Motive Prove Identity, Conspiracy, Mindset, and Relevance.”

About lawgnan

Enhance your understanding of Conditional Relevancy with clear, exam-focused explanations on Lawgana.in. This article breaks down when facts that seem irrelevant gain legal significance under Sections 6 to 55 of the Evidence Act. Learn how res gestae, motive, preparation, conduct, conspiracy, identification, mental state, customs, and special circumstances transform unrelated facts into powerful evidence. Ideal for law students, judiciary aspirants, and legal researchers, our structured notes, real-life illustrations, and mnemonic SCAM PIC-MR make complex concepts easy to remember and apply. Visit Lawgana.in to strengthen your Evidence Act preparation with precision and clarity.