Section72
The Bharatiya Sakshya Adhiniyam, 2023

Comparison of signature, writing or seal with others admitted or proved

In force From 01 Jul 2024 Act 47 of 2023 As on 15 Oct 2026

Act 47 of 2023 Ministry Home Affairs Enacted 25 Dec 2023 In force 01 Jul 2024

Section 72 of the Bharatiya Sakshya Adhiniyam, 2023 deals with comparison of signature, writing or seal with others admitted or proved. In order to ascertain whether a signature, writing or seal is that of the person by whom it purports to have been written or made, any signature, writing, or seal admitted or proved to the satisfaction of the Court to have been written or made by that person may be compared with the one which is to The Act came into force on 01 Jul 2024.

(1) In order to ascertain whether a signature, writing or seal is that of the person by whom it purports to have been written or made, any signature, writing, or seal admitted or proved to the satisfaction of the Court to have been written or made by that person may be compared with the one which is to be proved, although that signature, writing or seal has not been produced or proved for any other purpose.

(2) The Court may direct any person present in Court to write any words or figures for the purpose of enabling the Court to compare the words or figures so written with any words or figures alleged to have been written by such person.

(3) This section applies also, with any necessary modifications, to finger impressions

Section 72, The Bharatiya Sakshya Adhiniyam, 2023 (Act 47 of 2023).

Replaces a provision of the Indian Evidence Act

IEA 73 Comparison of signature, writing or seal with others admitted or proved Text carried over almost unchanged 100%

Measured by comparing the text of the two provisions, not taken from an official correspondence table — there is no machine-readable one. See both texts side by side before relying on it.

Both regimes are live. The repealed enactment still governs what happened while it was in force. We never redirect one to the other.

Related judgements & precedents

These are some judgments that construed this section, and hold precedence value. They hold authority on how to read, interpret and use this section.

  1. K.S. Satyanarayana v. V.R. Narayana Rao

    Supreme Court of India 27 Jul 1999 Binding (Supreme Court) Reportable (1999) 6 SCC 104

    Decided under Indian Evidence Act 73, which this section replaces. The court did not have this Act before it.

    Court's Decision & Legal Precedent

    Judgment of Main Case order-1.pdf 1999-07-27 DATE VERIFIED. Saghir Ahmad/Wadhwa. Isolates IEA 73: when a party denies signatures on the vakalatnama and written statement, the court may itself compare admitted/proved writings with the disputed ones under s.73 instead of a protracted trial. Map iea 73 + BSA 72 successor (near-identical 1). Do not pad contract 70/72 (already filled).

    On this section: Successor of IEA 73 (mapping.csv near-identical, score 1). The comparison-of-signatures holding carries to BSA 72.

    Read the full order on eCourts India

  2. Ritesh Sinha vs State of Uttar Pradesh Home Department Secretary

    Supreme Court of India 02 Aug 2019 Non-Binding (Split Decision - Remanded For Three Judge Bench) Reportable

    Decided under Indian Evidence Act 73, which this section replaces. The court did not have this Act before it.

    Court's Decision & Legal Precedent

    The case resulted in a split decision with no clear ratio decidendi. Justice Desai held that: (1) Voice sample is physical non-testimonial evidence not covered by Article 20(3); (2) A Magistrate has ancillary or implied power under Section 5 of Identification of Prisoners Act and Section 53 of Criminal Procedure Code to authorize voice sample collection during investigation; (3) Voice prints are like fingerprints and fall within inclusive definition of 'measurements' in Prisoners Act; (4) Voice sample can be included in 'examination' under Section 53 through doctrine of ejusdem generis. Justice Alam held that: (1) There is no express or evidently applicable provision in law authorizing compulsion to give voice sample; (2) Explanation (a) to Section 53 deals only with material and tangible bodily substances, not voice; (3) Voice sample cannot be included in definition of 'measurements' in Prisoners Act; (4) Court should not invent law through interpretation; (5) Law must come from legislature, not through court process.

    On this section: Court may direct person to write words for comparison. Both judges agreed this section applies only to proceedings before court, not investigation stage.

    Read the full order on eCourts India

  3. Gaudiya Mission vs Shobha Bose

    Supreme Court of India 15 Jan 2008 Binding (SC)

    Decided under Indian Evidence Act 73, which this section replaces. The court did not have this Act before it.

    Court's Decision & Legal Precedent

    A statutory appeal under Section 384 of the Indian Succession Act, 1925 is a regular appeal allowing consideration of all questions of fact and law. The Division Bench of the High Court cannot dismiss such an appeal in limine without admitting it and deciding it on merits with a reasoned judgment. The scope of appeal before a Division Bench hearing an intra-court appeal from a Single Judge is the same as the scope before a Single Judge in First Appeal, encompassing both questions of fact and law, and the limitations of Sections 100 and 101 of the Code of Civil Procedure do not apply to such appeals.

    On this section: Enables courts to compare handwritings. Respondent relied on this to justify trial court's handwriting comparison, but court noted this should be done by experts, not judges.

    Read the full order on eCourts India

  4. Akkaldevi Prakash vs Eligeti Sangeetha Rani alias Bale Sangeetha Rani

    Prl. District and Sessions Court, Jagtial 08 Mar 2016 Persuasive (Other HC)

    Decided under Indian Evidence Act 73, which this section replaces. The court did not have this Act before it.

    Court's Decision & Legal Precedent

    The propounder of a Will must remove all suspicious circumstances surrounding its execution. If forensic evidence and witness inconsistencies suggest forgery, registration alone does not validate the document.

    On this section: Power of the court to compare disputed signatures with admitted ones.

    Read the full order on eCourts India

  5. Surabhi Srinivasa Rao vs Naidu Dorababu

    SENIOR CIVIL JUDGE, BAPATLA 03 May 2024 Persuasive (Other HC/Lower Courts)

    Decided under Indian Evidence Act 73, which this section replaces. The court did not have this Act before it.

    Court's Decision & Legal Precedent

    When a defendant alleges forgery but takes no proactive steps to provide expert evidence, the court is empowered under Section 73 of the Evidence Act to compare signatures and reach a finding of fact.

    On this section: Court's power to compare disputed signatures with admitted signatures.

    Read the full order on eCourts India

  6. Shri Yella Reddy vs Shri Amrojappa

    High Court 17 Sep 2009 Persuasive (Other High Court)

    Decided under Indian Evidence Act 73, which this section replaces. The court did not have this Act before it.

    Court's Decision & Legal Precedent

    Referral of signature comparison to handwriting expert is not a matter of right but a discretionary power of the Trial Court. The Trial Court may refer the matter to a handwriting expert only when it finds difficulty in comparing the signatures itself. If the Trial Court can compare the signatures without difficulty, referral to an expert is unnecessary and would be a futile exercise. The provisions of Order 26 Rule 10(A) of the Code of Civil Procedure are enabling in nature and do not create a mandatory obligation or a right for parties to demand expert opinion.

    On this section: Section 73 empowers Trial Court to compare signatures. Expert referral is discretionary and only when court finds difficulty in comparing signatures. This is the foundational provision for handwriting expert opinion.

    Read the full order on eCourts India

The holding above is the ratio decidendi as extracted from the judgment by eCourts India, reproduced unaltered — it is a rendering of the court's reasoning, not a substitute for its words. Read the order itself before relying on it.

Judgments citing this section

These may be obiter dicta or a precedent, for you to study. These are the judgments where this section is quoted.

  1. High Court 04 Sep 2024 KLHC011227562024

    … State of Rajasthan [AIR 2013 SC 633] that there is no legal bar preventing the Court from comparing signatures or handwriting or to compare the disputed writing with the admitted writing and then for applying its own observation to prove the said handwriting to be the same or different, as the case may be. Section 72 of the Bharatiya Sakshya Adhiniyam (Section 73 of the Evidence Act) also empower the Court to do so. Learned Counsel for the petitioner submits that liberty may be left open to make a request in this regard before the trial Court. Granting such liberty, the original petition is dismissed. > Sd/- VIJU …

    Read this order on eCourtsIndia

Questions about Section 72

What have the courts held on Section 72 of the Bharatiya Sakshya Adhiniyam?

K.S. Satyanarayana v. V.R. Narayana Rao (27 Jul 1999) is the leading judgment on this section among those set out below, though it was decided under IEA 73, which this section replaced -- the court never mentioned this Act: Successor of IEA 73 (mapping.csv near-identical, score 1). The comparison-of-signatures holding carries to BSA 72. Another 5 judgments on this section are set out below, 3 of them from the Supreme Court. They run from 1999 to 2024.

How do I find court cases under Section 72 of the Bharatiya Sakshya Adhiniyam?

In judgments and charge sheets this section is written several ways, and each form finds a different set of orders. These search the full text of every order eCourtsIndia holds, best matches first: BSA 72, section 72 BSA, section 72 of the Bharatiya Sakshya Adhiniyam. People searching for it also type bsa 72 hour rule. Each opens the full list of orders on eCourtsIndia, where it can be narrowed by court, year and outcome. 6 reported judgments on this section are set out on this page, beginning with K.S. Satyanarayana v. V.R. Narayana Rao (27 Jul 1999).

What should I read with Section 72 of the Bharatiya Sakshya Adhiniyam, and has it changed?

It carries forward IEA 73 (Comparison of signature, writing or seal with others admitted or proved), so the judgments decided under that provision are the case law on this one.

When did Section 72 of the Bharatiya Sakshya Adhiniyam come into force?

Section 72 of the Bharatiya Sakshya Adhiniyam, cited as BSA 72, came into force on 01 Jul 2024, having been enacted on 25 Dec 2023. It is in force as at the date shown on this page.

Other sections of this Act

Source and method. Compiled from the enactments of Parliament and of the State legislatures as published on India Code, and republished together with commentary and other original matter under section 52(1)(q)(ii) of the Copyright Act, 1957. Structured, cross-referenced and maintained by eCourtsIndia. Text as in force on 15 Oct 2026. This page is not a substitute for legal advice.