In a significant procedural directive aimed at improving the clarity of evidence placed on record, the Supreme Court has directed its Registry to stop clearing paper-books for listing if they contain black-and-white photographs. The Court has mandated that all photographs must be coloured, accompanied by distance dimensions, and supported by a conceptual plan.
The Order
The direction came during the hearing of a Special Leave Petition arising out of a final judgment and order dated March 15, 2024, passed by the High Court of Bombay at Goa in Writ Petition No. 820 of 2023.
Observing the necessity for clear visual materials in judicial records, the Bench comprising Justice Surya Kant, Justice S.V.N. Bhatti, and Justice Joymalya Bagchi issued stringent instructions to the Registry regarding the acceptance of photographic evidence.
The Court explicitly ordered:
“The Registry is directed not to clear any paper-book for listing where the photographs appended are black-and-white.”
New Requirements for Filing Photographs
The Supreme Court laid down specific criteria for Advocates-on-Record (AORs) regarding the submission of visual material. The Bench directed that the following instructions be circulated amongst all AORs:
- Coloured Photographs: All photographs appended to the paper-book must be in colour.
- Distance Dimensions: The photographs must include distance dimensions to provide spatial context.
- Conceptual Plan: The photographs must be supported by a conceptual plan.
The Court warned that non-compliance with these directions would result in the material being rejected. The Order stated:
“Unless proper coloured photographs, along with distance dimensions and supported by a conceptual plan, are appended, no such material shall be allowed to be placed on record, and the matter will remain in the list of ‘defects not cured’ till further orders.”
Hard Copies Mandatory for E-Filed Photos
Addressing the practice of electronic filing, the Bench clarified that digital submission alone is insufficient for coloured photographs. The Court directed:
“If the photographs appended with the paper-book are filed through e-mail or e-filed, the learned AORs are directed to simultaneously submit hard copies of the coloured photographs also.”
The matter has been posted for further hearing on January 9, 2026.
Legal Representation
- For Petitioners: Mr. Shoeb Alam (Senior Advocate), Mr. M. De Souza, Mr. S.S. Rebello, Mr. Parijat Kishore (AOR), Mr. Raghav Sharma, Ms. Manisha Gupta, Ms. Moulishree Pathak, Mr. Ujjawal Agrawal, and Mr. Jaskirat Pal Singh.
- For Respondents: Mr. Dhruv Mehta (Senior Advocate), Mr. Ninad Laud, Mr. Keith Varghese, Mr. Guruprasad Naik, Mr. Dcosta Ivo Manuel Simon (AOR), Mr. Abhay Anil Anturkar, Mr. Dhruv Tank, Ms. Surbhi Kapoor (AOR), Mr. Sarthak Mehrotra, Mr. Bhagwant Deshpande, Ms. Subhi Pastor, and Mr. Abhay Singh (AOR).
Case Details:
- Case Title: Dinamati Gomes & Anr. v. State of Goa & Ors.
- Case Number: Petition(s) for Special Leave to Appeal (C) No(s). 7944/2024
- Bench: Justice Surya Kant, Justice S.V.N. Bhatti, and Justice Joymalya Bagchi
- Date of Order: November 21, 2025
