An exponential leapfrog of technological advancements caused every facet of societal involvement to be engulfed by technology. The world has witnessed a very hustle and bustle for embarrassing and adapting the virtues of technology into the daily life of humans. No one had succeeded in competing with the technological movement by raising excuses and interestingly, humans had reached a state where it is hard to survive ignoring technology. It is because nothing other than being more convenient, efficacious, and comfortable lifestyle posed by modern technology. Modern technology had developed and upgraded human life more qualitatively and quantitatively than previously. None of the fields deserved the adoption of technological advancements more than the legal sector since whole the aspects of the human being is maintained, controlled, and protected by law. The Judiciary which is known to be the kith and kin of the legal sector is deserved more to be transformed into technological advancements much before any field does so. As the judiciary is unable to be an exception for the adoption of technological advances, the Indian judiciary has transmitted and adopted many modern technologies into its various functionaries in order to smoothen its functions. However virtual Judicial functioning is the most advanced technology upended in the judicial system. The virtual court, where all court proceedings are done virtually, is a most modern initiative which has caught the attention of judicial systems all over the world owing to its efficacious and speedy access to justice, perhaps to be subjected for detailed research and study.

Vetting the technological movements taking place in the judicial system after the 90’s up to date would reveal a fact of a staggering and swift transition of Indian judicial systems to technology-based legal processes. At present, facilities for litigants to file the plaint electronically through e-filing, to pay the Court fees or fine online through https://vcourts.gov.in, and to view the status of the case has been operating well. However, for adjudication purposes, the litigant may have to appear in person or through a lawyer in the Court. Perhaps, traditional courts may be necessary for the future, but they are inadequate. Therefore, there is a need to integrate virtual courts into the existing legal ecosystem of the country.

DEFINITION OF VIRTUAL COURT

Virtual Courts are courts that employ a remote working system with the support of various software and technologies (1). They are courts where all regular court proceedings are undertaken via the virtual world which is a digital world. For instance, a virtual magistrates ‘court created by video links between police custody suites and a magistrates’ court together with an electronic document-sharing system to which all relevant parties have access (2). Thus, in such courts, none of the interested parties would have to visit and attend physically the courts. It is aimed at eliminating the presence of litigants or lawyers in the court and for adjudication of cases on a virtual platform (3). In Virtual Courts, Plaint and other documents are filed electronically, arguments are heard over videoconferencing/teleconferencing, evidence is submitted digitally, and judges decide Cases online either presiding from the physical Courtroom or any other place. A virtual court can be managed by a judge whose jurisdiction can be extended to the entire state and whose working hours may be 24X7 (4). To hold hearings entirely online, virtual courts are revising evidential, documentation, and procedural systems.

APPLICATION: CURRENT STATUS

Until now, none of the judicial systems all over the world had completely transformed into the concept of a virtual court. However, almost all judicial systems are on the way to virtual court since the 1990s and many courts have already introduced and experienced virtual hearings under certain circumstances. Moreover, many courts had experienced and gone through a virtual court system amidst the Covid-19 pandemic in order to eliminate personal contacts so as to prevent the spread of the disease. Its application midst the emergency situation has accelerated the steps and thoughts, which already existed in the pre-covid period, towards its application in the judicial systems even in the normal situation rather than emergency periods. Many industrialized and less developed nations have been laying policies and taking deliberate steps toward full digitization of their judicial systems, in light of the need that the system of administration of justice to be on par with the level of technical innovation in a civilized society (5).

The integration of technology in the Indian judiciary has been underway since the 1990s (6) and the efforts for it happened gradually over a period of time starting from the 1990s (7). At present, different levels of the Indian judiciary have embraced various technologies in their processes in order to reduce the time, and costs consumed and to speed up access to justice to people. Different initiatives launched by the Union Government of India and the Supreme court of India along with various judgments of the Supreme court and High Court and certain legislative amendments over the decade played a key role in the development of steps of virtual courts in India. Finally, the Covid-19 pandemic and the followed locked down have made us more closer towards the goal of virtual court. Let’s see what has been achieved in regard to virtual court until now in the judicial system of India. For convenience, we may divide the series of technological developments in the Indian judiciary into two phases, namely, pre covid and covid period.

• PRE COVID

Following are major renovations undergone in India towards the concept of virtual court before the COVID period:

• National Informatics Centre (NIC)
  The National Informatics Centre (NIC), established in 1976 by the Government of India in order to take effective steps for the development of information systems, proper utilization of information resources, and to introduce computer-based decision support system in government ministries and departments, initiated the transition of Indian courts to technologically developed one (8). In the 1990s, NIC played a major role in the information revolution at the district level, state level, And national level by implementing Information Technology projects at central and centrally sponsored sector programs.
  Unfortunately, since NIC was constituted to bring out technological improvements throughout the whole government sector, much attention was not taken to Judicial systems. However, the initiatives taken by NIC are plausible and stood as a motivation for further steps.
  A report related to NIC, while assessing its achievements, stated that a successful experiment through Video Conferencing between the Jail and the Court, wherein the under-trial is in the Jail complex and the Judge hears the under-trial sitting in the court was done in the state of Bihar effectively and it acknowledged technology facilitates speedy court cases trials. Additionally, in 1997, NIC along with the planning commission of India computerized 430 district courts.
• E-committee and E-courts
  In 2004 Chief Justice of India (CJI) made a proposal to the Central Government for the constitution of an E-Committee to assist him in formulating a national policy on the computerization of the Indian judiciary and advise technological, communication, and management-related changes, upon which the Ministry of Law and Justice constituted the E-Committee in the same year 2004. The E-Committee prepared a report on a strategic plan for the implementation of Information and Communication Technology(ICT) in the Indian Judiciary and presented it to the CJI in 2005.
  Consequently, it framed the National Policy and Action Plan for its implementation during a span of five years from the date of its effective commencement which ultimately would lead to a comprehensive e-courts project. The 230th Law Commission of India Report was the key to the formation of the Vision Statement and Action Plan 2009 which ultimately laid down the measures for the courts to be computerized and hence marked the advent of technology in the Indian Judicial System.
  The e-courts project was conceptualized by the Supreme Court of India, based on the “National Policy and Action Plan for Implementation of Information and Communication Technology (ICT) in the Indian Judiciary, 2005” published by the e-committee, with a vision to transform the Indian Judiciary by ICT enablement of courts.
  Its objective was to centralize its attention on utilizing ICT to provide services to all major stakeholders, including the judiciary, district, and inferior courts, as well as citizens, attorneys, and litigants. The project sought to improve court productivity and administer justice in a timely and cost-effective manner. However, the project was categorized into two phases.

Phase1

The phase1 commenced in 2007 and ended in 2015 was initially supposed to be finished within two years but took almost 8 years to complete. The Government approved the computerization of 14,249 district & subordinate courts by march 2014 with a total budget of rupees 935 crores. As of 30th September 2015, more than 95% of the mandated activities have been completed. (9)

Major achievements:

• Software: A unified national core application software – Case Information System (CIS) software – has been developed and made available for deployment at all computerized courts. Entry of data regarding past cases has been initiated, and data in respect of over 3 crore cases are available online.
• Video Conferencing facilities in courts and jails: A Video Conferencing (VC) pilot has been launched in five districts under the supervision of the e-Committee.
• National Judicial Data Grid: The national e-courts portal has become operational. The portal provides services to litigants such as details of case registration, cause list, case status, daily orders, and final judgments. Currently, litigants can access case status information in respect of over 5.5 crores pending and decided cases and more than 1.79 crore orders and judgments about the district and subordinate courts. Moreover, NJDG data also help the judiciary, judicial monitoring and management, and the government to get data for policy purposes. The installation of the National Judicial Data Grid (NJDG) has been regarded as the greatest accomplishment of the e-courts project in India.

Phase II (10)

In January 2014, the e-committee of the Supreme Court approved the Policy and Action Plan Document for Phase II of the e-courts project. And was commissioned with a budget of Rs. 1670 crore for four years in the year 2015. The Phase II of the project intended to focus apart on the computerization of courts across the country, in aiding the automation of workflow management which would enable the courts to exercise greater control over the management of a number of cases.

Features:

• Hardware for District Legal Service Authorities (DLSA) and Taluk Legal Service Committees (TLSC)
• The Development of Central Filing Centres
• Video-conferencing of all courtrooms and prisons
• Court libraries computerization
• Judicial Knowledge Management System

Afore said are some of the important features or goals of phase ii of the e-courts project. Further, it includes goals such as cloud computing, solar energy, information kiosks, live streaming of virtual hearings, etc. According to the "Objectives Accomplishment Report," Phase II initiated the transition to a single Case Information System (CIS), the creation of centralized filing centers, the computerization of judicial academies, video conferencing (VC) capabilities, the installation of a cloud computing network, the development of a court management system and improved ICT enablement through e-payment, e-filing, and the use of mobile applications with a focus on citizen-centric service delivery.

Video conferencing systems have been operationalized in 3240 court compounds and 1272 prisons, according to information provided to the Department Related Parliamentary Standing Committee on Personnel, Public Grievances, Law and Justice by the Department of Justice.

Additionally, Then Chief Justice of India Dipak Misra launched three applications in early August 2018, which included e-filing, e-pay, and NSTEP (National Service and Tracking of Electronic Processes). At the Tis Hazari court in Delhi, the first virtual court was launched on July 26, 2019. On August 17 of the same year, the Punjab and Haryana High Court established a virtual court that resolves traffic challan cases in Haryana. These projects were undertaken under the monitoring of the Indian Supreme Court's e-committee.

However, a question remained to be raised often that how well the e-court project has performed in both two phases. In fact, the current technological facilities provided by the project have been used prevalently by the stakeholders of the judiciary.

The purpose of the VC system during the pre-covid era was large to handle remand cases in order to stop inmates from moving between courts and prisons. These VC Facilities have been put into service with the 3240 courtrooms and 1272 associated prisons. The upsurge in e-transactions (from 2,2875,663 in 2013 to 84,5791377 in 2018) underlines the rising reliance of various judiciary stakeholders on the services made possible by the e-courts project.

• CASES APPLIED VIDEO CONFERENCING

Though during the Covid-19 period all the judicial proceedings of the apex court to lower courts were online, functions such as hearings, evidence presenting and testimony were done through video conferencing several times since 2000. Those stands as precedents for courts to follow, till date there are no exact provisions in any statute or piece of legislation dictating procedures for the utilization of video conferencing in courtrooms.

In Sucha Singh v. Ajmer Singh (11), Punjab's Ludhiana district's Samrala court allowed a US-based NRI to appear via video conference applications. In the case, of a dispute over property, at first, the court allowed the appellant residing in the USA to appear for examination through video conference apps with a condition that she shall go to any local authority where such facilities are available. But later, acknowledging the issue of the time difference, the court allowed using video conference apps personally without the intervention of any local authority.

In the case Maharashtra v. Dr. Praful B. Desai (12) the question under consideration was whether video conferencing could be used for recording evidence in a criminal trial. The Supreme court overruled the high court which held recording evidence via video conferencing is not compatible with the section 273 criminal procedure code and held that since the section requires only a constructive presence, not the actual presence, recording evidence via video conferencing is recognizable. However, the case stands as a strong precedent for e-evidence recording which is a vital part of a virtual court.

Amitabh Bagchi vs Ena Bagchi (13) is the case in which the Calcutta high court held that the section 65A and 65B of the India evidence act 1872 (14) provide provisions for electronic evidence such as electronic records and the admissibility of those electronic records, and video conferencing falls well under the definition of electronic records.

The aforesaid are some sort of instances wherein various courts had taken a robust stand towards the setup of technological advancements, including virtual court, within court proceedings.

• COVID PERIOD

The ordeal of COVID-19 was of justifying the well-known proverb “necessity is the mother of inventions”, though it caused fatal tribulations, as it endowed several positive changes in almost all walks of life.

It seems that the crisis has provided a ground for the realization of the words of the former prime minister of India Jawaharlal Nehru that “Crises and deadlocks when they occur have at least this advantage, that they force us to think.”

Jeannette Walls once said, “Sometimes you need a little crisis to get your adrenaline flowing and help you realize your potential”.

In fact, a substantial portion of enhancement in the progress and utilization of ICT has occurred during the Covid-19 period commenced from the start of 2019. An urgent meeting was held on 15th March 2020 by Chief Justice of India SA Bobde, wherein he discussed the precautions in an attempt to halt the Covid-19 epidemic, and issued guidelines for court functioning through video conferencing during the pandemic. Further, The chairman of the SC's e-committee, Justice DY Chandrachud, declared that video conferencing will be used for court hearings and that electronic filing is now available 24/7.

During the pandemic, the honorable high court of Telangana has initiated the mobile virtual court connecting system in Alidabad, in order to assist the lawyers and litigants, who have been under trouble participating in Virtual Court hearings due to the lack of a computer system or accurate internet, to attend court hearings through this mobile van seamlessly. (15)

Similarly, the high court of Uttarakhand set up five e-court vans equipped with Wi-Fi and computer systems. Judges will hear the cases – both civil and criminal – online while technical teams stationed in the vans will facilitate the appearance of witnesses, complainants, and experts before the virtual court and also help with documentation. (16)

According to a report in Times of India, “a local court has ordered trial through video conferencing (VC) on basis of demand made by a complainant in which additional sessions judge KK Dholakia ordered the prosecution to conduct all court proceedings in a murder case through video from Sabarmati Central Jail. (17)

Moreover, several hearings of both the supreme court of India and several high courts during the period of the pandemic were undertaken through video conferencing platforms.

ADVANTAGES

Some of the advantages that have been expected to be able to uphold by a virtual court system are described below.

1. Reduce the pendency of cases
   In fact, the first and foremost challenge faced by the Indian judicial system is the abnormal quantity of cases not disposed of yet and most of them are from years before. However, a virtual court could definitely find solutions for this. At the event of launching of computerization of courts organized by the Supreme Court of India, in his speech revealing the great potential of the e-judicial system in India, former president of India APJ Abdul Kalam said the aim of the e-Courts system should be to bring down the pendency by more than 60% in district courts from the existing 2.5 crores, in the high courts from the existing 36 lacks and in the Supreme Court from the existing 41,000 cases to 10,000 cases by the year 2012. (18)
   The 103rd Report of the parliamentary committee believes that transferring some kinds of cases from traditional courtrooms to virtual courts would help clear the backlog of cases that has been slowing down the justice system for decades.
2. Principle of Distributive Justice.
   Transformation of the judicial system and court service in a way accessible to all sectors of society is a vital part of distributive justice. Since 'Digital Justice’ is cheaper and faster, people living in remote and far-flung areas can also take part in court proceedings through video conferencing without having to spend a fortune to set foot in the courtroom. The Constitution of distributive justice in a country like India consisting of a vast and wide geographical and demographical collection is certainly achieved by digital justice.
3. Less time and place cost
   Conduction of cases in the honorable Supreme court, in particular, creates a great time and place cost to its stakeholders. A facility that helps to participate and activate in court proceedings from anywhere in India perhaps, reduces it (vehemently). Moreover, since it facilitates speedy justice, it will save more time for judicial officers and lawyers in which they can go through other cases and it ultimately leads to the reduction of the pendency of cases. Since people can access court proceedings from either home or the workplace, litigants do not need to leave their jobs to attend court. Additionally, it reduces the enormous logistical expenses related to moving inmates between jail and court and reduces footfalls in the courts by eliminating the physical presence of parties and lawyers in the court thereby saving precious judicial time.

Furthermore, benefits such as enhancement of efficiencies in proceedings, less stress on physical infrastructure, the lesser crowd in courtrooms, lesser waiting time in court corridors, more productive use of time and money, lesser vehicles on the road, and improved work-life balance are also expected. And then, there is the hope for a healthier environment.

DISADVANTAGES

The concept of the virtual court is not free from critics and challenges. Though a little bit critics are out of ignorance of the concept, some of them are genuine.

Sr. Counsel Rakesh Dwivedi in a letter to CJI SA Bobde has stated that “Courts are sentinels of fundamental rights. There are backlogs. Vital interests of the people are involved and the cases are in quarantine. Video Conferencing is like putting the court in ICU on oxygen”. Further, described the system as a “self-destructive idea”. However, his concern might be raised in the context of disruptions that occurred during virtual hearings. (19)

Technical issues

In a survey conducted in Europe among mostly legal professionals though, 71,5% reported positive experiences, and 50% had experienced technical problems. (20)

Adequate, secure, and user-friendly technical facilities such as several hardware and software along with technical know-how are fundamental requisites so as to proceed with efficacious court processes through a virtual platform. Though Indian courts have basic technological advancements at present, are to be enhanced more. All the stakeholders, including the parties, of the judiciary, too provided with such facilities. They should have access to locations where they can watch court proceedings online without having to purchase expensive equipment, such as town halls, police stations, or courts. Moreover, the fund required for such advancement and the lack of technical know-how is also a concern. However, fortunately, Covid-19 made many lawyers and judicial officers familiar with these. Poor connectivity also stands as a major concern particularly, in rural areas. Most of the critics were regarding this.

Security and privacy issues

The foremost challenge being faced by information and communication technology all over the world is the issues regarding security and privacy. Leakage of judicial data, which is to be very confidential and sensitive, would lead to high instability. This is more vulnerable when third-party software is used. The right to privacy, one of the fundamental rights guaranteed by the constitution of India would probably be violated in digital platforms. Moreover, it is hard to protect data and software from hacking.

• VIEWS OF COURTS

Indian courts have been proactive in embracing advancements in technology in Judicial proceedings. (21) In the case Amitabh Bagchi vs Ena Bagchi, the court observed that “Video conferencing is an advancement of science and technology which permits one to see, hear and talk with someone far away with the same facility and ease as if he is present herein. The only difference is that one cannot touch the person concerned. Even then, it will not disentitle a person to give evidence in such a way because of various reasons which we are now considering.” Pointing out the making of things easier and flexible as the essential requirement of advancement of technology and its application, the court opined “the Video conferencing is one such facility and it is to be evaluated with the amount of delay, expenses or inconvenience. If it appears that electronic video conferencing is not only much cheaper but also facilitates the court and avoids the delay of justice, a practical outlook is to be taken by the Court.” However, the court suggested that “in allowing such prayer Court will, first of all, consider whether linkage of such facility will be available between two places or not”. Court further remembered that “ If the Law Courts do not permit technology development in the Court proceedings it would be bagging behind compared to other sectors”.

In the case, Suvarna Rahul Musale vs Rahul Prabhakar Musale (22) Bombay HC observed that “an attitude change in judges is required. We need to train ourselves to understand the pulse of the new generation who is avidly techno-savvy. Though it is difficult for Judges, especially those who are in their middle age, to accept and digest the entry of new language and methods of evidence in the established judicial system, it is high time for us to change our mindset and see whether this new technology can help us to increase the speed and also we have to take into account the convenience of the parties as our judicial system is necessarily litigant centric”.

In the case, Bhasin vs Union Of India (23) SCI opined that “Law and technology seldom mix like oil and water. There is consistent criticism that the development of technology is not met by equivalent movement in the law. In this context, we need to note that the law should imbibe technological development and accordingly mold its rules to cater to the needs of society. Non-recognition of technology within the sphere of law is only a disservice to the inevitable. In this light, the importance of the internet cannot be underestimated, as from morning to night we are encapsulated within cyberspace and our most basic activities are enabled by the use of the internet.”

• LEGISLATIVE BACKDROP

Legal sanctity was given to video conferencing by the Supreme Court of India by an overarching order invoking Article 142 of the Constitution of India (24) passed on 6th April 2020 which covered all the High Courts in the country. The use of technology found judicial recognition in precedent in the State of Maharashtra v Praful Desai. In this case, the court pronounced that section 273 CrPC includes constructive presence. This demonstrates that being present in person is not required. It is clear from this that the word "presence," as it is employed in this Section, does not refer to physical presence and evidence can be produced in both oral and documentary, and electronic records. This indicates that evidence, even in criminal matters, can also be by way of electronic records. This would include video conferencing. Court further denied the claim that video conferencing is a violation of Article 21, as it is a virtual reality, saying that it is nothing more than actual presence. Order 18 Rule 4 of CPC (25) is also to be read with this.

In the case Amitabh Bagchi vs Ena Bagchi, the Calcutta High court remembered that by virtue of an amendment and insertion of Sections 65A and 65B of the Indian Evidence Act, a special provision as to evidence relating to electronic records and admissibility of electronic records, has been introduced with effect from 17th October 2000.

• SUGGESTIONS

The pandemic is one of the several causes for adopting virtual court. Travel may become difficult as a result of the climate problem, necessitating the usage of remote hearings. It's unlikely that video proceedings would fade once the pandemic is over. In a survey of registrants at the online E-justice Conference held by the German Federal Ministry of Justice on Dec 8, 2020, 70% of respondents said that video hearings would be commonplace throughout Europe in three years.

Indian courts are abundant in technological advancements though, not enough. 230th law commission report says that” now digital technology offers us new packages like database, ERP tools, court management practices – these will help in increasing the Productivity of courts; video-conferencing – through which we can record evidence. There is, therefore, vast technology available for the Courtroom, for enhancing the quality of justice, and finding the truth”. Further, it added “India is renowned as the origin of the software. The entire world is watching us. There are numerous companies here, including TCS, Infosys, HCL, and Wipro.”

In fact, a virtual court isn’t an absolute substitute for physical court, since inescapably, there are some cases that do not accord themselves to being settled virtually. Among these are, of course, criminal cases which are most sentimental and serious in nature, such as dishonesty or allegations of professional negligence, cases involving allegations of fraud, and those where hotly disputed witness evidence that demands scrutiny, as such appearances, which have historically been seen to influence how much weight the court gives to the evidence such as body language of witnesses, attitude and demeanor which are harder to evaluate in a virtual courtroom. Thus, decisions must be made regarding whether hearings are appropriate for video hearings and complaints might be resolved more successfully when parties and judges are available in one courtroom.

The report of Rajya Sabha suggested some offenses more suitable to treat virtually such as petty offenses where summons can be issued under section 206 of CrPC, Motor Accident Claim Petition cases, cases registered under Section 138 of the Negotiable Instruments Act, offenses under Motor Vehicles Act (Traffic Challan cases) and all matters where a person's physical presence can be waived. Further, it suggests that the idea of virtual courts be expanded to include summary trials, conciliation, and arbitration hearings.

Thus, virtual or remote hearings should be used as an alternative method of hearing in appropriate cases to reduce the need for burdensome physical appearances where they are useless, saving time, energy, travel, and other expenses. Physical court hearings would still be required in many proceedings. (26)

Further, the possibility of introducing computer courses as one of the subjects in the law courses, To help students become accustomed to using computers and online learning systems while pursuing a legal education, is to look by the bar council of India, as per the report suggests.

"Judges and Lawyers must work hard to ensure that sensitivity and humanity are not lost on the altar of technology," opined one critic on the virtual hearing procedure. Lord Maldon also reminded his peers that despite some in-person litigants not having access to technology, there is a feeling that there will be an increase in demand for the use of remote technology as a result of the success of remote hearings. As the nation loosens up its current Covid-19 working restrictions, he also asked for the current investments in the modernization of the courts to be maintained. (27) Nick Herbert, Minister for Policing and Criminal Justice said: “Live links free up valuable police time and resources to carry out their frontline duties and ensure crimes are dealt with more quickly and effectively”. (28) These emphasize the need for a scope of virtual court.

• CONCLUSION

As India is considered a rapidly developing country, undoubtedly, its judiciary has a pivotal role in maintaining and enhancing its development since the law and justice are considered the bedrock of any democratic country. That’s why the judiciary is known as the mirror of society. Technology is now the key player which molds a country into a developed one since no facet of humans is an exception to technology. Hence, the integration of technology into the judiciary perhaps transforms and leads the country into a developed one. Almost all aspects of this integration have been discussed briefly above. However, it is mentioned that the Indian judiciary underwent technological advancements which are essential for the establishment of virtual courts. Since virtual courts are not a pure substitute for physical courts, at present, on the way forward much thoughts have to be undertaken in legislative and judiciary in order to specify the types of cases wherein virtual courts are more accessible, accountable, transparent, and cost-effective. Further, we need to strike a balance between “justice delayed is justice denied” and “justice hurried is justice buried”. As with any other reforms, virtual courts also have to be aimed at the welfare and goodness of people. Apart from all this, the proactive approach of Indian courts in embracing technological advancements lefts an axis of hope in India that virtual courts are not far from us.

Reference:

1. Papiya golder, Future of virtual courts in India post pandemic: An Analysis, 7 IJRAR, 982, (2020).
2. Law insider, 
3. Information and Communication Technology in Indian judiciary, 
4. National informatics centre, 
   
5. Ngozika Rosemary Oji, Virtual/Remote Hearing: The Impact of Covid-19 Pandemic on the justice Sector in Nigeria, 3 IJOTAS, (2020).
   
6.  E-committee Supreme Court of India, National policy and action plan for implementation of ICT in the Indian judiciary, (2005).
   
7. Shubhank Patel, Video conferencing: an emerging concept on courtrooms, 1 International review of law and technology, (2020).
   
8. National Informatics Centre, Organization functions and duties (2017), 
   
9. Department of Justice India, Brief on e-courts Project (Phase I & Phase II), (2016).
   
10. National council Of applied economic research, Information & Communication technology in the Indian Judiciary: Evaluation of the e-courts Project Phase-II, (2021).
    
11. Sucha Singh v. Ajmer Singh,2018 SCC Online P&H 637 (2018).
    
12. State of Maharashtra v. Dr. Praful B. Desai, AIR 2003 SC 2053(2003).
    
13. Amitabh Bagchi vs. Ena Bagchi, AIR 2005 Cal 11(2005).
    
14. Section 65A and 65B of the Indian evidence act, (1872), of Admissibility of electronic records.
    
15. Virtual court connecting mobile van launched in Adilabad, The hindu news, (2020), 
    
16. E court vans to reach remote Uttarakhand hills, Times of India news, (2021), 
17. Murder case trial through video conferencing, Times of India, (2013), 
18. Dr. APJ Abdul Kalam, Evolution of e-judiciary, Address during the launch of computerization of courts, New delhi, (2007), 
    
19. Cases are in quarantine, The economic times news, (2020), 
    
20. Sanders, A., 2021. Video-Hearings in Europe Before, During and After the COVID-19 Pandemic. International Journal for Court Administration, 12(2).
    
21. Supreme Court Of India, Guidelines for court functioning through video conferencing during covid-19 pandemic, (2020).
    
22. Suvarna Rahul Musale vs Rahul Prabhakar Musale, High Court of Bombay, 2014.
    
23. Bhasin vs Union Of India, AIR 2020 SC 1030.
    
24. Article 142 of the Constitution of India 1950, of Enforcement of decrees and orders of Supreme Court.
    
25. Order 18 Rule 4 of CPC, Recording of evidence by commissioner.
    
26. Ngozika Rosemary Oji, Virtual/Remote Hearing: The Impact of Covid-19 Pandemic on the justice Sector in Nigeria, 3 IJOTAS, (2020).
    
27. Fiona Gillett, Remote hearings in England and Wales, International bar association, 
    
28. Gov.uk, Digital technology delivers more swift and effective justice, (2011), 
    

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