Sections 4 to 7 lay down various ways in which the facts are so related to each other to form compenent of the principal facts. These sections enact the law which is usually laid down in England in these terms, i.e., that acts, declarations and incidents which constitute or accompany and explain the fact or transaction in issue are admissible for or against either party as forming parts of res gestae.
Meaning of res Gestae
This is a Latin phrase which means 'thing said and done in course of same transaction'. It may be defined as those circumstances, facts or transactions which are in continuity of main transaction. It includes everything which can be considered to be fairly connected with the main event. The essence of doctrine is that a fact which though not in issue, is so connected with the fact in issue as to form part of same transaction becomes relevant by itself.
These incidents may be separated from the facts by lapse of time. It may consist of sayings and doings, thing left undone as well as things done. The test of admissibility of evidence as a part of res-gestae in whether the act, declaration or exclamation is so intimately interwoven or connected with the principle facts as to be regarded as a part of the transaciton itself.
Principle: The underlying principle behind the res gestae is that when any transaction is a fact in issue, then evidence can be given of every fact which form part of the same transaction. The doctrine of res gestae enables the court to take into account all the essential details of the transaction. It serves the purpose of completing the missing link. The rationale behind making crtain statements or fact admissible under Section 4 of BSA is on account of the spontaneity and immediacy of such statement or fact in relation to the fact in issue.
Res Gestae under Bhartiya Sakshya Adhiniyam
Section 4 of the BSA is a direct manifestation of the doctrine of res gestae as followed in England. This section provides that facts, though not in issue, but are so connected with fact in issue or relevant fact as to form part of the same transaction are relevant. They may occur at the same time or place or at different times and places. The national in making certain statements or facts relevant under Section 4 is on account of spontaneity and immediacy of such statement or fact in relation to the fact in issue.
Supreme Court in Javed Alam v. state of Chhattisgarh (2009) 6 SCC 450 held that the test for applying the rule of res gestae is that statement or fact should be spontaneous and should form part of same transaction ruling out any possiblity of conconction.
Same transaction: The term 'same transaction' has not been defined in the BSA. According to Stephen, a transaction is a group of facts connected together to be referred to by a single legal name, a crime, a wrong, a contract or any other subject of enquiry which may be in issue.
In G. Vijayvardhan Rao v. State of UP, AIR 1996 SC 2971, Supreme Court held that for a statement to be part of transaction it must be spontaneous and must be contemporaneous with the fact. If the statement is made after the act is over and its maker has time to think and reflect then it it not relevant.
In Teper v. R, 1952 AC 480 (PC), Privy Council held that the rule that in criminal trial hearsay evidence is admissible if it forms part of the res gestae is based on the proposition that the human utterance is both a fact and a means of communication. It is essential that the words sought to be proved by hearsay should be, if not absolutely contemporaneous with the action or event, at least clearly associated with it that they are part of the thing being done.
In Sukh v. State of UP (1999) 9 SCC 507, Supreme Court held that the test for determining whether the fact forms the part of same transaction or another depends upon whether they are related to one another in point of purpose or as cause and effect or as probable and subsidiary acts as to constitute one continuous action.
In Basanti v. State of Himanchal Pradesh (1987) 3 SCC 227, when shortly after the murder, the person suspected of murder described the absence of the deceased by saying that he had left the village, the court held that the statement as part of same transaction and thus relevant.
In R. v. Foster (1834)6 C & C 325, the deceased has been killed by a speeding truck, the witness had not seen the incident but the speeding truck. The deceased stated to him what had happened with him in the accident. The court held that the statement of the deceased to the witness to be admissible as res gestae.
Psychological facts or words accompanying Physical acts: The words spoken by the person doing the act or by the person to whom they were done or by bystanders are relevant as a part of same transaction, provided they are contemporaneous with transaction and there is no interval so as to give time and opportunity for fabrication.
In R v. Bedingfield, (1879) 14 Cox CC 341, on a trial for murder, it appeared that the deceased with her throat cut came suddenly out of a room in which she had left the accused and she said immediately 'see what Harry had done to me'. The court held that her statement was not admissible in evidence either as a dying declaration or as res gestae. The court held that statement must strictly accompany or be made at the same time as phusical act in question. This decision was later overruled in R v. Andrews, 1987 AC 281 (HL). In this case House of Lords allowed the stateme of the deceased to be admitted as part of res gestae even when there was some time gap between the statement and the event of stabbing and robbery.
The statement should not be a mere narrative of past occurence. For example in Sanwal Das v. State of Bihar, AIR 1974 SC 778, 'A' assaulted 'B' on the neck with a knife and this is seen by bystanders who exclaimed A is killing B. The exclamation is an much part of the transaction of murder as the gushing out of the blood from the wound inflicted on the neck.
On the other hand, in State of A.P. v. Panna Satyanarayan, AIR 2000 SC 2138, the accused murdered his wife and daughter. The father of deceased wife stated that the father of accused told him on telephone that his son had killed the deceased. There was no finding as to whether such information was given either at the time of commission of crime or immediately thereafter so as to form part of the same transaciton. The statement was held not to be relevant under Section 6 [Now Section 4 of BSA].
Time and Space: Section 4 specifically provides that the fact forming part of same transaction may occur at same time and place or at different times and places. Thus, the act or transaction may be completed in a moment of time or, if there are connecting circumstances, it may extend to a period of days, weeks or even months. Similarly, no limitation can be imposed as to territorial boundaries within which the transaction must occur.
For example a person is charged for waging a war against State in pursuance of which properties were destroyed and troops were damaged. Even though the acts were committed at different times and places, but they form part of general transaction [Illustration (b) to Section 4]. Thus such facts may be proved by giving evidence even if it is hearsay or even if committed at different time and places provided they are part of same transaction.
Hearsay and Res Gestae
Supreme Court in Gentela Vyayyavardhan Rao v. State of A.P., AIR 1996 SC 2791 held that rule embodied in Section 6 [now Section 4 of BSA] is an exception to general rule that hearsay evidence is not admissible. Hearsay evidence simply means that the person has not seen the actual happening of the incident but he has heard it from others. As a general rule evidence must be direct and hearsay evidence is not admissible in the court. However, if such evidence forms the part of same transaction as to quality as res gestae then the evidence may be given. Doctrine of res gestae constitutes as an exception to the principle of hearsay. In R v. Foster, the witnesses had only seen speeding vehicle and not the incident. The injured person explained to him the nature of the accident. The witness was allowed to give evidence of what the deceased said because it formed the part of same transaction i.e. res gestae. Supreme Court in sukhar v. State of UP., 1999 (7) JT 537 held that for bringing hearsay evidence within the provision of Section 6 [Section 4 of BSA], what is required to be established is that it must be almost contemporaneous with the acts. There should not be an interval which will allow fabrication.
Facts which form the occassion, cause or effect of facts in issue
Section 5 makes the following facts relevant:-
i. Facts which are the occasion, cause or effect (immediate or otherwise) of facts in issue or relevant facts.
ii. Facts which constitute the state of things under which they happened.
iii. Facts which afforded an opportunity for their occurence or transaction.
Occasion
In R v. Richardson the deceased girl at the time of murder was alone at the home. This fact is relevant because it constituted the occasion to commit murder.
Cause
The act in question must have been done by the person who had the cause for it. Evidence can be given of such circumstances which constitute the casue for the happening of the act.
Effect
In R v. Richardson, a girl was killed in the cottage. The scene of the crime showed that the prints of the footsteps which suggested that the accused must have worn the shoe which had iron knobs or nails in them. This was the effect of the fact in issue.
When a person dies because of poisoning the symptoms of poison are relevant as they are effects of the facts in issue. Illustration (c) is the correct illustration on this point.
Opportunity
In R v. Donellan, the deceased used to take a medicine in a routine manner which was given by her mother. The accused knew the routine of the medicine and one day he replaced the bottle of the medicine with bottle of poison. Mother innocently administered poison knowing it to be medicine. Knowledge of the accused was held to be relevant as it served as an opportunity to commit the crime.
State of things
In Ratten v. Reginam, the accused shot down his wife and took the defence of the accident. The fact that the accused was unhappy with his wife and was having an affair with the another woman was held to be relevant as it constituted the state of things for the happening of the act.
Motive, Preparation and previous or subsequent conduct.
Meaning of motive
The term 'motive' has not been defined in the Adhiniyam. A motive is that which moves a man to do a particular act. Motive should not be confused with intention which is an act of the will directing an act or a deliberate omission. It shows the nature of the act which the man believes he is doing.
Supreme Court in Suresh Chandra Bahri v. State of Bihar, 1994 Cr. LJ 3271 (SC) held that motive is something which prompts a person to form an opinion or intention to do certain acts. Neverthless absence of proof of motive does not render the evidence untrustworthy or unreliable. By itself, motive does not constitute any crime but once the crime is committed the evidence of motive assumes significane.
In R v. Palmer, accused borrowed huge sum of money from his friend. His friend asked for his money one day and died in suspicious circumstances after that. The fact that Palmer had strong motive to eliminate his friend was held to be relevant.
In Parshwananth v. State of Karnataka, AIR 2010 SC 2914, it was held that if the case is based on a circumstantial evidence of motive becomes material. [Illustrations (a) and (b) of Section 6 are examples of motive]
Relevancy of motive
There is hardly any act without motive. Ordinarily, the feelings and propensities under which the parties act are so uniform in their operation that a conclusion may safely be drawn that if a person acts in a particular manner, he does so under the influence of particular motive. Thus, facts which show or constitute motive are made relevant under Section 6(1) of the Adhiniyam.
For example 'A' is tried for murder of B. The fact that B known that A had murdered C and that B had tried to extort money from A' by threatening to make his knowledge public are relevant as they show the motive of 'A' for killing B who was blackmailing him.
Motive: How far relevant?
The Supreme Court, in Babu v. State of kerala, AIR 1999 SC 3861, discussed the relevancy and importance of motive and held as follows:
1. Motive is relevant as it aids the court in analyzing the evidence. Absence of motive increased the duty of court to become more, cautious in scrutinizing the evidence.
2. Where there is convincing eye witness in a case, motive has no role to play and it recedes in background.
3. Motive alone cannot be sole ground for convicting the accused.
4. Motive is not important when direct evidence is available. It is in case of circumstantial evidence that motive assumes importance.
Supreme Court in Sukhpal Singh v. State of Punjab, (2019) 15 SCC 622 held that the inability of prosecution to establish motive in a case of circumstantial evidence is not always fatal to the prosecution.
Preparation when relevant
Section 6(1) also lays down that preparation made by the accused to commit a crime is always relevant. Preparation itself is not a crime except in certain circumstances but when the crime is committed the preparation becomes relevant. It evidences a design or plan to do certain thing as planned. The probative force of preparation rests on the presumption that an intention to commit the offence was framed by the accused which persisted until it carried into execution. Illustration (d) refers to the acts of preparation.
Conduct of party when relevant
According to Wigmore, conduct is the effect and expressions of inward emotions. Section 6(2) makes conduct of any person relevant. The conduct may also include the statement accompanying and explaining.
Supreme Court in State (NCT of Delhi) v. Navjot Sandhu (2005) 11 SCC 600 held that the conduct, in order to be admissible under Section 8 [now section 6 of BSA] must be such that it has close nexus with a fact in issue or a relevant fact.
Explanation 1 to Section 6 makes it clear that mere statements do not constitute 'conduct' unless they accompany and explain acts other than statements. It is to be noted that the conduct of a party alone is admissible and not of a person who is not a party to the suit. Conduct of following persons is relevant:-
1. Any party, or his agent, to any suit or proceedings in reference to such suit or proceedings or in reference to any fact in issue or relevant fact.
2. Accused person i.e. person against whom offence is subject of any proceedings.
For example the question in whether 'A' was ravished. The fact that shortly after the alleged crime, she made a complaint relating to the crime, the circumstances under which and the terms in which the complaint was made are relevant. Conduct of an accused is relevant against him and not against his co-accused.
Statements affecting conduct of a party - Explanation 2: Explanation 2 to Section 6 provides that when the conduct of any person is relevant, any statement made to him or in his presence or hearing which affects such conduct is alo relevant.
For example: where the question is whether A robbed B, the fact, that after B was robbed, C said in A's presence - The police are coming to look for the man who robbed B and that immediately afterwards A ran away, are relevant as the statement of C explains and affect the conduct of A.
Supreme Court in Amina v. Hasan Koya, (2003) 6 SCC 93, held that the reason why evidence of conduct is allowed is because the man's conduct is always influenced by what he has been doing before or after the act. It is necessary that the conduct in question should either influence the facts or be itself influenced by the facts.
In Queen v. Abdullah, the accused was guility of murder of a young girl. The throat of the girl was slit and she was unable to speak. But, while in hospital she was in a conscious state. When she was asked about the assailant and the name of Abdullah (accused) was mentioned, she made affirmative signs. The majority held that in this case Section 8 [Now Section 6 of BSA] is not applicable and the conduct must be influence directly by the facts in issue/relevant facts and not by interpretation of words spoken by the third persons. The evidence was held to be relevant as dying declaration under Section 32 of the Act [Now Section 26 of BSA].
Supreme Court in State (NCT of Delhi) v. Navjot Sandhu, (2005) 11 SCC 600 observed that the conduct of the accused in pointing out the police the place of hiding the murder weapon is relevant under Section 6 of BSA.
Relevancy of tape recorded conversation
Tape recorded conversation may be relevant under Section 4, 5 or 6. Supreme Court in R.M. Malkani v. state of Maharashtra, AIR 1973 SC 157 observed that the tape recorded conversation is admissible provided the conversation is relevant to the matters in issue and there is identification of the voice and the accuracy of conversation is proved by eliminating the possibility of erasing the tape record. Court helf that documentary evidence even in criminal matters could be by electronic records including video conferencing.
Supreme Court in Ram Singh v. Co. Ram Singh, AIR 1986 SC 3 held that a tape recorded statement is admissible in evidence, subject to following conditions:-
1. The voice of the speaker must be identified by the maker of the record or other persons recognizing his voice. Where the maker of the record is unable to identify the voice, strict proof will be required to determine whether or not it was the voice of the alleged speaker.
2. The accuracy of the tape recorded statement must be proved by the maker of the record by satisfactory evidence; direct or circumstantial.
3. Possibility of tampering with, or erasure of any part of the tape recorded statement must be totally excluded.
4. The tape recorded statement must be relevant.
5. The recorded cassette must be sealed and must be kept in safe custody.
6. The voice of the particular speaker must be clearly audible and must not be lost or distorted by other sound or disturbances.
Further, in Yusufalli v. State of Maharashtra, AIR 1968 SC 147 Supreme Court held that the court must be satisfied beyond reasonable doubt that the tape record has not been tampered with.
Facts necessary to explain or introduce facts
Section 7 of Bhartiya Sakshya Adhiniyam makes facts which are necessary to explain or introduce facts in issue or relevant fact, as relevant in so far as they are necessary for that purpose. Thus, facts which are introductory or explanatory in nature can be proved if they have direct bearing on fact in issue
Explanatory Facts
There are some evidence which if considered separately and alone from other evidence would not amount to anything, but if taken into consideration with some other facts proved in the case, it explains and illustrates them and such facts are relevant under Section 7 of BSA. Evidence of explanatory facts are not relevant in itself if they are considered separately.
For example 'A' sues 'B' for inducing 'C' to break a contract of service made by him with A. C on leaving A's service, says to A - I am leaving you because B has made me a better offer. This statement of C is a relevant fact as it explains C's conduct which is relevant as a fact in issue [ Illustration (d) to Section 7]
Where a person is tried for leading certain people to riot by marching them, the cries of the mob may be given in evidence as explanatory of the nature of the transaction. [Illustration (f) to Section 7]
Introductory Facts
The reasons for making introductory facts relevant under Section 7 is that it would be pratically impossible in conducting a suit or proceeding to jump directly on the main fact. A judge needs some introductory matter in order to know the circumstances leading up to the main incident and the result that follow it. Such introductory facts are of great help in supplying the missing link.
For example A sue B for a libel imputing disgraceful conduct to A; B affirms that the matter alleged to be libelous is true. The position and relations of the parties at the time when the libel was published may be relevant facts as introductory to fact in issue. [Illustration (b) to Section 7]
Facts which support or rebut inferences
If a fact in issue or a relevant fact suggests any inference then all those facts which support or rebut such inferences would be relevant. For example, if shortly after crime A absconds then this act will be relevant under Section 6 as conduct. Now any fact which either supports or rebuts this conduct will be relevant under Section 7. If after absconding he is arrested in train without ticket then this fact will be relevant as supporting the inference that he is guilty. If he is able to show that he left home because of some urgent work then also the fact will be relevant as rebuttable of his guilt.
Identity of a person: If the circumstances so arise that the court needs to know the identity of a person then any fact which establishes his identity is relevant. Therefore, under this section test identification parade become relevant. In Ram Lochan v. State of West Bengal, AIR 1963 SC 1074, Supreme Court held that superimposed photographed of the deceased over the skeleton of human body was admissible to prove that the skeleton was that of the deceased.
Test Identification Parade
Test Identification Parade of the accused is provided under Section 54 of BNSS, 2023. This provision enables the police officer in charge of the police station to seek the court's permission to direct the person arrested for committing an offence to subject himself to identification by any person or persons in such a manner as the court thinks fit. The evidence of test identification parade is taken under Section 7 of Bhartiya Sakshya Adhiniyam.
Necessity and purpose
Such test is conducted to test the veracity of the witness and his capacity to identify the unknown persons. Test Identification parade is primarily meant for the investigation purposes. Identification parade tests the memory of the witnesses, in order for the proseuction to determine whether any or all of them can be cited as eyewitness to the crime.
Supreme Court in Ramanathan v. State of Tamil Nadu, AIR 1978 SC 1201, has hel that the purpose of test identification parade is to find out whether the accused is the perpetrator of the crime or not. If the name of the offender is not mentioned by the eye-witnesses then in such circumstances such evidence becomes more important.
In Ram Babu v. state of UP AIR 2010 SC 2143, Supreme Court held that purpose of test identification parade is to test credibility and trustworthiness of the evidence of the witness in Court. Supreme Court in Hare Kishan Singh v. State of Bihar, AIR 1988 SC 863, held where one of the witnesses failed to identify the accused at the identification parade, identification by him of the accused in the court is useless.
In Har Nath Singh v. State of M.P., AIR 1970 SC 1619 Supreme Court observed that TIP serves two purposes:
(i) To satisfy the investigation authorities that certain person not previously known to witness was involved in the office and
(ii) To furnish evidence to corroborate the testimony which the witness concerned tenders before the court.
Whether holding of TIP is essential?
Test identification parade is not necessary where all the witnesses state that they otherwise know accused persons and they are not strangers to them and they clearly identified them [State of U.P v. Sukhpal Singh AIR 2009 SC 1733, Dana Yadav v. State of Bihar, AIR 2002 SC 3325].
In R Shahji v. State of Kerala, AIR 2013 SC 651, Supreme Court held that where witnesses were acquainted with the accused and the incident was also widely covered by media, holding of test identification parade was not essential. In Surendra Narain v. State of M.P., AIR 1998 SC 3031, Supreme Court held that even if the accused demands, holding of test identification parade is not essential.
If the TIP is not conducted and the witnesses identify the accused for the first time before the court, evidence regarding identification does not become inadmissible and cannot be discarded on the ground of not being preceded by TIP when the court finds the same to be trustworthy.
Evidentiary value of TIP
The evidence of test identification parade is not substantial piece of evidence but only has a corroborative value. In Heera v. State of Rajasthan, AIR 2007 SC 2425, Supreme Court held that the identification parades belong to the stage of investigation. They do not constitute substantive evidence. In George v. State of kerala, AIR 1998 SC 1376, the court held that TIP corroborates the testimony of the witness and the identification of the accused.
In Chunthuram v. State of Chattisgarh, 2020 SCC OnLine Sc 883, Supreme Court held that when TIPs are conducted in presence of police then the resultant communications tantamount to statements made by the witnesses to a police officer in course of investigation and they fall within the bar of Section 162 CrPC [Now 181 of BNSS]. In Malkhan Singh v. M.P., 2003 9 SCC 137, Supreme Court held that identification parade is weak sort of evidence. It is not a substantive evidence. Failure to hold identification parade would not make inadmissible evidence of identification in court.
Delay in holding TIP
Efforts should be made to ensure that TIP is conducted as soon as possible so as to eliminate the possibility of fabrication of evidence, however, delay in holding TIP is not fatal if it is satisfactorily explained by the prosecution [Md Kalam v. State of Rajasthan, AIR 2008 SC 1831]. The Court may even base the conviction of the accused on the sole ground of such identification if there is no inordinate delay in holding such test identification and it is conducted with due care and caution.
Precaution and Procedure to be adopted
It is necessary to conduct test identification parae with proper precaution to rely upon such evidence. The following precautions must be taken while conducting such test:
1. It must be conducted in the supervision of Magistrate who shall ensure that the identification is conducted in proper manner.
2. No police officer shoul be present at the time when parade is conducted.
3. It must be conducted as soon as possible after the accused is arrested so that the memory of witnesses does not fade with time.
Procedure: Generally, the accused is lined up with other persons or dummies of same features. The ratio of dummies should be 1:4 or 1:6 per accused. Out of these the witnesses will have to identify the accused without any aid or support. If the test is conducted after taking due care and precaution, its reliability is increased and it can be used by investigating agency to establish the identity of the accused.
Principles of Test Identification Parade Summarised
Supreme Court in Rajesh v. State of Haryana, (2020)SCC OnLine SC 900 summarized the principles of test identification parade. The court held that the identification is course of a TIP is intended to lend assurance to the identity of the accused. The findings of guilt cannot be based purely on the refusal of the accused to undergo an identification parade. Supreme Court summarized the following principles:-
1. The purpose of conducting a TIP is that persons who claim to have seen the offender at the time of the occurence identify them from amongst the other individuals without tutoring or aid from any source.
2. Identification parades belong to the stage of the investigation of crime and there is no provision which compels the investigation agency to hold or confers a right on the accused to claim a TIP.
3. A TIP should ordinarily be conducted soon after the arrest of the accused, so as to preclude a possibility of the accused being shown to the witnesses before it is held.
4. As a rule of prudence, the court would, generally speaking, look for corroboration of the witness' identification of the accused in court, in the form of earlier identification proceedings. The rule of prudence is subject to the exception when the court considers it safe to rely upon the evidence of a particular witness without such, or other corroboration.
5. The weight that is attached to such identification is a matter to be determined by the court in the circumstances of that particular case.
Identificaiton by DNA
Supreme Court in Kathi David Raju v. State of A.P., (2019) 7 SCC 769 held that direction for identification of person by DNA test should be based on the satisfaction of police authorities on some material collected on basis of substantial investigation. DNA test cannot be requested or directed as a step towards roving or fishing inquiry. Further, in Sunil v. State of M.P (2017) 4 SCC 393, Supreme Court held that failure to conduct DNA tests of samples taken from the accused or to prove the DNA report would not necessarily result in failure of prosecution case. Conviction may still be possible based on the remaining evidences.
Identification by voice
Supreme Court in Ritesh Sinha v. State of U.P., (2019) 8 SCC 1 held that Judicial Magistrate can direct an accused to provide his voice sample for investigation even without his consent.
Conclusion
Sections 4 to 7 of the Bhartiya Sakshya Adhiniyam (BSA) collectively form a foundational framework for admitting a wide array of facts that, while not the central "fact in issue" itself, are intrinsically connected to it. These provisions operationalize the common law doctrine of **res gestae** ("things done"), allowing the court to view a transaction in its complete context rather than as an isolated event.
The core principle uniting these sections is contextual relevance. Section 4 is the direct statutory embodiment of *res gestae*, making facts relevant if they form part of the "same transaction," irrespective of time and space, provided they exhibit spontaneity and immediacy that rules out concoction. This section serves as a crucial exception to the rule against hearsay evidence, admitting statements and acts that are so interwoven with the main event that they are considered part of the event itself.
Building upon this, Section 5 broadens the scope by admitting facts that constitute the occasion, cause, effect, opportunity, or state of things surrounding the facts in issue. These facts help the court understand the background and circumstances that made the event possible or explain its consequences.
Section 6 delves into the mental and behavioral elements of a case. It makes relevant facts showing motive, preparation, and the conduct of parties and accused persons. While motive alone is not conclusive, it becomes particularly significant in cases based on circumstantial evidence. The conduct of an accused, including statements that influence or explain their actions, is highly probative, as people's behavior is presumed to be influenced by their involvement in events.
Finally, Section 7 acts as a supporting provision, admitting facts necessary to explain or introduce facts in issue or relevant facts. This includes evidence that may seem insignificant in isolation but becomes crucial when connected to other facts, such as the results of a Test Identification Parade (TIP), which, while not substantive evidence, serves to corroborate a witness's testimony in court regarding the identity of an accused.
In essence, these sections work in harmony to reject a fragmented view of evidence. They empower the judiciary to consider the entire narrative of a case—the events leading up to it, the accompanying words and deeds, the underlying motives, the subsequent conduct, and all explanatory circumstances. This holistic approach, guided by judicial precedents that emphasize spontaneity, contemporaneity, and a close nexus to the main transaction, ensures that the fact-finding process is both comprehensive and grounded in the natural continuity of human events, thereby leading to a more just and accurate determination of the truth.
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