The Supreme Court directed the Registry to accept only colour photographs with distance details and conceptual plans, strengthening evidentiary clarity in future filings.

Supreme Court issued an important procedural direction to improve the clarity of evidence placed before it, instructing its Registry not to approve paper-books for listing if they contain black-and-white photographs.
The Court has made it mandatory that all photographs submitted must be in colour, must mention distance dimensions, and must be accompanied by a conceptual plan to ensure accuracy and better understanding during hearings.
This directive arose during the hearing of a Special Leave Petition linked to a final judgment and order from March 15, 2024, issued by the High Court of Bombay at Goa concerning Writ Petition No. 820 of 2023.
Recognizing the need for clear visual materials in judicial records, the Bench, which included Justice Surya Kant, Justice S.V.N. Bhatti, and Justice Joymalya Bagchi, laid down strict guidelines for the Registry regarding photographic evidence.
The Court explicitly stated,
“The Registry is directed not to clear any paper-book for listing where the photographs appended are black-and-white.”
The Supreme Court established specific requirements for Advocates-on-Record (AORs) when submitting visual materials.

The Bench directed that the following guidelines be disseminated among all AORs:
- Coloured Photographs: All photographs included in the paper-book must be in color.
- Distance Dimensions: The photographs should have distance dimensions to provide spatial context.
- Conceptual Plan: Each photograph must be supported by a conceptual plan.
The Court cautioned that failure to comply with these directives would lead to the rejection of the material.
It declared,
“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.”
In light of the ongoing practice of electronic filing, the Bench clarified that digital submissions alone are inadequate for coloured photographs.
It 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 case is scheduled for further hearing on January 9, 2026.
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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 appered for the For Petitioners.
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) appeared for the For Respondents.
Case Title: Dinamati Gomes & Arn v. State of Goa & Ors
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