LEADING OF EVIDENCE IN A COURT- POINTS TO REMEMBER

1. Always remember that the entire Evidence Ordinance revolves around section 5.
2. In terms of Thai section evidence can only be led of a fact in issue or a relevant fact. 
3. In Civil cases Facts in issue will be those issues framed under Section 146 of the CPC.
4. In criminal actions the facts in issue will be the ingredients of the offence and the ingredients of the defence.
5. Read 62 NLR 112 
6. Relevancy is discussed under Sections 6 to 55 of the Evidence Ordinance.
7. Be mindful of Section 118 of the Ordinance regarding competency of witnesses. 
8. Analyze the educational Background of the witness.
9. See whether he has a personal interest towards the victim or the accused. 
10.  Analyze his confidence.
11. Make him feel comfortable.
12. In questioning use his language.
13. Do not use high flown language.
14. No technical terms unless the witness is an expert. 
15. In such case read the technical area fully.
16. Use simple language.
17. Before a production of a thing or a document you must get the witness to describe it and the circumstances that the witness saw it. 
18. Get him to identify the accused in a criminal case if you are for the prosecution. 
19. Be mindful of the ingredients of the offence and the defence. 
20. Be mindful of Men's Rea and Actus Reus in a criminal case. 
21. In a Civil case be mindful of the elements of the relevant substantive Law.  
22. Read Sections 101 to 105 of the Evidence Ordinance. 
23. Never shout at your own witness. 
24. Visualize the defence in advance and cover the loopholes in your case wherever possible without waiting for that to come out in cross examination. 
25. Write down every question that you may Ave to ask. 
26. Develop a structure based on what you expect to take out from the witness. 
27. In the case of documentary evidence be mindful of Sections 65 to 69 of the Evidence Ordinance. 
28. In the case of Computer Evidence be mindful of the pro is ions of Act No 14 of 1995.