Section 48(1) of the Evidence Act 1995 prescribes the means of adducing evidence of the contents of documents but does not dispense with the requirement to prove that a document is what it purports to be. Documents produced by a third party in response to a subpoena are not self-authenticating; a party seeking to tender such documents as business records under s 69 must adduce evidence establishing their authenticity, such as testimony from a person who compiled the document, found it among business records, or can recognise it as a record of the business. The mere fact of production in response to a subpoena is insufficient.
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