I am sorry, but the case information you provided is incomplete and not a real case. "Section 32(1) in The Indian Evidence Act, 1872" is a section within a statute, not a case. Additionally, "Union of India - Subsection" is not a valid court. A real case would involve specific parties (plaintiff/petitioner and defendant/respondent) and a judgment delivered by a specific court.

To provide a useful summary, I need the actual case name (e.g., X v. Y) and the court that decided it (e.g., Supreme Court of India, High Court of Delhi). Please provide a complete case citation or a more detailed description of a specific case involving Section 32(1) of the Indian Evidence Act.