1. Yes email communication can be submitted as evidence without the 65B certificate. 2. whether workman or not is a primary question and is sine qua non for the court to decide in order to grant any relief. it is inherent in the second question but I would like to believe that it is something which the court will go into at the very stage of addressing the maintainability of the case. under cpc production of documents is dealt in some order and an application to that effect will suffice.