Section 65B was written to deal with a specific worry: electronic records can be altered, corrupted, or manipulated more easily than paper documents, so before a printout, CD, or other electronic record is let in as evidence, the law wants some certification of how it was produced and that it accurately reflects the original data. Whether courts have consistently insisted on that certification is exactly what the four statements in this question are testing.
Statement A is accurate: the Section 65B(4) certificate is treated as a condition precedent, meaning without it the electronic record simply cannot be admitted, not merely that its weight is reduced. Statement B is also accurate, describing P.V. Anvar v. P.K. Basheer's holding that Section 65B is a complete code, meaning parties cannot sidestep its certificate requirement by relying on the general secondary evidence provisions instead. Statement D is accurate too, since Arjun Panditrao Khotkar is indeed the most recent major word on the subject, reaffirming the certificate requirement in 2020 while easing some practical difficulties around obtaining it.
Statement C is where the problem lies. It is true that Navjot Sandhu, decided in 2005, allowed printouts and CDs to be treated as admissible without insisting on the Section 65B certificate. But the law does not stay frozen at 2005; P.V. Anvar in 2014 expressly disapproved of that lenient approach and restored the certificate as mandatory. Describing Navjot Sandhu's holding as though it still represents good law, without noting it was overruled, makes statement C the inaccurate one among the four.
So the statement that is not true is the one describing Navjot Sandhu as permitting unauthenticated electronic records, since that position no longer holds after P.V. Anvar.