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Test Identification Parade An Evaluation Through Judicial Pronouncements, Its Utility And Veracity

This is a technique primarily used in criminal cases to identify the accused in court. The idea of this procedure is to see if witnesses can identify the accused among various people. The Indian Evidence Act, of 1872 deals, inter alia, with the admissibility and inadmissibility of evidence in court, including the examination of witnesses and the evidentiary value of documents submitted to the Court of First Instance1.

Test identification is useful to law enforcement, not as evidence in court. Judges are off duty in test identification parade arrangements, largely like police, but if an identifier misidentifies her, the whole investigation could well be sidetracked and the investigation never resolved in an identification parade.

A disadvantage to testing is that this is a parade recommendation to officers that specific procedures must be clearly explained to investigators and that police should not be involved during inspection identification parades. Governments should increase their capacity to conduct test identification parades. It's carried out in its usual location, but the windows should be tinted so that these key people can see what's going on instead of the judges, etc 2.

The Test Identification Parade is governed by Section 540-A of the Criminal Procedure Code, 1973 and Section 9 of the Indian Evidence Act, 1872. Nothing in the Code of Criminal Procedure authorizes investigative authorities to organize parades or to give defendants the right to demand parades. Sec 162 of CrPC effectively regulates these parades. Also, in the case of Rajesh and Anr v. Haryana 3, the court ruled that refusal to participate in the process identification parade could not be grounds for conviction.

History Of Tip

Until 2005, there were no specific provisions in the Evidence Law or the Code of Criminal Procedure for identifying defendants. A 2005 amendment to the CRPC introduced a new Section 54 that required testing for the identification ofan arrested person. A test identification parade should be held as soon as possible with the necessary protections and precautions. However, test identification is not required if the defendant has been seen several times at different times and places by witnesses4.

For hundreds of years, India has had a lively identity parade. This greatly contributes to the speeding up of investigations and early resolution of incidents. Test identification parades can be conducted by police officers,magistrates, or individuals. However, it can only retain evidential value under section 80 of the Evidence Act 1872 if it is done by the magistrate himself and the court presumes its credibility5.

If conducted by a T.I.P. Police Officer/Judge of the Peace, witnesses identifying the accused may be questioned duringthe trial. Up. Generally done in Dacoity, Riots, and Heinous Crimes. Identification is an act of the mind that takes advantage of the opportunity to see the victim. Observation should be good because older men cannot find the accusedas easily as young men can easily find the accused.

Test Of Credibility

The reliability of identification by identifiers in terms of the test identification parade varies from situation to situation and from case to case. The timing, severity of the incident, the actions perpetrated by the offender, and the traumatic experience at the time such an event occurred, record permanent scars on the victim's mind and identifiers, making it clear who committed the act. remember to the time, place, and number of people involved all play a part. If this took place during the day in an open area, the victim may have had enough light to clearly identify the person, including whether the person had their face covered.

Identification is not considered adequate if the individual covers the face or other body parts, as the classifier cannot identify the individual. We believe the court will decide whether to hold the parade depending on the circumstances of the case. In the case of the Raman Bhai Narayan Bhai Patel v. AIR, Gujarat (1999) SCC6 case, the attack took place in broad daylight, and the courts ruled that if the crime was committed in broad daylight, the witnesses would easily remember and identify the person. said to be identifiable. A conviction was committed based on identification by the Test Identification Parade.

In the case of Dana Yadav v. State of Bihar AIR (2002) SCC7, the Supreme Court of India held that the sole purposeof a TIP was to corroborate the court and identify the defendant and should be identified in the court. I made a clear decision. Generally, not used if the suspect's name is not mentioned before the initial investigation or police.

In Anil Kumar vs. U.P. State. AIR (2003) SCC8, the Hon'ble Supreme Court of India held that retention of TIP was not mandatory and the defendant had no right to assert the retention of her TIP. The delay in arresting TIP is not fatal, but efforts should be made to arrest the defendant as quickly as possible so as not to expose witnesses to the defendant's pranks.

The credibility of the identification done by the identifier a regard to the test identification parade, the credibility varies from circumstance to circumstance and case to case. The time, severity of the incident acts done by the criminal, such traumatic experiences when done, it registers a permanent scar in the mind of the victim or identifier, that they remember the person who did the act clearly.

Even time of the day when the act was committed, place of occurrence, no of people involved, everything comes in to play. If done during the day time in an open place, it can be that there was enough lighting for the victim to clearly identify the person, similarly, whether the persons covered their faces, etc all comes into consideration.

Conditions For The Identification Parade

  • It is for the satisfaction of the prosecution that investigation was moving in the right direction 9.
  • It is to test the strength and trustworthiness of the evidence 10.
  • It acts as corroborative evidence 11.
  • It is to test the ability of the witness to recognize the suspect 12.
  • It is to corroborate the substantive evidence in the process of cross- examination of the witness 13.
  • Police held identification parade to enable witnesses to identified the properties which are the subject matter of offence and to identify the person 14.
  • It is to check the veracity of the witnesses who claim to see the accused i.e. to test the memory of witnesses and they can be considered as an eye-witness 15.

Constitutionality Of Test Identification Parade

A magistrate's order requiring a person to attend test identification parade does not violate his fundamental right under Article 20(3) of the Constitution. The identification of the accused at TIP by someone not accused's own act. His mere attendance or exhibition of body cannot be regarded as furnishing any positive volitional evidentiary act16.

Article 20(3)of the Constitution of India is also not violated by compelling an accused to stand up and show his face for the purpose of identification. It does not amount to giving of testimony as to the final facts. He can also be ordered to disclose any scar or mark on his body for the purpose of identification17.

During the course of investigation, witnesses may say that they will identify the culprits, if they were shown to them, they will identify the properties, if the properties are produced before them. Therefore, the necessity of holding of testof identification parade during the investigation is necessary to test the memory and veracity of the witness does arise.

Test of identification parade is integral part of investigation. In regard to the admissibility of test of identification parade, they are relevant by virtue of Section 9 of Indian Evidence Act. Hon'ble Supreme Court of India was pleased toopine in Budhasen V. State of A.P.18 that the T.I.P. has two fold objectives:
  1. Establishing identity of the accused and corroborating the identity of witness before trial.
  2. TIP also tests the memory of the witnesses.
Generally speaking, accused cannot demand TIP as a matter of right but if demanded, never turn down such demand. If the prosecution turns down the request of the accused for identification, it runs the risk of the veracity of the eye witnesses being challenged on that ground, as held in Lajjaram v. State, 195519.

Identification evidence is highly persuasive to triers of fact. There is an intuitive sense that when someone witnesses a stranger commit a crime, he or she should be able to remember that face. After all, we see and remember faces every day. However, more than four decades of research has revealed this assumption to be flawed, there is clear evidence that witnesses often struggle with accurately recognizing the face of a stranger perpetrator20. Indeed, although eyewitness testimony can be an important and valuable form of evidence, eyewitness identification errors are a leading cause of wrongful convictions in many countries21.

The evidence which requires particular attention is identification evidence, which resembles confession evidence in being, at the same time, both extremely compelling and potentially unreliable. Witnesses are frequently required to identify persons whom they have only seen fleetingly and often in confused circumstances. The identification of the perpetrator is often the only issue that needs to be determined in a criminal trial22.

Mistaken identity may often occur in good faith, but the effects can be extremely serious for the defendant and, for this reason, there is an obvious need for caution in relation to such evidence. As with evidence of lies by the defendant, the hazards associated with identification evidence are addressed by means of a Judge's direction, but there are additional safeguards which apply where the identification has been made by means of a formal procedure conducted under police supervision, such as an identification parade23.

Analysis Of Supreme Court Judgment

  1. Kedar Singh Vs. State Of Bihar Air (1999) Scc 24

    In this case, the Hon'ble Supreme Court ruled that because there is never complete darkness, individuals could be identified even at night in complete darkness. There may be other ways to identify individuals. For example, body type, clothing, gait, voice, etc. Therefore, if a defendant hides his face, he can be identified by his gait, tattoos, watch, voice,clothing, shoes, and body type. This type of evidence is called indirect/circumstantial evidence.
  2. Heera Vs. State Of Rajasthan Air (2007) Scc 25

    In this case, all major judgments related to test identification parade are referred by the court in order to give the decision for the case. It was that 7-armed people came and hit members working at a petrol station at 2 am in the morning, threw stones due to which glass broke, and due to the stone, they woke up. They beat the people with lathisand robbed 12000 rupees from them, even when the neighbour came to see what was happening, he was also attacked with lathis.

    Recovery was made of items as per section 27 of the Evidence Act,1872 etc. was admissible, Test identification parade was conducted by a civil judge and magistrate, the necessary terms of conducting a parade was told by the court, the court said something like test identification parade is only tested and has no place for provision in court or evidence. Accused were identified, all requisite procedure was adhered to and the appeal was dismissed as there wasnothing wrong in the judgement of the lower court, and identification parade is right in the case.
  3. Raju Manjhi Vs. State Of Bihar 26

    Judgment in this landmark case was handed down by Judge N. V. Ramana and Hon'ble MR. Judge Mohan M. Shantanagodar. The lower court where the appeal was filed was the Patna High Court. In fact, one night a year,nearly 10 to 12 people between the ages of 20 and 26 broke into Kamdeosin's house, stole things, and complaints were filed, leading to police investigations. The injured were taken to hospital after the location of their injuries was determined.

    A number of witnesses were questioned, and the lower court claimed it followed the cinematic nature of the story and continued its investigation. No witness identifications were made during the test identification parade, but this does not mean that the accusations against the defendants are false. and not for any other purpose. The identification parade moves into the investigation phase.
  4. Habib Vs. State Of Bihar 27

    In this case, the Hon'ble Supreme Court is T.I.P.'s weak proof. As a rule of caution, if the only evidence against the defendant is identification by a witness, this should not be considered sufficient to justify a conviction.
  5. Amit Singh Bhikam Singh Vs. State Of Maharashtra 28

    In this case the Hon'ble Supreme Court held that T.I.P. doesn't constitute Evidence but can only be used for corroboration of statement in the court. The Evidentiary value of T.I.P. conducted at the Investigation stage, cannot be considered as important Substantial Evidence and also conviction can't be based/founded on the sole reason of T.I.P.,the witness Identification is required in the court in order to convict.

Facets Of Test Identification Parade

  1. Evidence of sniffer dogs:
    In Abdul Razzak v. State of Maharashtra 29, it was held by the Supreme Court that the evidence of dog tracking is admissible but ordinarily, is not of much weight. The possibly of misunderstanding between the dog and its master is close to its heels. The possibility of misrepresenting or wrong inference from the behaviour of dogs cannot be ruled out.
  2. Identification by finger print:
    The accepted conclusion of science is that several fixed and typical variety of ridges on fingertips are clearly distinguishable and that the chance of two individuals bearing the same combinationof such marks are so small as to be negligible. Hence identity of finger marks is the strongest evidence of the identity of person and such evidence is admissible.
  3. Joint Test Identification Parade (TIP):
    In Sheikh Sintha Madhar alias Jaffar alias Sintha v. State 30, it was held that there is no invariable rule that that the two accused persons cannot be made part of the same test identification parade. Joint Test Identification Parade does in no manner affects the validity of Test Identification Parade.

    The purpose of holding a TIP is just to ensure that whether the investigation is going on the right track ornot and is merely a corroborative evidence. If the accused is already known to the witness, Test Identification Parade does not hold much value and it is the identification in the court which is of utmost importance.

Evidentiary Value

The probative value of the test identification parade is absolute, the use of the test identification parade as mandatory evidence is outdated, and the test identification parade has only a corroborative value as evidence.

As explained more detailed manner in the cases section of the paper, in the case of State of Himachal Pradesh vs Lekhraj31 it was mentioned that "Test identification is considered a safe principle of judiciousness for authentication of the sworn testimony of various evidentiary value people appearing as witnesses in court with regards to the character of theaccused. There may anyway be special cases to this general principle when for instance the court is intrigued by a specific observer on whose testimony it can securely depend without such or other corroboration32.

A parade taken at an inquest is not considered material substantive evidence, a conviction may be based on the sole grounds of a test identification parade, and a conviction requires the identification of witnesses in court. Even if the same people who came forward in the parade came forward in court, the added value would be the same.

Test identification is usually required when the suspect's identity is in jeopardy. This is necessary for situations wherethe victim has never met the suspect before the incident. Usually, when a crime is inflicted on a victim, the victim can see the offender and later identify the offender using various mechanisms such as build, height, etc. If the investigator can identify the person, a test identification parade will be held in such cases. The parade should be held as close aspossible, including in front of the Magistrate33.

International Context

  1. Pakistan:

    An identification parade is an investigative tool used by police to identify criminals when there are witnesses. It is to provide the suspect of a crime with a person (dummy) that matches their description. Witnesses are then required to identify the suspect from the individual. Indeed, neither the Criminal Procedure Code of 1898 nor his Qanun- e-Shahadat Ordinance of 1984 provides any instructions or details on how to conduct an identity test. Article 22 of the Qanun-e-Shahadat Regulations 1984, which is commonly referred to for identifying tests,refers only to their relevance and does not provide procedures.

    Specific guidelines to be followed when conducting an identification parade are set out in the Rules and Orders of the Lahore High Court, Volume 3, Chapter 11, Part C.392. The details of the identification parade procedure will be recorded in the case file and the certification of the identification parade procedure will be attached to the courtrecords34.
  2. Malaysia:

    The entire process of identifying the parade is detailed in Maral's Criminal Case, 2013. The identification parade should be conducted as soon as possible and all available witnesses should be invited to the first parade. Good practice in England is that the parade should be conducted by the officer on duty in charge of the police station, not by the officer in charge of the investigation. Witnesses must be allowed to see the accuseduntil all preparations have been made and they have gone to find the accused, and must not be pre-corroborated by photographs or oral or written descriptions.

    The line-up of persons in the identification parade should be of similar character. It is a settled practise for the police to parade persons of similar height, built and ages and the same nationality of the suspect of to identify the suspect (R v. Dickman35, 1910; R v. Bundy, R 272). When the accused had brown eyes and the person with such brown eyes had not been mixed in the parade the evidence of the identification had to be rejected (Chander v. S A36, 1973). When theaccused is a bearded man, with a tape on his neck waited with the witnesses outside the magistrate's court and among five other persons in the parade none was similarly bearded the evidence hadto be rejected (Yeshwant v. S A, 1973).
  3. United Kingdom:

    The Court of Appeal in R v Turnbull 37 prescribed rules to guide Judges faced with contested visual identification evidence. The guidelines are also applicable in cases of voice recognition or identification. The guidelines are aimed at assessing the quality of the identification. Guidelines are as follows:
    1. When a case depends wholly or substantially on the correctness of one or more identifications of the accused which the defence claims are mistaken, the judge should warn the jury of the special need for caution before convicting the accused in reliance on the identification. In particular he should instruct them of the reason for the need for this warning and make some reference to the possibility that a mistaken witness can be a convincing witness and that a number of witnesses can all be mistaken. There is no prescribed form of words.
    2. The judge should direct the jury to examine closely the circumstances in which the identification by each witness came to be made.
  4. South Africa:

    In S v Hlalikaya and others 38 is an example of a case where a suspect refused to cooperate in the holding of the usual type of identification parade. No adverse inference was drawn from non-cooperation, but the court did receive in evidence the results of the so-called photographic identification parade, which was held by police in lieu of the ordinary parade. The court concluded that the accused did not have a constitutional right to legal representation at a photo identification parade and accordingly, whether or not they were advised that their legal representative could be present at the parade, was immaterial. The court further stated that if an accused were entitled to legal representation at a photo identification parade, then the question.

In S v Thapedi 39 , it was held that the accused may ask for a legal representative to assist him during the conduct of an identity parade, although the failure to provide legal assistance at that stage does not per se amount to parade evidence being obtained unconstitutionally.

Current Scenario:
  • Evidence Of TIP Inadmissible If Suspects Were Shown To Witnesses Before Identification:
    Was held by Supreme Court40: Even a TIP conducted in the presence of a police officer is inadmissible, the bench of Justices BR Gavai and PS Narasimha observed, In this case, the High Court of Kerala upheld the conviction of the accused under Sections 143, 147, 148 of the Indian Penal Code, and Sections 3(2)(e) of Prevention of Damages to Public Property Act, 1984, read with Section 149 of the IPC.

    The conviction was mostly based on the evidence of TIP. The accused were allegedly involved in a violent protest against the Kerala Government decision to delink pre degree courses from colleges and start plus two courses at the school level. The protesters had become violent and caused damage to as many as 81 buses belonging to the Kerala State Road Transport Corporation leading to the death of a bus conductor with KSRTC.
  • Test Identification Parade Can't Be Permitted After Lapse Of Several Years:
    Held by Karnataka HC41: The Karnataka High Court has made it clear that Test Identification Parade is to ascertain the identity of accused persons and cannot be conducted after lapse of several years, as there is risk of the witnesses having lost proper memory. It thus set aside an order passed by the trial court permitting the investigating officer to conduct a TIP of an accused after 11 years of filing.
  • Rajasthan HC Issues Guidelines For Test Identification Parade:
    In POCSO Cases, Orders Lower Courts For Immediate Implementation in POCSO Trials42: In a significant ruling, the Rajasthan High Court, Jaipur has issued guidelines for Test Identification Parade (TIP) in POCSO Cases. The court ruled that special Judges of POCSO Act cases and all the District & Sessions Judges of the State shall ensure the immediate implementation of this order with all the judicial officers and in all the respective courts.
  • Not Prudent To Convict An Accused Solely On Basis Of Identification For The First Time In Court Without Test Identification Parade: Supreme Court43: Clarifying an important aspect regarding Test Identification Parade (TIP), the Supreme Court on Monday held that it would not be prudent to convict an accused solely on the basis of their identification for the first time in court.

    A Division Bench comprising of Justices MR Shah and Aniruddha Bose held that:
    "Even applying the law laid down by this Court in the aforesaid decisions. It is a fundamental principle of criminal justice that the defendant's guilt must be proven beyond a reasonable doubt. Another common thread running through the criminal justice network is that he has two possible views on the evidence presented in the case, that the accused is guilty and that theaccused is innocent the view which is favourable to the accused should be adopted. Kali Ram Vs. State of Himachal Pradesh 44.
  • Absence of Test Identification Parade may not be ipso facto sufficient to discard testimony of witness who has identified accused in Court held by SC45: While acquitting the appellants of the offences of allegedly transporting huge quantity of spirit without license, on ground of doubtful prosecution case, the Supreme Court has stated that that Test Identification Parade is a part of investigation and it is not substantive evidence.

    The question of holding Test Identification Parade arises when the accused is not known to the witness earlier and the identification by a witness of the accused in the Court who has for the first time seen the accused in the incident of offence is a weak piece of evidence especially when there is a large time gap between the date of the incident and the date of recording of his evidence, added the Court.
  • Godra Train Burning case 46:
    In this case, comprising Justices P S Narasimha and J B Pardiwala, that the first convict who had challenged the sentence was identified in the Test Identification Parade. "He was pelting stones with the motive of not letting passengers come out. The role of the second convict is also clear," he submitted.

Salient Features:
  1. Video Identification:
    In the paper-based world, law assumes a process which is mutually understood and observed by all the parties. Almost without thinking, a four-part process takes place, involving acquisition, identification, evaluation and admission. When we try to apply this process to digital evidence, we see that we have a new set ofproblems 47.

    Nowadays, in most countries live parades have now been largely replaced by video parades, an innovation that has been made possible by the development of sophisticated computer systems used to compile video images from a standardised database of moving video clips48. In Britain, two different IT systems are in widespread use toprovide video identification: VIPER (Video Identification Parade Electronic Recording) and PROMAT (Profile Matching). Each system has its own database of images.
  2. Forensic Identification:
    When false eyewitness identifications and wrongful convictions are discovered, they are usually exposed through post-conviction DNA testing. However, in the vast majority of criminal cases, DNA evidence has either been destroyed49 or, more commonly, never even existed in the first place50 This, of course, poses a significant problem for the innocent defendant convicted based primarily on eyewitness evidence.
  3. Voice Identification:
    Voice itself may be an issue in a criminal case, inasmuch as it may itself be a personal characteristic upon which an identification of a criminal depends. It thus seems appropriate that we have in recent years seen the coining of the word ear-witness for the witness who heard, rather than saw51 something.
  4. Previous Identification:
    Where, in criminal proceedings, a witness gives evidence identifying the accused as the person who committed the offence charged, evidence of a previous identification of the accused by that witness may be given, either by the witness himself or by any other person who witnessed the previous identification 52 for example a police officer who conducted a formal identification procedure such as a video identification or an identification parade, as evidence of consistency 53.
In R v. Christie 54 is the leading authority that if witnesses testify that they have identified the accused as the perpetrator, they can also present evidence that they have previously identified the accused. Basically, prioridentification can violate her three rules of exclusion: the hearsay rule, the rule against selfish remarks, and the ruleagainst non-expert opinion evidence.

Considering the above guidelines and the meticulousness and diligence required to ensure the transparency and accuracy of the identification process, it is the personal opinion of the authors that the results of the test identification parade should be regarded as adequate and acceptable evidence in comparison. Before a trial court if you do not follow any of the above procedures and you are able to directions to the witness. Furthermore, in contrast to a parade surrounded by groups of similarly positioned people, it is the only person or group that occupies the box designated for the defendant in court, thus identifying the defendant in court. It's pretty easy to do.

It should also be noted that the test identification parade is held by investigative authorities as soon as possible after the suspect's arrest and before the suspect is taken to the court of first instance. In the court of first instance, the defendant loses the meaning of subsequent audit results.

Delay in holding the first identification in court affect the reliability of the evidence. The purpose of test identification is to test and strengthen the trustworthiness of the evidence regarding identification of the accused in the court. Hence, the absence of test identification parade would not always be detrimental for the prosecution but it depends on the facts and circumstances of the case.

  2. system/
  3. (2019) 1648 SC 36.
  6. (2003) 2 GLR 1522
  7. (2002) 7 SCC 295 : 2002 SCC (Cri) 1698
  8. 2003(2) Supreme 319
  9. Ayyub v. State of UP, AIR 2002 SC 1192.
  10. Malkhan Singh v. State of MP, AIR 2003 SC 2669.
  11. Akbar Nazir Ahmad v. State of Maharastra, 2004 Bom CR (Cri) 396 Bom.
  12. Dana Yadav v. State of Bihar, AIR 2002 SC 3325.
  13. Harnath v. S., 1970 SC 1619.
  14. Visveswaran v. State, AIR 2003 SC 2471.
  15. Suresh Ganpat Munde v. State Of Maharastra, 2000 (5) Bom CR 40.
  16. AIR 1961 Cal 531, 1961 CriLJ 462
  18. 1970 AIR 1321, 1971 SCR (1) 564
  19. AIR 1955 All 671, 1955 CriLJ 1547
  20. Gary L. Wells & Nancy K. Steblay, "Eyewitness Identification Reforms: Are Suggestiveness -Induced Hits and Guesses True Hits?",Journal of Applied Psychology, 799, 835�844 (2011).
  21. Heather L. Price, "Judicial Discussion of Eyewitness Identification Evidence" 49 CJBS 209�220 (2017).
  22. S v. Mdlongwa, 2010 (2) SACR 419 (SCA).
  23. Chris Taylor, Law Express Evidence, (Pearson, Chennai, 4th Edn., 2009).
  24. 1962 AIR 955, 1962 SCR Supl. (2) 769
  25. 2007 ACJ 213, 2007 (4) ARBLR 417 Raj, 2008 (1) CTLJ 97 Raj, RLW 2007 (4) Raj 3232
  26. AIR (2018) SCC
  27. AIR (1972) SCC
  28. AIR (2007) SCC
  29. (1967) 72 Bom LR 646 (SC)
  30. AIR 2016 SC 1844 p. 1848
  31. Cr. A No.363 of 1995
  32. Cr. Appeal No. 381 of 2011. In High Court of Himachal Pradesh, Quoted by Justice Tarlok Singh Chauhan and Justice Chander BhusanBarowalia.
  33. Biray Singh vs. State, 1953 Crl.L.J., 1817 (Allahabad)
  35. [2017] HCA 24; 261 CLR 601; 91 ALJR 686; 344 ALR 474; 264 A Crim R 577
  36. AIR 1966 P H 93, 1966 CriLJ 292
  37. [1977] QB 224
  38. 1997 (1) SACR 613 (SECLD),
  39. 2002 (1) SACR 598 (T)
  40. Gireesan Nair & Ors. Etc. Versus state of Kerala, Criminal Appeal nos. 1864 - 1865 of 2010
  41. K Umesh Shetty v. State of Karnataka, CRIMINAL APPEAL NO.118 OF 2021
  42. Suresh S/o Late Shri Pema Ji v. State Of Rajasthan, 2021
  43. Amrik Singh vs State of Punjab, 2022 (SC) 582
  44. (1973) 2 SCC 808
  45. Jayan And Anr v. State Of Kerala, CRIMINAL APPEAL NO. OF 2021
  46. Criminal appellate jurisdiction SLP Crl d no. 34207/2018
  47. Swati Mehta, "Cyber Forensics and Admissibility of Digital Evidence" (2011) 5 SCC J-54.
  48. Amina Memon, "A Field Evaluation of the VIPER System: a New Technique for Eliciting Eyewitness Identification Evidence" 17Psychology Crime & Law 711 (2011).
  49. Cynthia E. Jones, "The Right Remedy for the Wrongly Convicted: Judicial Sanctions for Destruction of DNA Evidence" 77 Fordham L. Rev. 2893 (2009). (Discussing how poor handling of evidence has resulted in premature destruction in thousands of cases, including in States in which laws have been enacted mandating evidence preservation.).
  50. Barry Scheck, "Closing Remarks to Symposium, Thinking Outside the Box: Proposals for Change" 23 Cardozo L. Rev. 899 (2002).
  51. Ray Bull, "Earwitness Testimony" 39 Med. Sci. Law 120-127 (1999).
  52. R v. Osbourne and R v. Virtue, [1973] QB 678, CA. 295 (See Ch 10).
  53. R v. Burke and Kelly, (1847) 2 Cox CC.
  54. [1914] AC 545.

Award Winning Article Is Written By: Mr.Abhishek Kumar - LLB 3rd Year Ajeenkya Dy Patil University
Awarded certificate of Excellence
Authentication No: AP347417860969-18-0423

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