Vinod @ Nasmulla vs State Of Chhattisgarh 2025 INSC 220 - Test Identification Parade - Criminal Investigation

Indian Evidence Act, 1872 - Section 9 -A test identification parade is not substantive evidence in a criminal prosecution but is only corroborative evidence. The purpose of holding a test identification parade during the stage of investigation is, firstly, to ensure that the investigating agency is proceeding in the right direction where the accused is unknown and, secondly, to serve as a corroborative piece of evidence when the witness identifies the accused during trial. The evidence of identification merely corroborates and strengthens the oral testimony in court which alone is the primary and substantive evidence as to identity - Evidentiary value of the TIP discussed - Referred to In Rameshwar Singh v. State of Jammu and Kashmir (1971) 2 SCC 715 - if the witness who identified a person or an article in the TIP is not examined during trial, the TIP report which may be useful to corroborate or contradict him would lose its evidentiary value for the purposes of identification- Once the person who identifies the accused during the TIP is not produced as a witness during trial, the TIP is of no use to sustain an identification by some other witness. (Para 14)

Criminal Investigation - It is not uncommon for the police to be under pressure to quickly resolve a case having implications on public order and therefore, look for soft targets. (Para 22)