In a significant ruling, the Supreme Court underscored the need for trial courts to exercise extreme caution when accepting dock identification of strangers by witnesses without a prior Test Identification Parade (TIP).
The Court highlighted that without a TIP, the identification of an accused who is a stranger to the witness cannot be deemed reliable evidence for conviction. This safeguard is vital to prevent wrongful convictions based on questionable dock identifications.
The justices noted, “In cases where the accused is unknown to the witness and there has been no TIP, trial courts should be very cautious while accepting the dock identification by such a witness.”
The ruling came as the Court overturned a conviction due to the absence of a TIP, emphasizing the persistent doubts surrounding the accused’s identity. The bench pointed out that without a TIP, the dock identification remains suspect, thus failing to meet the standard of proof beyond a reasonable doubt.
Drawing from a previous case, the Court reiterated that corroboration through a TIP lends credibility to witness testimony. However, in the present case, the lack of such corroboration rendered the witness’s court identification insufficient for a conviction.
The appeal was allowed, with the Court ruling in favor of the appellant due to the prosecution’s failure to conclusively prove the accused’s identity.
