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Daya Singh v. State of Haryana — Test Identification Parade corroborating eyewitness identification

Part of the Forensic Docket on Legal Desire Forensics — a conviction confirmed through final appeal, kept here as a method-of-crime record.

The facts

The appellant was convicted under Sections 302 and 307 of the Penal Code and Sections 3 and 5 of the Terrorist and Disruptive Activities (Prevention) Act, 1987.

Two eyewitnesses identified the appellant during trial, even though certain other eyewitnesses were unable to identify him, and this in-court identification was corroborated by an earlier Test Identification Parade.

The Supreme Court restated the settled evidentiary principle that the purpose of a TIP is to provide corroboration to a witness’s identification given in court, so that where the substantive evidence of a witness in court is itself found to be reliable, a TIP mainly serves to reinforce rather than substitute for that testimony.

On this basis, the conviction was held sustainable and the appeal was dismissed.

Status: conviction upheld through final appeal.

Why this belongs in the Forensic Docket: A Test Identification Parade is corroborative, not a precondition — when the eyewitness’s courtroom testimony is independently credible, a properly conducted TIP simply reinforces it, and a partial failure to identify by other witnesses does not automatically defeat an otherwise reliable identification.

Case details

Citation [2001] 1 S.C.R. 1115
Case number Criminal Appeal No. 416/1998
Court Indian Supreme Court
Decided 2001-02-20
Module MO Archive

Read the full judgment (PDF), sourced from the Indian Supreme Court Judgments open dataset (AWS Open Data Registry, CC-BY-4.0).

Explore more in the Forensic Docket or browse the full Forensics hub.

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Anuj Kumar
https://legaldesire.com/about-us/
Legal Desire Media and Insights is a leading legal news and insights platform founded in 2012 by Anuj Kumar, a lawyer, author and legal industry entrepreneur with 14 years in legal publishing. Our editorial team covers judgments, deals, law firm updates, careers and policy across India, the US, UK and Gulf. Coverage is editorially independent; sponsored posts are labeled Partner Content. Contact: legaldesire.com/contact