Failure to hold a test identification parade does not invalidate reliable in-court identification.

On 8 July 2013, Satish was stabbed during an incident near Muthumariyamma Temple in Bengaluru and later died.

The prosecution alleged that the appellant stabbed him and that other accused persons restrained him.

The trial court convicted the appellant under Section 302 IPC, acquitted him of the charge under Section 307 IPC, and acquitted accused Nos. 3 and 4; the case against accused No. 2 had abated following his death.

The appellant challenged his murder conviction, disputing, among other things, the eyewitness identifications, the absence of a test identification parade, inconsistencies in the testimony, and the recovery evidence.

1. Whether the eyewitness evidence, including testimony from the injured complainant, reliably established that the appellant stabbed the deceased, notwithstanding the absence of a test identification parade and the alleged inconsistencies.

2. Whether the medical and recovery evidence sufficiently supported the prosecution case and the appellant’s conviction under Section 302 IPC.

Section 302 IPC governs the offence of murder.

The Court assessed the prosecution’s direct evidence by considering the testimony of the injured complainant and other eyewitnesses alongside the medical and forensic evidence.

It held that the absence of a test identification parade, by itself, was not a ground to reject eyewitness testimony where the witnesses identified the accused in court.

The judgment cites no precedent or separate statutory evidentiary provision.

The Court accepted the complainant’s presence at the scene, noting his injuries were supported by the wound certificate and by other prosecution evidence, even though the trial court had found inconsistencies about who assaulted him and acquitted the appellant under Section 307 IPC.

It found that the complainant and eyewitnesses PWs. 4, 5 and 14 consistently identified the appellant as the person who stabbed Satish; the discrepancies raised by the defence did not undermine that evidence, and the lack of a test identification parade did not displace their in-court identifications.

The post-mortem evidence established homicidal death, while the forensic evidence showed “A” group blood on the knife, the deceased’s clothes and the appellant’s clothing.

In light of the eyewitness and corroborative evidence, the Court found no basis to interfere with the trial court’s conviction.

The trial court’s acquittals of the other accused and of the appellant under Section 307 IPC were not disturbed.

The supplied judgment extract does not state the sentence imposed.