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(ii) Identification of the accused in the Court is a substantive evidence. The previous identification in the test identification parade is a rule of prudence and not law.

It simply acts as a check valve to the evidence of identification in court of an accused by a witness.

(iii) Absence of test identification parade is not ipso facto fatal.

(iv) If the accused is named or sufficiently described in the complaint leaving no doubt in the mind of the court regarding his involvement, safely then identification for the first time before court can also be considered.