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Mohanlal Gangaram Gehani vs State Of Maharastra on 17 February, 1982

―It is well settled that where a witness identifies an accused who is no known to him in the Court for the first time, his evidence is absolutely valueless unless there has been a previous T.I. parade to test his powers of observations. The idea of holding T.I. parade under Section 9 of the Evidence Act is to test the veracity of the witness on the question of CRL. A 4/1993 Page 41 of 43 his capability to identify an unknown person whom the witness may have seen only once. If no T.I. parade is held then it will be wholly unsafe to rely on his bare testimony regarding the identification of an accused for the first time in Court.‖ In Mohanlal Gangaram Gehani v. State of Maharashtra: (1982) 1 SCC 700 also the same view is expressed.
Supreme Court of India Cites 8 - Cited by 361 - S M Ali - Full Document

Laxmipat Choraria And Ors vs State Of Maharashtra on 14 December, 1967

In Laxmipat Choraria and Others v. State of Maharashtra: AIR 1968 SC 938, the Supreme Court categorically observed that showing of a photograph prior to the identification makes the identification worthless. The Supreme Court also observed that there could be no doubt that if the intention on the part of the prosecution is to rely on the identification of the suspect by a witness, his ability to identify should be tested without showing him the suspect or his photograph or furnishing him the data for identification.
Supreme Court of India Cites 25 - Cited by 83 - M Hidayatullah - Full Document
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