In State of H.P. Vs. Lekh Raj and Another [(2000) 1 SCC
247], this Court emphasized the purpose for holding test
identification parade in the following terms:
"3...During the investigation of a
crime the police agency is required to
hold identification parade for the
purposes of enabling the witness to
identify the person alleged to have
committed the offence particularly when
such person was not previously known to
the witness or the informant. The
absence of test identification may not
be fatal if the accused is known or
sufficiently described in the complaint
leaving no doubt in the mind of the
court regarding his involvement.
Identification parade may also not be
necessary in a case where the accused
persons are arrested at the spot. The
evidence of identifying the accused
person at the trial for the first time
is, from its very nature, inherently of
a weak character. This Court in Budhsen
v. State Of U.P. ((1970) 2 SCC 128 :