Lala @ Anurag Prakash Aasre v. The State of Maharashtra

Criminal Appeal · 2021 INSC 415Decided 24 Aug 2021
Criminal Appeal No. 540 of 2018
Justice Sanjay Kishan Kaul · Justice Hrishikesh Roy

Background

A group of 10-12 men attacked a man named Balu Mandpe with sharp weapons, killing him, and also injured a bystander who tried to intervene. The appellant was convicted of murder and related offences by the trial court and High Court, mainly on the strength of eyewitness testimony, even though the FIR itself did not name him: it only described one attacker by physical appearance ("a tall person with a longish nose"). The appellant argued that without a Test Identification Parade (TIP) and given the omission of his name from the FIR, his identification as that attacker was unreliable.

Decision Breakdown

The Supreme Court carefully examined the original trial court records (noting discrepancies between different translated/transcribed versions of witness statements) and found that although the FIR did not name the appellant, a supplementary statement recorded within hours did name him, and multiple eyewitnesses later identified him by name and appearance consistently at trial. The Court held that a Test Identification Parade is not mandatory when the accused is already known to the eyewitnesses and has been specifically named and identified in their testimony: a TIP is only a corroborative investigative tool, not substantive evidence required by law. Finding the eyewitness identification credible and consistent despite minor variations, the Court upheld the conviction and dismissed the appeal, while leaving open the possibility of the State considering remission on its own merits.

Lesson Learnt

A conviction does not automatically fail just because a particular attacker's name is missing from the first police complaint or no formal identification parade was held: courts can rely on credible, consistent eyewitness identification from trial testimony when the accused was already known to the witnesses.

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