The Supreme Court said mere identification of an accused in the test identification parade (TIP) cannot form the substantive basis for conviction and there cannot be repeated TIPs till such time that the prosecution is successful in obtaining identification of the accused.

A bench of Justices Navin Sinha and R Subhash Reddy said, "We find it extremely disturbing that both the trial court and the high court did not go into this aspect at all to satisfy themselves if any TIP had been proved to have been held at all and that too in accordance with the law."