RAMKISHAN MITHANLAL SHARMA vs THE STATE OF BOMBAY.[And Two Connected Appeals]

The Supreme Court ruled that Section 162 of the Code of Criminal Procedure (Act V of 1898) does not apply retrospectively to investigations conducted under the City of Bombay Police Act (Bombay Act IV of 1902) prior to its repeal on 1st August 1951. The Court held that evidence from test identification parades conducted before this date is inadmissible under Section 162, while evidence from parades held after this date is admissible. The decision clarifies the applicability of procedural laws to ongoing investigations and the nature of statements made during such investigations.