Sister Mina Lalitha Baruwa vs State Of Orissa & Ors

The Supreme Court addressed the procedural irregularities in the Test Identification Parade conducted by PW-18, emphasizing the necessity of adhering to the prescribed format under Schedule XLVII of the Cr.P.C. The Court held that the failure to record the appellant's statements regarding the behavior of the accused during the identification process undermined the integrity of the identification. Consequently, the Court ruled that the identification of the accused was unreliable, impacting the prosecution's case significantly.