In Brief
Mukesh Singh was convicted of robbery, dacoity, and murder (Sections 302, 392, 394, 397 IPC) and sentenced to life imprisonment. He appealed, arguing that the prosecution's case rested solely on eyewitness identification and that he should not be compelled to participate in a Test Identification Parade (TIP), which he claimed violated Article 20(3) of the Constitution. The Supreme Court held that Article 20(3) does not protect against compulsory attendance at a TIP, as it does not require any positive volitional evidentiary act by the accused—the witness performs the identification. While TIP corroboration strengthens eyewitness testimony, in-court identification by a reliable witness can suffice. The Court upheld the conviction, finding the injured eyewitness credible and relying on corroborating evidence of the concealed weapon, despite the accused's TIP refusal.
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