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As per case facts, an anonymous call led police to find a Mahant's dead body with blunt force injuries. Witnesses presented video and photo evidence. Appellants were identified and convicted
...by the trial court based on Section 164 CrPC statements, electronic evidence, and a test identification parade. The appeal challenged the reliability of Section 164 CrPC statements as witnesses turned hostile, and the admissibility of electronic evidence without a Section 65-B certificate. The question arose whether convictions could stand on such evidence when witnesses resile and electronic evidence lacks proper certification. Finally, the High Court ruled that Section 164 CrPC statements were not substantive evidence and were unreliable. Electronic evidence (CD, photos) was inadmissible due to the lack of a Section 65-B certificate. The test identification parade was flawed, and the prosecution failed to prove guilt beyond reasonable doubt, leading to the quashing of convictions. One appeal abated due to the appellant's death.
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