In Feroz Ahmad v. State, the Delhi High Court had considered the question of whether the conviction of robbery could be upheld in a case where the accused was primarily identified by dock identification. The appellant stated that the witnesses were unfamiliar with him and that Test Identification Parade (TIP) could not be conducted due to the fact that he was presented to the witnesses prior to the parade without adequate face covering. The prosecution was based on the in-court identification and purported discovery of incriminating material by the witnesses. Justice Vimal Kumar Yadav believed that in criminal law, identification was paramount and when the offender is not known by anybody, the identification should be done fairly by the use of a fair TIP so that subsequent dock identification can be done. The TIP was ruled to be compromised by the Court and dock identification on its own was deemed to be weak and unreliable. It also questioned the recovery evidence saying that the additional statements seem to have been added to connect the gaps in the investigations. The Court used the principle which requires proving beyond reasonable doubt and the benefit of doubt and dismissed the conviction and acquitted the appellant after 23 years since the identity of the accused was not clear.