Searching Case Laws & Precedent on Legal Query.....!
Analysing the retrieved Case Laws
Scanned Judgements…!
Searching Case Laws & Precedent on Legal Query.....!
Analysing the retrieved Case Laws
Scanned Judgements…!
Multiple sources emphasize that when the face of the accused is not clearly visible in CCTV footage, the FSL (Forensic Science Laboratory) report on facial recognition becomes inconclusive or unnecessary.
Role of FSL in Identifying Faces:
When faces are masked, covered, or not visible, the FSL facial recognition report may be inconclusive or rejected.
Naved vs State - Delhi
, the reports mention that poor pixel quality or deliberate covering (mask/scarf) hampers facial recognition, and expert opinions sometimes dispute the FSL findings refs: 2025 Supreme(Online)(Del) 7995,Naved vs State - Delhi
.Legal and Investigative Practice:
In some cases, identification is based on other evidence like witness testimonies or contextual clues rather than FSL reports.
Expert Opinions and Supplementary Evidence:
Naved vs State - Delhi
, expert analysis contradicted FSL reports, indicating that the object in hand was a mask, not a weapon or a face, thus diminishing the importance of facial recognition refs: 2022 0 Supreme(Del) 957,Naved vs State - Delhi
.References:- 2025 Supreme(Online)(Guj) 9149- 2024 Supreme(Online)(MP) 37150- 2025 Supreme(Online)(Del) 7995- 2022 0 Supreme(Del) 957-
Naved vs State - Delhi
- 2023 Supreme(Online)(Guj) 1185
In today's digital age, CCTV and video footage play a pivotal role in criminal investigations and trials across India. But what happens when the footage captures only the backside of a suspect, with no clear view of the face? A common question arises: Whether of Video Footage is Mandatory when Face of Accuse is Not Visible only Backside is Visible?
This issue is critical for lawyers, investigators, and accused individuals alike. Courts must balance the need for scientific validation against practical evidence sufficiency. This post explores Indian legal precedents, emphasizing that () analysis is not strictly mandatory if identity can be established through other reliable means. Note: This is general information based on case law and not specific legal advice. Consult a qualified lawyer for your case.
The forensic examination of video footage is not strictly mandatory when the face of the accused is not visible and only the backside is shown, provided that the available evidence can sufficiently establish the identity of the accused through other means. The requirement hinges on the evidence's nature, reliability, and without expert verification. Courts prioritize the totality of circumstances over rigid scientific mandates.
reports confirm if footage is unaltered. For instance, in one case, the report dated shows that the memory card was accessed through a Vivo mobile phone with an Android Operating System and Jio Network Application installed with Telegram, WhatsApp, Instagram etc. and detected possible tampering. 2023 0 Supreme(Ker) 888 This underscores 's focus on integrity over mere identification.
Facial clarity is key for direct identification. Courts caution against relying on blurred or partial views: resting a conviction on the basis of such images, and even on expert opinion obtained in respect thereof may be hazardous.
Similarly, the ultimate opinion was based on facial comparison and , but questioned how far such scientific opinion can be relied upon, especially when the actual image is extremely blurred. 2018 0 Supreme(Del) 520
From additional sources, when faces are obscured, often proves inconclusive. In 2025 Supreme(Online)(Guj) 9149, the item no.3 i.e. conclusion clearly shows that a person found wearing the blanket was not visible and therefore, it is the finding of the that, the face of the accused is not matched with the person found in the CCTV footage. Courts thus shift to other evidence.
Video without facial visibility remains viable with corroboration. Scientific analysis enhances credibility but isn't always required: scientific analysis of should be conducted to establish authenticity, but the absence of such analysis does not necessarily render the evidence inadmissible if the visual cues are sufficient. 2021 0 Supreme(Bom) 978
Other cases reinforce this. In 2025 Supreme(Online)(Del) 7995, despite poor quality, ruled out manipulation, and identification relied on witnesses: Petitioner is clearly visible in the CCTV footage and after seeing the CCTV footage, the petitioner has been duly identified by PW-14 (brother of the deceased) and PW-15 (wife of the decea.... In 2024 Supreme(Online)(P&H) 782, faces of the culprits in the CCTV footage are not identifiable... face of the petitioner is not visible, yet proceedings continued on other grounds.
or body features may substitute, but courts prefer holistic evidence. 2023 0 Supreme(Del) 5274 notes identification by known persons despite partial visibility, with hard disks sent to for copying.
In 2021 0 Supreme(Raj) 519, One white Micra Car was visible in the footage but the number of the car and driver of the car were not visible, highlighting reliance on context over .
Courts emphasize supplementary proofs:- Witness Testimony: Known individuals identify suspects from footage. 2023 0 Supreme(Del) 5274- Vehicle/Contextual Clues: Number plates, clothing, or location. 2023 Supreme(Online)(Guj) 1185- Expert Opinions Beyond : Gait or object analysis, disputing initial reports.
Consensus: is non-mandatory when faces are obscured; other evidence takes precedence. 2024 Supreme(Online)(MP) 37150
– Hazards of blurred images/expert opinion.
In conclusion, analysis of video footage is highly valuable but not an absolute requirement when the accused's face is invisible, and only the backside shows. Courts recognize limitations, prioritizing reliable identification via multiple sources. This flexible approach ensures justice without undue technical barriers.
Key Takeaways:- Not Mandatory: If other evidence suffices.- Advisable: For authenticity in doubtful cases.- Holistic View: Always consider full evidence chain.
#FSLIndia, #CCTVEvidence, #CriminalLaw
The item no.3 i.e. conclusion clearly shows that a person found wearing the blanket was not visible and therefore, it is the finding of the FSL that, the face of the accused is not matched with the person found in the CCTV footage. ... Referring to the report of FSL on the aspect of CCTV footage, he submitted that the learned trial court has ....
not visible. ... He stated that he identified all the persons visible in the CCTV footage as they were known to him prior to the incident as they used to visit his house and office. He stated that he identified all the persons visible in the CCTV footage. ... Further the hard disc containing the CCTV footage was sent to FSL wherein it was copied in a p....
Learned counsel for the applicant has submitted that applicant has not committed any offence. He is innocent. He has been falsely implicated. In CCTV footage, the person seen is having mask on his face. He is not clearly visible. ... In CCTV footage of 03:00 a.m. one person wearing white shirt and pant with mask on face but without wearing any shoes or chappal is enter....
The argument regarding poor pixel quality of the footage cannot be accepted at this juncture, since the FSL report on video authenticity is awaited. Nonetheless, the FSL has ruled out manipulation. ... Petitioner is clearly visible in the CCTV footage and after seeing the CCTV footage, the petitioner has been duly identified by PW-14 (brother of the deceased) and PW-15 (wife of the decea....
State counsel, he has responded on the instructions from the Investigating Officer that faces of the culprits in the CCTV footage are not identifiable. Ld. State counsel fairly conceded, on instructions from the IO, that face of the petitioner is not visible in the CCTV footage. ... 2.3 Police report also reveals that CCTV footage of the alleged incident, as pr....
Ltd. shows it to be a face mask. ... The FSL report filed on record supports the version of the police that the petitioner was holding a fire-arm which was used. It is true that the petitioner has also filed on record an expert opinion that what he was holding in his hand was merely a face-mask and not a fire-arm. ... 5.1 The FSL report relied upon by the prosecution of the analysis of the CCTV #HL_START....
The FSL report relied upon by the prosecution of the analysis of the CCTV Footage shows that the applicant was holding a pistol like object, whereas the same CCTV footage when got examined from an expert from Brilliant Forensic Investigation Pvt. Ltd. shows it to be a face mask. ... The FSL report filed on record supports the version of the police that the petitioner was holding a fire-arm which was used.....
Because we conclude that it does not, we hold that the district court was not required to exclude the pole-camera footage at Harry’s criminal trial for drug trafficking. ... Harry Was Not Eligible for Safety-Valve Relief from the Mandatory Minimum Imposed Under 18 U.S.C. § 3553(f), a court will not apply the mandatory minimum to a defendant convicted, like ....
was fully covered and his identity is not visible as such. ... As regards the husband leaving the house is not visible in the CCTV footage. It is stated by APP that the neighbour’s CCTV covers only one side and that there is also another way leaving from the house. ... 22] Considering the above evidence on record it is to be noted that although the person who has come on a red coloured motorcycle on 07.0....
The Sessions Court has relied on CCTV footage, but no CCTV Footage is duly proved or evidence is collected by the Investigating Agency. Even during investigation, the number plate of the alleged car seen in the CCTV footage is not visible. ... Further, it appears that the CCTV Footage is watched and examined by the Court its own and the said recording of CCTV is not sen....
In another instance, footage is shown on the electronic media where the face of the victim is blurred but the faces of her relatives, her neighbours, the name of the village, etc. is clearly visible. It would not require rocket science to find out and establish her identity. We, therefore, hold that no person can print or publish the name of the victim or disclose any facts which can lead to the victim being identified and which should make her identity known to the public at....
IO has further stated that the face of the petitioner is not visible on the CCTV footage. IO has stated that the status report had been filed and the location of the petitioner was not found near the place of the incident.
70. PW-6 Ravindra testified that one digital video recorder and one CD, received from Pramod Avasthi, were seized and Exhibit-P.29 was prepared. Similarly, one CD received from Jalaj Vyas, was seized (Exhibit-P.30). One white Micra Car was visible in the footage but the number of the car and driver of the car were not visible".
One white Micra Car was visible in the footage but the number of the car and driver of the car were not visible”.
7. Learned counsel for the appellant opened his submissions by contending that the two CD''s (Ex. PW-30/18) and (Ex. PW-30/19) which were made out of the Hard Disc Drives (Ex. PW-7/A) and (Ex. PW-21/A) containing the CCTV footage of two persons going on a bike are secondary evidence in terms of the Indian Evidence Act and are inadmissible without the certificate as required under Section 65-B of the Indian Evidence Act. In support of his contention, the learned counsel relied on the case of An....
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