14 unveiled photographs of the accused were published across newspapers starting from 23.06.2011. In this regard, reliance is placed on Ex. D6, D45 and D48 which are newspaper articles containing photographs. Furthermore, it was submitted that the procedure of the TIP was questionable as Rahul and Manoj were made to stand together in the TIP line-up. The identification memo does not record the appearances of the other persons. Ms. Prakash submitted that Rahul and Manoj do not look similar - she relied on the arrest memos Ex. P12 and P15 to support her argument. PW-10 in his cross examination stated that some persons were tall, others were short; some were fair and others, dark. Therefore, the combined TIP procedure was faulty and could not have been relied on. In this regard, counsel relied on Lal Singh and others v. State of U.P9, Muthuswami v. State of Madras10 and Mohammed Abdul Hafeez v. State of AP11 to say that in the absence of individual distinguishing features, a TIP of the accused conducted after a relatively long time may not be relied upon by the courts. 27. Learned senior counsel submitted that there was serious doubt about the identity of Rahul, who was referred to as “Govind” in all documents until the preparation of his arrest memo Ex. P12 on 22.06.2011. There was no reason why an alias for Rahul was associated with him in the arrest memo. This raises doubt about the identity of the individual. All documents relating to the medical treatment for the bullet injury as well as the case proceeding (Crime No. 377/2011 registered by PW-29 crucially on the date of occurrence) refer to him as Govind. These were Ex. P103 - dehatinalisi at 10:30 PM on 19.06.2011; Ex. P97 - letter of police to the District Hospital & report of District Hospital Indore after examination of wounds and referring him to M.Y Hospital; Ex. P104 Crime details recorded at 11 PM on 19.06.2011; Ex. P105 - FIR of the shooting incident at 12:15 AM on 20.06.2011; Ex. P101 - case closure report on 9 2003 (12) SCC 554 10 AIR 1954 SC 4 11 (1983) 1 SCC 143