The case of Budhsen vs. State of U.P. AIR 1970, S.C. 1321 related to:

Budhsen v State of U.P. (AIR 1970 SC 1321) dealt with "Identification parades": the Supreme Court explained that identification in a test identification parade is not substantive evidence and only corroborates identification in court, and examined the safeguards needed for such parades. Facts establishing identity are relevant under section 9. The case is not an authority on dying declarations, documentary evidence or burden of proof.

Current law: Facts establishing identity remain relevant under BSA section 7; the distinction between substantive court testimony and supporting identification remains material. BSA commenced on 1 July 2024; section 170 preserves the Evidence Act for proceedings pending immediately before that date.