An identification parade is not mandatory nor can it be claimed by the suspect as matter of right.

S.9—Test identification parade—When desirable An identification parade is not mandatory nor can it be claimed by the suspect as matter of right. The purpose of pre-trial identification evidence is to assure the investigating agency that the investigation is going on in the right direction and to provide corroboration of the evidence to be given by the witness or victim later in court at the trial. If the suspect is a complete stranger to the witness or victim, then an identification parade is desirable unless the suspect has been seen by the witness or victim for some length of time. In Malkhan Singh v. State of M.P., (2003) 5 SCC 746, it was held:  ―The identification parades belong to the stage of investigation, and there is no provision in the Code of Criminal Procedure which obliges the investigating agency to hold, or confers a right upon the accused to claim a test identification parade. They do not constitute substantive evidence and these parades are essentially governed by Section 162 of the Code of Criminal Procedure. Failure to hold a test identification parade would not make inadmissible the evidence of identification in court. The weight to be attached to such identification should be a matter for the courts of fact.‖  

Case Law:
Prakash vs. State of Karnataka;

Citation :
2014 Cri.L.J. 2503 (SC)