IDENTIFICATION PARADE

1. INTRODUCTION:
 Identification Parade [hereinafter referred to ID Parade] is an evidence gathering process and not a judicial
process.1
 In Kenya, ID parade procedure is regulated by:
a) The National Police Service Act, 2011,2 contained in the Police Force Standing Orders, 19743 (Form
P156, Rule 6) previously made under Section 5 of the Repealed Police Act and saved under Section
131 of the succeeding National Police Service Act.
b) The Evidence Act, Cap 63: Under Section 63(1), oral evidence must in all cases be direct evidence.
Under Section 63(2), “direct evidence” means with reference to a fact which could be seen, the
evidence of a witness who says he saw it.
 The general jurisprudence in Kenyan Courts is that failure to adhere to the guidelines in Form P156 will
invalidate any evidence gathered through an ID Parade.
 The Kenya Police Order 15/26 was the initial law governing the conduct of identification parades in
Kenya. It was set out by the Police Commissioner with initial instructions from the Chief Justice early in
the 1950’s. It was amended in 1974 and labeled as Chapter 46 of the Police Force Standing Orders,
Paragraph 6.
 Police Form 156 is used for the conduct of identification parades and is designed pursuant to the Police
Force Standing Orders.
2. CONCEPT AND MEANING OF THE TERM “IDENTIFICATION PARADE”:
 An ‘Identification Parade’ refers to a procedure in criminal law where a group of people with similar
characteristics who must be at least 8 in number excluding the one suspected of committing a crime, are
assembled to discover whether a witness can identify the suspect whom s/he allegedly saw during the
commission of a crime and whom s/he had previously described in sufficient detail to the police.4
 Dock Identification v. Identification Parade: Dock identification involves a witnesses pointing out the
accused standing at the dock and identifies him as the culprit who committed the crime. The Courts
generally avoid convictions based on dock identification as enunciated in Gabriel Njoroge v. Republic5
where it was held that “dock identification of a suspect is generally worthless unless other evidence is
adduced to corroborate it.” The same was reiterated in Owen Kimotho Kiarie v. Republic.6 Later, the Court

1
An English Scholar, J.W. Sheperd stated that ‘identification parades can be traced as far back as March 1860, when they were instituted by a
Metropolitan Police Order. The Order stated that the police should place a suspect amongst his peers and then ask the witness to select the person
seen performing the crime.’ The Hansard of 16 th May 1968, Vol. 764 evidences the existence of these regulations governing the Metropolitan
District. In Kenya, the origin of the term identification parade can be traced back to the case of R. v. Mwango s/o Manaa, (1936) EACA 1. This
was later confirmed in the case of David Mwita Wanja and 2 others v. R., Criminal Appeal No. 117 of 2005 where the Court held that “as long as
1936, the predecessor of this Court emphasized that the value of identification as evidence would depreciate considerably unless an identification
parade was held with scrupulous fairness and in accordance with the instructions contained in the police standing orders.”
2
See, S.35(b)&(d), the National Police Service Act, 2011.
3
Chapter 46 Standing Order 6.
4
Blacks Law Dictionary defines the term ‘Identification Parade’ as a police identification procedure in which a criminal suspect and other
physically similar person are shown to the victim or a witness to determine whether the suspect can be identified as the perpetrator of the crime.
5
1982-1988 1 KAR, 34.
6
Criminal Appeal No. 93 of 1983 (Unreported).
Dr. Ratemo Tom
Kenyatta University School of Law, Parklands, Nairobi.
1
 in Amolo v. Republic7 elucidated further by stating, “the reason for the Court’s reluctance to accept a dock
identification is part of the wider concept, or principle of law that is not permissible for a party to suggest
answers to his own witnesses or, as it sometimes put, to lead his own witness.” Thus, it is generally
believed that if an accused is in the dock while the witness testifies against him, undue attention is drawn
towards him. His presence in the dock may prompt a witness to point him out as the person he identified at
the scene of the crime even though he might not be sure of that fact. Moreover, it is believed that the
presence of an accused in the dock might suggest to a witness that he is expected to identify him as the
person who committed the offence. This was discussed in the case of Mwiruri and 2 Others v. Republic.8
The striking difference between ‘dock identification evidence’ and ‘identification parade evidence’ is that
the latter carries a lot of weight, is more credible and is admissible in a Court of law. However, it cannot be
said that all dock identifications is worthless. The Court might base a conviction on such evidence if it is
satisfied that, on the facts and circumstances of the case, the evidence produced is true and if prior thereto,
the Court duly warns itself of the possible danger of mistaken identification.9
3. PURPOSE OF CONDUCTING ID PARADES:
 An accused person must be clearly identified. If there is no proper identification then an accused cannot be
convicted unless there are other factors connecting him with the offence.
 In Republic v. Mwango,10 the Court held that an ID parade must be conducted when the identity of an
accused is doubtful. However, in Ajode v. Republic,11 it was held that where a suspect is known to the
witness, then there is no need for an ID parade to be conducted as this becomes an instance of
demonstrating recognition as opposed to identification of the suspect. Thus, the purpose of conducting ID
parades can be said to be twofold. It is held to:
a) enable eye witness identify the suspect(s) whom s/he allegedly saw prior to a trial being held: In Ajode
v. Republic,12 the Court further held that a Court should not place much reliance on dock identification
unless it has been preceded by properly conducted identification parade. Similarly in Wafula & 3
Others v. R.,13 the Court held that the police failed to investigate the case, particularly conducting ID
parade nearly 14 months after the commission of a crime. The identification was held to be valueless.
b) facilitate due process which is a fundamental requirement in criminal law: Article 50 of the
Constitution of Kenya, 2010 cements an accused person’s right to a fair trial. The right includes the
right to have an ID parade conducted in accordance with set down procedure prior to an accused being
charged. Moreover, the Kenya Police Force Standing Orders at Form No.156 has set down procedures
which if flouted will negate the validity of an ID parade as violates an accused person’s rights and may
lead to his release. In John Musyimi Mutua & Wambua Mutie v. R.,14 where witnesses identified one
appellant in an ID parade two years after commission of the crime and no ID parade was conducted for

7
1991 2 KAR, 254.
8
Criminal Appeal No. 117, 131, 133 of 2000.
9
Mwiruri and 2 Others v. Republic, Criminal Appeal No. 117, 131, 133 of 2000.
10
(1936) 3 EACA 39.
11
(2004) 2KLR 81.
12
(2004) 2KLR 81.
13
(1986) KLR 627.
14
(2004) eKLR.
Dr. Ratemo Tom
Kenyatta University School of Law, Parklands, Nairobi.
2
 the second appellant, the Court held that the admissibility of such identification was shaky and could
not be relied upon. The conviction of the accused was quashed. In essence, this illustrates that
identification evidence is an essential aspect in criminal procedure for a proper conviction.
4. WHEN TO HOLD ID PARADES:
Identification parades are held where:
a) the police have sufficient information to justify the arrest of a particular person for suspected
involvement in an offence;
b) an eye witness has identified or may be able to identify that person;
c) the suspect disputes his identification as a person involved in the commission of that offence or where
a dispute as to identity may reasonably be anticipated.
5. EXCEPTIONS TO IDENTIFICATION PARADES: Where:
a) suspect does not consent;
b) it is impracticable to assemble people who resemble the suspect;
c) the eye witness cannot identify the offender;
d) the case is one of pure recognition of someone well known to the witness.
6. FACTORS INFLUENCING THE IDENTIFICATION PARADE:
These are the factors that the Court will take into account when finding out whether the accused is the
perpetrator of the crime, or if an issue is raised concerning the conduct of the parade. These factors include:
a) Whether the identification (given by a witness) places the accused at the scene of the crime? The factors to
be considered are:
i. Description of the perpetrator: The prosecution should not rely wholly on circumstantial evidence15
nor should the guilt of the accused be based on suspicion,16 nor based on public sympathy.17
ii. Positive identification: If a witness is unable to identify an accused person at the identification parade,
they cannot then purport to identify them at the dock.18
iii. The initial report: It should contain a description of the accused persons.
iv. Nature of the light: Whether the commission of the offence took place at night or during the daytime?
Whether there was sufficient light to enable identification of the assailant? How bright was the light?
How far was the light from the persons identified? What was the intensity and size of the torchlight? 19
v. Time spent with the accused: Whether the witness spent sufficient time with the perpetrators and
whether they were alert during the whole ordeal so as to observe each and every move of the accused
persons? Whether the witnesses had a conversation with the robbers at close proximity?
vi. Appearance of the robbers: Whether the accused had concealed their identity, for example, by wearing
disguises.

15
Mary Wanjiku Gichira v. R. Criminal Appeal No. 17 of 1998 and restated in Joan Chebichii Sawe v. R., Criminal Appeal No. 2 of 2002.
16
R. v Manyara, Criminal case No. 52 of 2004.
17
R. v Manyara, Criminal case No. 52 of 2004.
18
R. v Manyara, Criminal case No. 52 of 2004.
19
Simon Kihanya Kairu & Another v R., 2006 eKLR: Criminal Appeal 99 & 100 of 2004.
Dr. Ratemo Tom
Kenyatta University School of Law, Parklands, Nairobi.
3
7. PROCEDURE UNDER THE FORCE STANDING ORDERS:
Form Police 156
THE KENYA POLICE
(Chapter 46, The Force Standing Orders)
PROCEDURE FOR UNDERTAKING IDENTIFICATION PARADES
If it is necessary for a witness to identify an accused/suspected person, the following procedure must be undertaken:
a) The parade must be conducted with scrupulous fairness, otherwise the value of identification as evidence
will be lessened or nullified.
b) The witness or witnesses must describe the accused person prior to the parade being conducted: The
Courts have held that the witness should not merely state “I will be able to identify the accused if I see him
again.” In Ajode v. Republic,20 Court of Appeal held that it is trite law that before an ID parade is conducted and
for it to be properly conducted, the witness should be asked to give an adequate description of the accused. This
is what will inform the police on whom to include in the parade as there ought to be persons of similar
appearance with the suspect. The police should then conduct a fair parade based on the description provided.
This was reiterated in Ntelejo Lokwam v Republic.21 In this case, the ID parade was held 3 years after the
robbery. The Court held that “in the absence of a description being given to the police when the first report was
made after the robbery had taken place, it would be impossible for an independent tribunal evaluating the
evidence to arrive at a determination that the complainants had in fact made a positive identification of the
appellant.”
c) Parade should be held in privacy: Thus, it should not, unless unavoidable, be held in public but in an enclosed
compound or yard from which all spectators or unauthorized persons are excluded.
d) An accused person must be informed of the reasons for the parade and that he may elect to have an
advocate/friend present when the parade is undertaken. The presence of an advocate/friend helps to assure
the accused that his rights are well taken care of.
In the case of David Mwita Wanja & 2 Others v. Republic, the appellant contended that his rights were violated
as he was not allowed to have a friend present then. However, the Court held that the parade was conducted
properly. It was an omission on Mwita’s part to provide a name and address of a friend he wished to call that
led him not having a friend present.
In Ssesanga Stephen v. Uganda,22 the Court held that the suspect together with his lawyer have a legal right to
be informed that an ID parade is being conducted. The right of an accused to be informed that he can have his
lawyer present is mandatory and failure to do so is fatal to the parade.
In Joshua Mutiso Kisese v. Republic,23 the appellant appealed his conviction on grounds that the officer
conducting the ID parade had not followed the rules. The appellant had not been advised of his right to have an
advocate or friend present. The officer conducting the parade did not tell the Court whether the witnesses were
accommodated before the parade commenced. It also appears that the appellant and his co-accused (who passed

20
(2004) 2KLR 81.
21
(2006) e KLR.
22
[1969] EA 365.
23
(2013) eKLR.
Dr. Ratemo Tom
Kenyatta University School of Law, Parklands, Nairobi.
4
 away during the trial) were placed in the same line-up, and the witnesses went before that parade one after the
other, without the appellant being asked whether he wished to change the position in which he was standing.
The Court quashed the conviction and sentence holding that the parade was improper.
e) The police officer in charge of the case cannot conduct the parade even though s/he is present. However, if
the officer is present, then s/he must be present for the whole of the parade. This is because the rules require that
for fairness, an independent person should be present to take care of the rights of the suspect. Another officer
other than the one in charge of the case must therefore conduct the parade. Annegret Rust & Colin Tredoux in
their Research Paper24 have held that ‘…an officer conducting the parade should state that s/he is independent
and that he knows nothing about the case…’
f) When explaining the procedure to a witness, an officer conducting the parade must inform him/her that
s/he will see a group of people which may or may not contain the accused person. The witness should not
be told to ‘pick out someone’ or be influenced in any way whatsoever in the process of picking.
In Oluoch v. Republic,25 Ndiku & 2 Others v. Republic26 and Simon Kihanya Kairu & another v. Republic27 the
Court held that the identification parades were conducted unprocedurally because the police officer suggested to
the witness the presence of the accused/suspected person in the parade.
In Oluoch v. Republic28 the Court held that in an ID parade, it is dangerous to suggest to a witness that the
person to be identified is believed to be present at the parade. The value of the parade as evidence is depreciated
by this fact.
g) The witness or witnesses should not see an accused before the parade.29 In it Ajode v. Republic,30 was held
that where the witness saw the accused outside the Police Station prior to the parade being conducted, his
identification was valueless as he was demonstrating recognition as opposed to identification. However, in
Njuki & 4 Others v. Republic, the Court of Appeal held that although there were discrepancies in the conduct of
the parade as the witness saw the accused persons before it was conducted, the main factor to be considered in
such a case was whether the discrepancies were of such a nature as to create doubt in the guilt of the accused.
Where the discrepancies were relatively minor they could be overlooked.
h) Where a witness is identifying more than one suspect, the members of the ID parade should not be
similar i.e., the parade should always contain new members whom the witness has not seen before:
In Mburu & Another v. Republic,31 the Court of Appeal held that in cases involving multiple suspects, multiple
identification parades must be held. It is improper to line up the same persons in more than one parade. It was
thus held that the ID parade of the second accused was valueless, his conviction was quashed and his sentence
set aside.

24
Annegret Rust & Colin Tredoux, Identification Parades: An Empirical Survey of Legal Recommendations and Police Practise in South Africa’.
25
Criminal Appeal No. 66 of 1984.
26
Criminal Appeal No.11of 2000’A’.
27
Criminal Appeal No.99 &100 of 2004.
28
Criminal Appeal No.66 of 1984.
29
See, Livingstone Mwangi v. Republic, 2007 eKLR where the Court held that the identification parade was not worthy of any evidential value
since the identifying witness had already seen the suspect who was arrested; Athumani Manzongo & Another v. Republic, Criminal Appeal Case
No.467 of 2000; Omar v. Republic, Criminal Appeal No. 133 of 1985.
30
(2004) 2KLR 81.
31
(2008) 1 KLR (G&F).
Dr. Ratemo Tom
Kenyatta University School of Law, Parklands, Nairobi.
5
i) If a witnesses desires to keep his/her identity secrete and the circumstances are such that the officer in charge
of the case deems such a course advisable for reasons of security, victimization, etc., arrangements must be
made for the witness to view the parade from a concealed vantage point (i.e., through a window, or from behind
a screen). If the witness identifies one or more of the persons on the parade, the persons so identified will be
removed from the parade and brought before and confronted with the witness, who will be asked to confirm in
the normal way, i.e., by touching the person.
j) An accused person must be placed among at least 8 persons of similar: i) Age, ii) Height, iii) General
appearance and class of life as accused, and iv) if accused is suffering from disfigurement, steps should be taken
to ensure that it is not especially apparent.
In Mburu & Another v. Republic,32 the fact that it was conceded, even by the prosecution that the second
accused was the only person in the parade with a visible wounded face and swollen eye, the Court held that the
parade was improperly conducted and identification of the accused was thus valueless.
Similarly, in R. v. Mwango and Maina, an ID Parade was conducted in hospital where the suspect was admitted
and which the ID parade consisted of only 3 men. The officer in charge of the parade asked the complainant
“among these men, who assaulted you?” The complainant picked out the accused who was later tried and
convicted. The conviction was quashed as this flouted two major police force standing orders: i) the accused
should have been placed among eight people of similar height, age and general appearance, and ii) the witness
should have been asked to pick out the person he believed committed the offence.
Likewise, in Njihia v. Republic,33 where the complainant stated that he had identified the appellant at an ID
parade in which the appellant and two other suspects had been lined with eleven other persons, the Court of
Appeal held that the ID parade conducted was not proper as it consisted of 3 suspects mixed with 11 others
contrary to the ratio of 1 suspect to 8 persons which is stipulated in the Police Force Standing Orders. The ratio
was thus mathematically too low to exclude the chance of random guesswork.
In the case of David Mwita Wanja & 2 Others v. Republic, the three appellants were charged with robbery with
violence. They were convicted and death penalty imposed on them. Their first appeal was dismissed. They
appealed to the Court of Appeal. The issue of law raised on appeal centred on the ID parades conducted two
months after the commission of the alleged offence. In this case, two parades were conducted. The eight persons
who took part in the second parade were however, the same persons in the earlier parade except for the
positions they stood. It was submitted by the counsel for the appellants that the evidential value of the ID
parades were rendered meaningless since the witness could readily tell by elimination that the two appellants
were the only new faces in the parade. The Court concurred and held that it was extremely prejudicial to the
appellant.
In the Station Stranglers Case, the suspect had a scar on his chin. After the parade, he raised a complaint that he
was easily noticeable due to the scar. The Court rejected the argument stating that the distance between the
witness and the accused was enough not to allow the visibility of the scar.

32
(2008) 1 KLR (G&F).
33
(1986) eKLR: (1986) KLR 422.
Dr. Ratemo Tom
Kenyatta University School of Law, Parklands, Nairobi.
6
k) An accused may be allowed to take any position he chooses or change to any position after each identifying
witness has left, if s/he so desires. This ensures that the suspect does not feel noticeable and that his protection
is guaranteed. The intention of such movement is in no way intended to confuse the witness but to help achieve
a positive identification of the suspect.
l) The witnesses should not be allowed to communicate with each other: This ensures that the suspect is
protected from bias in that s/he is not identified on the basis of information received from another witness
which, in most cases, might be subjective.
m) Every unauthorized person must be excluded. This ensures that the accused feels safe and protected from
any form of bias or prejudice. Unauthorized persons are likely to interfere with the psychology of the accused
person.
n) Where a witness desires to see an accused person walk, talk, see him with a hat on or off, it should be done,
but the whole parade must be asked to do the same. This should apply to the whole parade to ensure that the
suspect does not have undue advantage over the others. In the South African case of Two Hats Parade the
accused was the only one in the parade with a scarf. The woman identifying him asked the police officer
conducting the parade to move and turn sideways and even asked him to produce a noise. The procedure was
held improper as the others were not asked to do the same.
o) Upon identification, the witness must actually touch the person s/he identifies. This ensures certainty and to
avoid confusion that is likely to arise due to a misunderstanding. An example is where the police officer
understands it another way and records it differently.
p) A note indicating how the witness identified the accused must be made after each witness leaves the parade.
This is done for the purpose of keeping proper records and to help in determining whether the witness positively
identified the accused or not. Besides, the circumstances under which the accused was identified will help in
comparing the description of the accused by the witness and the identified person in the parade. The record will
assist the Court to exercise its discretion with regard to the circumstances surrounding the ID parade.
q) A record should as well be made by an officer conducting the parade of any comments made by an
accused person during the parade, particularly, comments made when the accused was identified. This is done
for the purpose of keeping proper records and to determine the question of positive identification. Besides, it is
also meant to assist the Court in exercising its discretion in determining whether or not to admit the evidence.
r) At the end of the parade or during the parade, an officer conducting it should ask the accused is s/he is
satisfied that the parade is undertaken in a fair manner and note down reply made.
In Jimmy Wanjohi Wanjiku v. Republic,34 the Court held that the parade was properly conducted as the accused
signed the report indicating that he was satisfied with the manner in which it had been conducted.
s) It is the duty of the Magistrate to ensure that where a police officer gives evidence of an ID parade, the
parade was conducted in accordance with the above rules.

34
Criminal Appeal No. 128 0f 2006.
Dr. Ratemo Tom
Kenyatta University School of Law, Parklands, Nairobi.
7
 Form Police 156
THE KENYA POLICE
(Chapter 46, The Force Standing Orders)
REPORT OF AN IDENTIFICATION PARADE HELD AT
Diaspora Police Station
ON 21/02/1017 FROM 10.00AM TO 12.00PM
A. CASE FILE NO. CR/24/2/2017
Offence: Robbery with violence contrary to Section 296(2) of
the Penal Code, Cap 63
Investigating officer: Name: Kevin Komite
Rank: Corporal whether present: Yes/No
B. OFFICER IN CHARGE OF THE PARADE: Name: Chepkogen Kennedy
Rank: Chief Inspector
Station: Diaspora Police Station
Name of the suspect: Margret Halo
Address of the Suspect: P.O Box 287, Nairobi.
Suspect informed of the purpose of the parade by: Chepkogen Kennedy
Suspect asked if s/he consents to appear on the parade and replies thereto: Yes
Signature of the Suspect
Informed that, if desired, a friend or solicitor may be present and replies thereto: Yes
Name and address of friend or solicitor: N/A
Signature of the Suspect
C. WITNESS:
No. Name Address
1. Winnie Kamau P.O Box 1978-00100, Nairobi
2. Wyclife Lonna P.O Box 992, Nairobi.
3. ……………... ………………………….
D. MEMBERS OF THE PARADE:
No. Name Address
1. Karen Wambui P.O Box 1978-00100, Nairobi
2. Celestine Dofa P.O Box 112-00100, Nairobi
3. Jackline Owuor P.O Box 78-00100, Nairobi
4. Hellen Kerubo P.O Box 18-00100, Nairobi
5. Sarak Kamau P.O Box 17-00100, Nairobi
6. Asha Kim P.O Box 19-00100, Nairobi
7. Silivia Ogola P.O Box 198-00100, Nairobi
8. Susan Mwikali P.O Box 180-00100, Nairobi
(N.B: The name of the accused person should not be include in the list of members of the parade)
Dr. Ratemo Tom
Kenyatta University School of Law, Parklands, Nairobi.
8
 What objections (if any) were made by the suspect concerning the arrangements, or the persons on the
parade? What action was taken concerning the objection: No objection
The witnesses’ accommodation arrangements: Witnesses sat in the crime office before the parade
away from the identification yard.
E. RESULT OF THE PARADE:
Witness No. Position of the Suspect Was Suspect Remarks
on the Parade Identified? If so, how?
1 Between Yes, by limping
3&4 (This must match with
(Suspect should not be the information the
counted) witness gave while
reporting the incidence)
2 Between Yes, by limping and
6&7 speaking
3 Between
-&-

Reply by suspect when asked if satisfied with the conduct of the parade: The suspect was asked and was
contended with the process.
Signature of the Suspect
F. CERTIFICATE BY THE OFFICER CONDUCTING THE PARADE:
I conducted the whole of the proceedings in connection with the parade and I certify that the instructions on
identification parade were strictly complied with and that, as far as possible, the persons taking part in the
parade were of similar age, height and general appearance, as the suspect.
Signature:
Date: 21/02/2017 Rank: Corporal
4. CONCLUSIONS:
 While the law sets out certain requirements of how ID parades should be conducted, requirements are not
always followed to the letter, resulting in acquittals for individuals who may have participated in the
investigated crime.
 There are various questions that crop up. For instance, what are the odds that 8 people who look similar to
an accused can be found to conduct an ID parade? The probability is extremely low. Why should witnesses
whose lives have been threatened by an accused be asked to touch the accused they identify?
 In the light of the above, it is proposed that the following reforms should be undertaken to change the
conduct of ID parades so as to ensure that the evidence obtained cannot be impeached due to a minor
technicality and more importantly, justice is not only done but seen to be done:

Dr. Ratemo Tom

Kenyatta University School of Law, Parklands, Nairobi.
9
a) Amendment of the Witness Protection Act: It should be amended to extend the protection of
witnesses to witnesses who identify perpetrators at an ID parade especially for rape victims and
victims of robbery with violence. The mere sight of the accused conjures up bad memories and having
to touch the accused can be traumatizing for the witness.
b) The provision for identification through touching should be scraped out: as it is intimidating
especially for victims of rape. It may expose a witness to dangerous suspects. A witness may shy away
from identification for fear of victimization. It is proposed that number tags can be used to identify
suspect.
c) Adoption of the sequential system of parades: This is where the parade members are presented to
the witness individually in a random manner.
d) Use of photographs in place of corporeal parades: Using photographs in a well prepared manner
enables the witness to be confident and relaxed when identifying the accused persons. This is faster
and it protects the identifying witness from coming face to face with the suspected person(s). It also
removes the aspects of tension and fear among the identifying witness. The South African case of
Station Strangler where the boy failed to identify the accused probably due to fear could have easily
identified them from photographs.
e) Incorporation of more advanced methods of identification: This is similar to the use of photographs
only that a database system of pictures is used in collaboration with other hi-tech it equipment. ICT
technology could also be embraced where a Video Identification Parade Electronic Recording System
(VIPER) can be used as it is faster as compared to a real-life ID parade which generally takes weeks to
arrange and causes the witnesses distress. Here the suspect’s description is entered into the system and
then galleries of images similar to him are displayed. A video of the images is then shown to the
witness in controlled conditions.

Dr. Ratemo Tom

Kenyatta University School of Law, Parklands, Nairobi.
10