18 Jan




Generally, the courts are concerned with the quality rather than quantity (i.e. number) of evidence-See Section 200EA, Ugwumba V State[1]. However, in certain situations (as shall be highlighted) the courts usually require that evidence should be substantiated/confirmed by another evidence-Igri V State. Also Dabiri V COP.

Corroboration was defined in Nwambe V State[2] as “confirmation of a witness’s evidence by independent testimony”. See also Okafor V COP[3] and Ohunyon V State[4] where  definitions similar to this were provided. See also R V Okagbue[5]. As noted by Kaglo JSC in Iko V State (citing DPP V Hester): evidence which is deficient, suspect[6] or incredible needs to be confirmed/supported. Similar point noted in Isiaka V State.


[1] 1993 5 Nwlr Pt 296 p 660.

[2] 1995 NWLR pt 348 p 405.

[3] 1964 NMLR 89.

[4] 1996 3 nwlr pt 436 p 264 at 273.

[5] 1958 3 FSC 27.

[6] Maybe as a result of bias, lies, concoction, and so on-See Lord Morris in DPP V Hester.


Quite eccentric really

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