PRINCIPLE STATEMENT

A judgment in proceedings to which a party is not a participant (res inter alios acta) is irrelevant as between that party and others in subsequent proceedings, unless its existence is a fact in issue or is relevant under some other provision of the Evidence Act; such a judgment, if wrongly admitted, should be expunged.

RATIO DECIDENDI (SOURCE)

Per Ogundare, JSC, in Ezebilo Abisi & Ors. v. Vincent Ekwealor & Anor (1993) NLC-1031990(SC) at pp. 37–38; Paras C–E.
"A judgment in proceedings to which a party is not a participant (res inter alios acta) is irrelevant as between that party and others in subsequent proceedings, unless its existence is a fact in issue or is relevant under some other provision of the Evidence Act. Such a judgment, if wrongly admitted, should be expunged."
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EXPLANATION / SCOPE

Judgments bind only parties to the proceedings (res judicata) or those in privity with them. Judgments from proceedings between other parties (res inter alios acta—”things done between others”) are generally inadmissible in subsequent litigation involving different parties. This prevents judgments from affecting strangers who had no opportunity to participate. Exceptions exist when: (1) the judgment’s existence (not its correctness) is a fact in issue; (2) specific Evidence Act provisions make it relevant. For example, a judgment affecting property rights in rem may be admissible to show those rights were adjudicated, but not to prove the merits. Wrongly admitted judgments should be expunged and disregarded. This principle protects due process and prevents collateral binding

CASES APPLYING THIS PRINCIPLE