PRINCIPLE STATEMENT

Where the commission of a crime is alleged in any proceedings (civil or criminal), it must be proved beyond reasonable doubt and the onus of such proof rests on him who alleges the commission of such a crime.

RATIO DECIDENDI (SOURCE)

Per Iguh, JSC, in Tewogbade v. Obadina (1994) NLC-228990(SC) at p. 25; Paras B--C.
"Where, therefore, the commission of a crime is alleged in any proceedings, civil or criminal, it must be proved beyond reasonable doubt and the onus of such proof rests on him who alleges the commission of such a crime."
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EXPLANATION / SCOPE

Criminal conduct allegations (forgery, fraud, theft) require criminal standard of proof—beyond reasonable doubt—even in civil proceedings. This applies whenever criminal conduct is alleged as part of civil claims or defenses. The alleging party bears the burden: if Party A claims Party B’s document is forged, Party A must prove forgery beyond reasonable doubt. This high standard protects against casual criminality allegations and recognizes the serious implications of finding criminal conduct. The principle applies to all criminal allegations in civil cases: forgery, fraud, conspiracy, theft, assault. However, this doesn’t convert civil proceedings to criminal—it affects only proof standard for the criminal allegation. Other civil issues are proved on balance of probabilities. This prevents parties from establishing criminal conduct through civil proceedings with lower proof standards

CASES APPLYING THIS PRINCIPLE