PRINCIPLE STATEMENT

After closely scrutinizing concurrent findings of fact, where they are fully supported by evidence, not perverse, not reached through wrong approach to evidence, and not arrived at through wrong application of principles of substantive law or procedure, the Supreme Court will not interfere with them.

RATIO DECIDENDI (SOURCE)

Per Iguh, JSC, in Akpabio v. The State (1994) NLC-961993(SC) at pp. 22; Para E – pp. 23; Para A.
"I myself, have closely scrutinised these concurrent findings of facts and feel completely satisfied that they are fully supported by evidence before the court. It is neither established that they are perverse or were reached as a result of a wrong approach to the evidence nor were they arrived at as a result of any wrong application of the principles of substantive law or procedure. In the circumstances, this court will not interfere with them."
View Judgment

EXPLANATION / SCOPE

Supreme Court review of concurrent findings involves careful scrutiny, not rubber-stamping. The Court examines whether findings are: (1) Supported by evidence—some evidentiary basis exists; (2) Not perverse—within the range of reasonable conclusions from evidence; (3) Reached through proper approach—correct evaluation methodology; (4) Based on correct legal principles—proper application of substantive law and procedure. Only after this scrutiny does deference apply. If any of these elements fail, interference is warranted. This balances: substantial deference to concurrent findings (promoting finality) against Supreme Court’s responsibility to correct fundamental errors. The principle describes the Court’s actual review process—active examination followed by deference if standards are met.

CASES APPLYING THIS PRINCIPLE