PRINCIPLE STATEMENT

No fact need be proved in any civil proceedings which the parties or their agents agree to admit at the hearing, or which before the hearing they agree to admit by writing under their hands, or which by any rule of pleading in force at the time they are deemed to have admitted by their pleadings.

RATIO DECIDENDI (SOURCE)

Per Ogwuegbu, JSC, in Honika Sawmill (Nig.) Ltd v. Hoff (1994) NLC-2081992(SC) at P. 25; Paras A--C.
"No fact need be proved in any civil proceedings which the parties thereto or their agents agree to admit at the hearing, or which, before the hearing, they agree to admit by any writing under their hands, or which by any rule or pleading in force at the time they are deemed to have admitted by their pleadings..."
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EXPLANATION / SCOPE

Three types of admissions eliminate proof requirements: (1) Admissions at hearing—parties/agents orally admit facts during trial; (2) Written admissions before hearing—formal written agreements admitting facts; (3) Deemed admissions by pleading—facts deemed admitted under pleading rules (like failure to deny). All three have identical effect—the facts are established without proof. This statutory provision (from Evidence Act) reinforces pleading rules and party autonomy. Benefits: efficiency (no time wasted proving agreed facts), party control (parties can narrow issues), and certainty (admitted facts are established). Courts can rely on admitted facts without requiring evidence. This principle underlies much civil procedure—pleading systems work by establishing which facts are admitted (requiring no proof) versus contested (requiring proof).

CASES APPLYING THIS PRINCIPLE