LEGAL PRINCIPLE: APPELLATE PRACTICE – Concurrent Findings – When Appellate Court Will Interfere with Concurrent Findings of Fact
PRINCIPLE STATEMENT
It is settled law that this court will not normally interfere with the concurrent findings of the two lower courts unless there is some miscarriage of justice or a violation of some principles of law or procedure.
RATIO DECIDENDI (SOURCE)
"It is settled law that this court will not normally interfere with the concurrent findings of the two lower courts unless there is some miscarriage of justice or a violation of some principles of law or procedure."
EXPLANATION / SCOPE
This reinforces the concurrent findings doctrine (Principles 216, 248, 283, 380, 402). Supreme Court interference with concurrent findings requires showing: (1) miscarriage of justice—incorrect outcome causing substantial injustice; (2) violation of legal principles—misapplication of law; or (3) violation of procedure—breach of procedural rules affecting fairness. “Normally interfere” indicates the general rule—deference unless exceptional circumstances. The exceptions permit interference when: findings produce unjust results, legal errors taint findings, or procedural irregularities affect reliability. This high threshold serves: finality (double concurrence creates strong presumption), judicial efficiency, and respecting lower courts’ fact-finding roles. “Miscarriage of justice” is serious—not merely that Supreme Court might have decided differently, but that allowing findings to stand would produce substantially unjust outcome. The concurrent findings doctrine is among Nigerian jurisprudence’s most firmly established principles, consistently applied to prevent endless fact re-litigation while preserving Supreme Court oversight for fundamental errors.