PRINCIPLE STATEMENT

When any judgment of any court or any other judicial or official proceedings has been reduced to the form of a document or series of documents, no evidence may be given of such judgment or proceedings except the document itself, nor may the contents of such document be contradicted, altered, added to or varied by oral evidence.

RATIO DECIDENDI (SOURCE)

Per Onu, JSC, in Shyllon v. Asein (1994) NLC-1101989(SC) at p. 27; Paras. C–D.
"When any judgment of any court or any other judicial or official proceedings...has been reduced to the form of a document or series of documents, no evidence may be given of such judgment or proceedings... except the document itself... or may the contents of such document be contradicted, altered, added to or varied by oral evidence."
View Judgment

EXPLANATION / SCOPE

This extends Principle 423 to judicial and official proceedings. Documentary judicial records are conclusive—oral evidence cannot: prove different terms, contradict contents, alter what’s recorded, add to the record, or vary documented proceedings. This applies to: judgments, court proceedings, and official proceedings reduced to documentary form. The rule serves: finality of recorded proceedings, preventing false testimony about judicial acts, and protecting judicial record integrity. “Except the document itself” means: the document is primary evidence, secondary evidence admissible only when primary unavailable (see Section 132 Evidence Act), and oral testimony cannot substitute for or contradict documentary record. This prevents: parties claiming proceedings differed from record, witnesses testifying about different judgment terms, or attempts to vary recorded judicial acts through testimony. The documentary record is authoritative and conclusive. Exceptions (like fraud, mistake) follow general documentary evidence exceptions but are narrowly applied to judicial records given their official nature and importance. This principle reinforces documentary supremacy over oral evidence for judicial and official proceedings.

CASES APPLYING THIS PRINCIPLE