LEGAL PRINCIPLE: APPELLATE PRACTICE – Interference with Findings of Fact – Principles Governing
PRINCIPLE STATEMENT
Unless findings of fact are perverse, or based on inadmissible evidence, or based on no evidence before court or based on unreasonable conclusions, the appellate court should not interfere.
RATIO DECIDENDI (SOURCE)
"Unless findings of fact are perverse, or based on inadmissible evidence, or based on no evidence before court or based on unreasonable conclusions, the appellate court should not interfere."
EXPLANATION / SCOPE
This succinctly states appellate interference standard (see Principles 216, 248, 283, 313, 348, 359, 380, 402, 424, 441, 461-462, 487). Appellate courts interfere with fact findings only when: (1) Perverse: No reasonable tribunal could reach such finding—fundamentally unreasonable. (2) Based on inadmissible evidence: Finding rests on evidence that shouldn’t have been admitted—violates evidence rules. (3) Based on no evidence: Finding lacks any evidentiary support—no evidence at all to support it. (4) Based on unreasonable conclusions: Conclusions drawn from evidence are unreasonable—irrational inferences. These are exceptional circumstances justifying interference. General rule: Appellate courts defer to trial court findings—don’t reassess evidence, don’t substitute their views, and respect trial court’s fact-finding role. This serves: respecting trial court advantage (seeing/hearing witnesses), maintaining appellate/trial court roles, and promoting finality. “Should not interfere” means: strong presumption against interference, high threshold for intervention, and deference as default position. Only when findings fall into enumerated exceptional categories should interference occur. This prevents: appellate courts becoming courts of first instance, endless fact re-litigation, and undermining trial courts’ fact-finding function. The four categories capture: perversity (finding no reasonable tribunal would make), evidentiary defects (inadmissible evidence or no evidence), and reasoning defects (unreasonable conclusions). This succinct formulation provides clear framework for appellate review of fact findings.
CASES APPLYING THIS PRINCIPLE
None recorded.