LEGAL PRINCIPLE: CRIMINAL LAW – Confessional Statement – Nature of Confession – Admission of Act Causing Death
PRINCIPLE STATEMENT
From the facts disclosed in Exhibit '1 ', the evidence of the accused on oath at the trial and the evidence of the prosecution witnesses, I have no doubt in my mind that the victim died as a direct result of the voluntary act of the accused and the learned trial judge and the court below came to a right conclusion. It is therefore immaterial to me in the determination of this appeal whether Exhibit '1' is a confessional statement of the offence of murder or not.
RATIO DECIDENDI (SOURCE)
Per Ogwuegbu, JSC, in Uluebeka v. State (2000) NLC-341999(SC) at p. 8; Paras A–B.
"From the facts disclosed in Exhibit '1 ', the evidence of the accused on oath at the trial and the evidence of the prosecution witnesses, I have no doubt in my mind that the victim died as a direct result of the voluntary act of the accused and the learned trial judge and the court below came to a right conclusion. It is therefore immaterial to me in the determination of this appeal whether Exhibit '1' is a confessional statement of the offence of murder or not."
EXPLANATION / SCOPE
Characterising a statement as a confession is not determinative where other evidence clearly proves the accused’s voluntary act caused death. Even if the statement is not strictly a confession, the totality of evidence—including the accused’s testimony and prosecution witnesses—may independently establish guilt. The court focuses on substance over label. The key question is whether the evidence proves the accused caused death voluntarily. Technical classification of statements is secondary to the probative value of all evidence. This pragmatic approach prevents acquittal on technical classification where guilt is clearly proved.