LEGAL PRINCIPLE: CRIMINAL LAW – Rape – Admission of Offence to Third Party – Whether May Constitute Corroboration
PRINCIPLE STATEMENT
Admission of an offence by an accused person to other persons may amount to sufficient corroboration in law. So in R. v. Francis Kufi (1960) WNLR 1, the accused was charged with indecent assault against a young girl of 10 years. It was held, and rightly in my view, that the admission of the offence by the accused to the father of the girl was sufficient corroboration in law.
RATIO DECIDENDI (SOURCE)
"Admission of an offence by an accused person to other persons may amount to sufficient corroboration in law. So in R. v. Francis Kufi (1960) WNLR 1, the accused was charged with indecent assault against a young girl of 10 years. It was held, and rightly in my view, that the admission of the offence by the accused to the father of the girl was sufficient corroboration in law."
EXPLANATION / SCOPE
An accused’s admission of an offence to a third party can constitute sufficient corroboration in law. The admission must be voluntary and relate to the offence charged. The third party’s testimony is independent evidence connecting the accused to the crime. In R. v. Francis Kufi, the accused’s admission to the victim’s father was held sufficient corroboration for indecent assault. The principle applies to rape and other sexual offences. The admission need not be a full confession—acknowledging the act suffices. The weight of the admission depends on the circumstances. The judge must warn of the danger of relying on admissions. The admission must be proved by independent evidence. The principle recognises that admissions against interest are reliable.
