LEGAL PRINCIPLE: CRIMINAL LAW — Defences — Alibi — Duty of Accused to Disclose Particulars
PRINCIPLE STATEMENT
The accused must disclose the facts of the alibi with necessary details and particulars at the earliest opportunity to put the burden on the police to check on them; otherwise, the police cannot be expected to go on a wild goose chase.
RATIO DECIDENDI (SOURCE)
Per Uwaifo, JSC, in Eyisi & Ors v. State (2000) NLC-1601999(SC) at p. 51; Paras A–C.
"The facts of the alibi are known to him and such witnesses as may be available. He should therefore disclose them with necessary details and particulars at the earliest opportunity so as to put the burden on the police to check on them and deal with them with some finality. If he does not, the police cannot be expected to go on a wild goose chase."
EXPLANATION / SCOPE
An alibi defence must be particularised with specific details: where the accused was, at what time, with whom, and any supporting evidence. The accused knows these facts. Vague or general assertions are insufficient. The police cannot be expected to investigate without concrete leads—they are not required to go on a “wild goose chase.” The burden to provide particulars is on the accused. The principle prevents accused persons from raising vague alibis without any basis. If sufficient particulars are provided, the police must investigate. Failure to investigate a properly raised alibi may weaken the prosecution’s case. The rule ensures that alibi defences are genuine and verifiable.