LEGAL PRINCIPLE: CRIMINAL LAW — Homicide — Causation — Prosecution Must Prove Act of Accused Caused Death With Certainty
PRINCIPLE STATEMENT
To establish a charge of murder or manslaughter, it must be proved not merely that the act of the accused person could have caused the death of the deceased, but that it did.
RATIO DECIDENDI (SOURCE)
Per Uwaifo, JSC, in Aiguobaruoghian & Anor v. State (2004) NLC-2942002(SC) at p. 21; Paras A–B.
"To establish a charge of murder or manslaughter, it must be proved not merely that the act of the accused person could have caused the death of the deceased, but that it did."
EXPLANATION / SCOPE
Possibility is insufficient in homicide cases; the prosecution must prove actual causation beyond reasonable doubt. The standard is not whether the accused’s act could have caused death, but whether it did cause death. This serves ensuring that conviction follows only from proven fact, not mere speculation or probability. The court cannot convict based on evidence showing only that the accused’s act was a possible cause of death, where other causes remain plausible. Certainty of causation is the constitutional minimum for criminal conviction.