APPELLATE PRACTICE — Evaluation of Evidence — Appellate Court Will Not Substitute Own Views for Trial Court’s Findings
Ratio Decidendi
Per Edozie, JSC, in Ezukwu v. Chukwu & Anor (2004) NLC-1602000(SC) at p. 19; Paras C–D:
"Besides it is settled law that where a trial court unquestionably evaluates the evidence and appraises the facts, it is not the business of an appellate court to substitute its own views for the views of the trial court. As this court held in the case of Odofin v. Ayoola (1984) 11 SC 72 per Oputa, JSC: 'if there is any evidence to support a particular conclusion of the trial court, an appellate court which could have come to a different conclusion on the same evidence should restrain itself and respect the conclusion of the trial court that saw, heard and believed.'"
Explanation / Scope
Appellate courts defer to trial court findings based on evidence evaluation and credibility assessment. Substitution of views is not permitted where evidence supports the conclusion. The principle applies to appellate practice. The rule respects the trial court’s advantage of seeing and hearing witnesses. Different possible conclusions do not justify interference. The appellate court must uphold findings supported by evidence.