LEGAL PRINCIPLE: EVIDENCE LAW — Documentary Evidence — Oral Evidence Cannot Vary Contents of a Document
PRINCIPLE STATEMENT
When any judgment, official proceeding, contract, or disposition of property has been reduced to a document, no evidence may be given of its terms except the document itself. The contents of such document cannot be contradicted, altered, added to, or varied by oral evidence.
RATIO DECIDENDI (SOURCE)
Per Pats-Acholonu, JSC, in Adecentro (Nigeria) Ltd v. Council of Obafemi Awolowo University (2005) NLC-332000(SC) at p. 12; Paras A–B.
"When any judgment of any court or any other judicial or official proceedings or any contract, or any grant or other disposition of property has been reduced to the form of a document or series of documents, no evidence may be given of such judgment or proceedings, or of the terms of such contract, grant or disposition of property except the document itself… nor may the contents of any such document be contradicted, altered, added to or varied by oral evidence…"
EXPLANATION / SCOPE
The parol evidence rule prohibits oral evidence to vary, contradict, or add to written documents. The document itself is the exclusive evidence of its terms. The principle applies to evidence law. The rule preserves the integrity of written agreements and official records. Exceptions exist for fraud, mistake, or ambiguity. Oral evidence cannot alter clear documentary terms.
