Principle Statement

Record of proceedings is the only indication of what took place in a court; it is not like minutes of a meeting; it is always the final reference of events, step by step, that took place in court.

Ratio Decidendi (Source)

Per Oguntade, JSC, in Ogidi & Ors v. State (2005) NLC-2032003(SC) at p. 9; Paras B–C.

"Record of proceedings is the only indication of what took place in a court; it is not like minutes of a meeting; it is always the final reference of events, step by step, that took place in court."

Explanation / Scope

The record of proceedings is the definitive, step-by-step account of court events. It serves as the final reference for what transpired. The principle applies to constitutional law and judicial procedure. The rule establishes the record’s primacy over memory or speculation. The record is not merely minutes but an authoritative chronicle. Parties and courts rely on the record as the authentic account.

Cases Applying This Principle