CRIMINAL LAW ā Confessional Statement ā Sufficiency for Conviction ā Voluntary Confession Direct and Positive
Ratio Decidendi
Per Kastina-Alu, JSC, in Dibie v. State (2007) NLC-123-103-2005(SC) at p. 11; Paras DāE:
"Once a confession of guilt is shown to have been made freely and voluntarily, be it judicial or extra-judicial, if it is direct, positive and properly established, it constitutes proof of guilt and is enough to sustain a conviction so long as the court is satisfied as to its truth."
Explanation / Scope
A voluntary confession, whether judicial or extra-judicial, can alone sustain a conviction. The confession must be direct and positive as to guilt, and the court must be satisfied it is true and reliable. The confession must be properly established, often through evidence of voluntariness. No corroboration is required if these criteria are met.