CRIMINAL LAW — Corroboration — Definition and Nature of Corroborative Evidence
Principle Statement
Corroborative evidence must be independent testimony, whether direct or circumstantial, which confirms in some material particular not only that an offence has been committed, but also that the accused person committed it.
Ratio Decidendi (Source)
Per Ogbuagu, JSC, in Ogunbayo v. State (2007) NLC-123-272-2005(SC) at p. 11; Paras A–C.
"Evidence in corroboration, must be an independent testimony, direct or circumstantial, which confirms in some material particular, not only that an offence has been committed, but that the accused person has committed it."
Explanation / Scope
The principle defines the essential characteristics of corroborative evidence. Corroboration is independent evidence that supports or confirms the testimony of a witness. It must come from a source independent of the witness whose evidence it seeks to corroborate, meaning it cannot be sourced from the same witness. It may be direct or circumstantial, but it must connect the accused person to the commission of the offence. It is not enough that the evidence shows that an offence occurred; it must also point to the accused as the perpetrator. Corroborative evidence need not confirm every detail of the witness’s testimony; it is sufficient if it confirms a material particular. The principle ensures that corroboration is meaningful and capable of strengthening the prosecution’s case. It prevents reliance on evidence that merely repeats the witness’s testimony without independent value.
