CRIMINAL LAW — Corroboration — Definition and Nature of Corroborative Evidence
Principle Statement
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.
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
This principle defines corroborative evidence in criminal law. Corroboration must be independent of the witness it seeks to support—not derived from the same source. It must confirm the offence and the accused’s participation. The evidence can be direct or circumstantial. It must relate to a material particular, not trivial details. The purpose is to strengthen or confirm the testimony being corroborated. The principle ensures that corroboration adds weight and reliability. It applies in cases where corroboration is legally required or prudentially sought. The court must identify the independent nature of the corroborative evidence.
