CRIMINAL LAW ā Corroboration in Rape Cases ā Practice Direction ā Whether Corroboration Required in Law
Principle Statement
Corroboration is not a rule of law that an accused person in a charge of rape cannot be convicted on the uncorroborated evidence of the prosecutrix.
Ratio Decidendi (Source)
Per Ogbuagu, JSC, in Ogunbayo v. State (2007) NLC-123-272-2005(SC) at p. 11; Paras DāE.
"Corroboration is not a rule of law that an accused person in a charge of rape, cannot be convicted on the uncorroborated evidence of the prosecutrix."
Explanation / Scope
This principle establishes that corroboration is not a legal requirement for conviction in rape cases. A conviction can validly rest on the uncorroborated testimony of the prosecutrix if the court is satisfied of her credibility. The rule requiring corroboration was a practice direction, not a rule of law. The court must still exercise caution and carefully evaluate the prosecutrix’s evidence, but the absence of corroboration does not automatically invalidate the conviction. The principle reflects modern judicial thinking that treats sexual offence victims like other witnesses. The court considers the totality of evidence and warns itself of the danger of convicting solely on uncorroborated testimony.