EVIDENCE LAW — Documentary Evidence — Clear and Unambiguous Document — Admissibility of Extrinsic Evidence
Principle Statement
Where a document is clear and unambiguous, parole evidence cannot be led to contradict it. In other words, extrinsic evidence is basically inadmissible to add to or alter the contents of a document.
Ratio Decidendi (Source)
Per Ogbuagu, JSC, in Baliol Nigeria Ltd v. Navcon Nigeria Ltd (2010) NLC-123-57-2003(SC) at p. 6; Paras A–B.
"Where a document is clear and unambiguous, parole evidence cannot be led to contradict it. In other words, extrinsic evidence is basically inadmissible to add to or alter the contents of a document."
Explanation / Scope
This principle establishes that extrinsic evidence is inadmissible to contradict, add to, or alter a clear and unambiguous document. The principle applies in evidence law. It ensures that documents speak for themselves. The principle reflects the parole evidence rule. It prevents parties from challenging clear documents with oral evidence. The court must determine if the document is clear and unambiguous. The principle provides guidance on the admissibility of extrinsic evidence.
