Principle Statement

The usual method of proving a public document is by the production of a certified copy of it. Once it is certified as such copy, it is unnecessary to call a witness to verify it.

Ratio Decidendi (Source)

Per Oguntade, JSC, in Orlu v. Gogo-Abite (2010) NLC-123-234-2002(SC) at pp. 21–22; Paras D–A.

"The usual method of proving a public document is by the production of a certified copy of it. Once it is certified as such copy, it is unnecessary to call a witness to verify it."

Explanation / Scope

This principle establishes that certified copies of public documents prove themselves without the need for a witness to verify them. The principle applies where public documents are tendered. It ensures that public documents are easily proved. The principle reflects the evidentiary rule on public documents. It prevents unnecessary calling of witnesses. The court must accept certified copies. The principle provides guidance on proving public documents.

Cases Applying This Principle