Ratio Decidendi

Per Adekeye, JSC, in Okonkwo & Ors v. Okonkwo & Ors (2010) NLC-123-296-2003(SC) at p. 19, paras. D–E:

"The Supreme Court will not ordinarily disturb concurrent findings of fact made by the High Court and the Court of Appeal unless a substantial error apparent on the face of the record of proceedings is shown or when such findings are perverse."

Explanation / Scope

This principle establishes that the Supreme Court will not ordinarily disturb concurrent findings of fact unless a substantial error is apparent on the record or the findings are perverse. The principle applies where concurrent findings are challenged. It ensures that findings are respected. The principle reflects the limited scope of appellate review. It prevents unnecessary interference. The court must find an exception. The principle provides guidance on when the Supreme Court will interfere with concurrent findings.

Cases Applying This Principle