LEGAL PRINCIPLE: APPELLATE PRACTICE – Concurrent Findings – Interference by Supreme Court
PRINCIPLE STATEMENT
This is a case where concurrent findings of the trial court and Court of Appeal should not be interfered with as they are fully supported by evidence and there is no substantial error on the face of proceedings to show they are perverse or patently erroneous or that miscarriage of justice will result if they are allowed to stand.
RATIO DECIDENDI (SOURCE)
"It is clear that this is a case where concurrent findings of the trial court and the court below should not be interfered with as they are fully supported by evidence and there is no substantial error on the face of the proceedings to show that they are perverse or patently erroneous or that a miscarriage of justice will result if they are allowed to stand. See Chinwendu v. Mhamali (1980) 3-4 S.C. 31 at 75; Lamai v. Orbih (1980) 5-7 S.C. 28; Ibodo v. Enarofia (1980) 5-7 S.C. 42; Woluchem v. Gudi (1981) 5 S.C. 291 at 326; Kale v. Coker (1982) 12 S.C. 252; Lokoyi v. Olojo (1983) 2 SCNLR 127 at 131; and Igwego v. Ezeugo (1992) 6 NWLR (Pt.249) 561 at 585."
EXPLANATION / SCOPE
This reinforces the concurrent findings doctrine (Principles 216, 248, 283, 380). Supreme Court interference requires showing: findings unsupported by evidence, substantial error apparent on the record, perversity (no reasonable tribunal could reach such findings), patent error (obvious mistakes), or miscarriage of justice would result from upholding findings. When concurrent findings are: supported by evidence, free from substantial error, reasonable, and produce just results, the Supreme Court defers. The multiple case citations demonstrate this principle’s consistent application over decades. “Substantial error” means significant mistakes affecting outcome, not trivial errors. “Patently erroneous” means obviously wrong on the face of the record. The principle balances: finality (double agreement creates strong presumption), judicial efficiency (preventing endless fact re-examination), respect for lower courts (who heard evidence), against Supreme Court’s oversight responsibility (correcting fundamental errors). This high bar for interference ensures concurrent findings stand unless clearly wrong.