LEGAL PRINCIPLE: APPELLATE PRACTICE – Concurrent Findings of Fact – Interference by Supreme Court – Exceptional Circumstances Required
PRINCIPLE STATEMENT
For such findings to be interfered with by this court, exceptional circumstances must be shown by the appellants.
RATIO DECIDENDI (SOURCE)
Per Ejiwunmi, JSC, in Echi & Ors v. Nnamani & Ors (2000) NLC-1271994(SC) at p. 7; Paras D–E.
"For such findings to be interfered with by this court, exceptional circumstances must be shown by the appellants."
EXPLANATION / SCOPE
The Supreme Court requires exceptional circumstances to interfere with concurrent findings of fact by lower courts. Mere disagreement or possibility of different conclusion is insufficient. The appellant must demonstrate manifest error, perversity, or miscarriage of justice. This high threshold respects the fact-finding roles of trial and intermediate appellate courts. Concurrent findings carry great weight because two courts independently reached the same conclusion. The principle promotes finality and prevents endless factual re-litigation. Exceptional circumstances include ignoring material evidence, drawing wrong inferences, or applying wrong legal principles.