LEGAL PRINCIPLE: APPELLATE PRACTICE – Concurrent Findings of Fact – Interference by Supreme Court – When Justified
PRINCIPLE STATEMENT
Needless to say that those concurrent findings and inference of grant made by the two lower courts which have not been dented by the appellants in this court ought not ordinarily be interfered with or reversed by the Supreme Court more so when those findings are reasonably justified and supported by evidence given in the case and no special circumstances, showing obvious or palpable errors in the current findings have been established in the interest of justice to do so.
RATIO DECIDENDI (SOURCE)
Per Achike, JSC, in Chikere & Ors v. Okegbe & Ors (2000) NLC-261995(SC) at p. 11; Paras A–B.
"Needless to say that those concurrent findings and inference of grant made by the two lower courts which have not been dented by the appellants in this court ought not ordinarily be interfered with or reversed by the Supreme Court more so when those findings are reasonably justified and supported by evidence given in the case and no special circumstances, showing obvious or palpable errors in the current findings have been established in the interest of justice to do so."
EXPLANATION / SCOPE
The Supreme Court will not ordinarily interfere with concurrent findings of fact by lower courts if they are reasonably justified by evidence and not dented by the appellant. Special circumstances—such as obvious or palpable errors—must be established to justify interference. Concurrent findings carry great weight because two courts have independently reached the same factual conclusions. The appellant bears the burden of demonstrating manifest error or miscarriage of justice. This principle promotes finality and respects the fact-finding roles of lower courts.