PRINCIPLE STATEMENT

The Supreme Court does not interfere with concurrent findings of the lower courts except where exceptional circumstances why it should do so are shown.

RATIO DECIDENDI (SOURCE)

Per Adio, JSC, in Elf Nigeria Ltd v. Sillo (1994) NLC-511992(SC) at p. 21; Para A.
"This court does not interfere with concurrent findings of the lower courts except where exceptional circumstances why it should do so are shown."
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EXPLANATION / SCOPE

Concurrent findings—factual findings affirmed by both trial and appellate courts—receive heightened deference from the Supreme Court. The double agreement creates a strong presumption of correctness. “Exceptional circumstances” justifying interference include: findings unsupported by any evidence, perversity (no reasonable tribunal could reach such findings), misapplication of law to facts, or violation of legal principles. Mere disagreement with the conclusion or alternative interpretation of evidence doesn’t constitute exceptional circumstances. This deference reflects: (1) trial courts’ advantage in assessing witness credibility; (2) appellate courts’ review confirming trial findings; (3) finality interests—endless re-examination wastes resources. The Supreme Court focuses on legal principles rather than fact-finding. This high threshold for interference promotes finality and efficient use of Supreme Court resources for jurisprudential development.

CASES APPLYING THIS PRINCIPLE