CRIMINAL LAW — Burden of Proof — Proof Beyond Reasonable Doubt — Standard Defined
Ratio Decidendi
Per Ogbuagu, JSC, in Afolalu v. State (2010) NLC-123-193-2008(SC) at p. 8, paras. A–C:
"Proof beyond reasonable doubt, is not proof beyond shadow of doubt. It is not, therefore, a proof beyond all possible or imaginary doubt that it is such proof as precludes every reasonable hypothesis except that which it tends to support. It is proof to moral certainty, such proof as satisfies the judgment and conscience of the judge as a reasonable man, and applying his reason to the evidence before him that the crime charged has been committed by the defendant and so satisfies him as to leave no other reasonable conclusion possible."
Explanation / Scope
This principle defines proof beyond reasonable doubt as proof to moral certainty, not proof beyond all possible or imaginary doubt. It must preclude every reasonable hypothesis except guilt. It must satisfy the judgment and conscience of a reasonable judge, leaving no other reasonable conclusion possible. The principle applies in all criminal trials. It ensures that the standard is properly understood. It prevents acquittals based on fanciful possibilities. The burden remains on the prosecution. The court must apply this standard in assessing evidence. The principle provides guidance on the meaning of proof beyond reasonable doubt.