LEGAL PRINCIPLE: CRIMINAL LAW — Confession — Confession Alone Without Corroboration — Whether Can Support Conviction
PRINCIPLE STATEMENT
The secrecy with which criminals perpetrate crime has deprived the prosecution of eyewitnesses in some cases; hence confession alone, even without corroboration, can support a conviction as long as the court is satisfied of its truth.
RATIO DECIDENDI (SOURCE)
Per Onu, JSC, citing Achabua v. The State (1976) 12 SC 63 at 68, in Emeka v. State (2001) NLC-72000(SC) at p. 11; Paras A–B.
"...the secrecy with which criminals perpetuate crime has tended to deprive the prosecution in some cases of eye-witnesses, hence confession alone even without corroboration can support a conviction as long as the court is satisfied of the truth."
EXPLANATION / SCOPE
Confession alone can sustain a conviction without corroboration if the court is satisfied of its truth. The principle recognises the practical reality that crimes are often committed in secrecy, making eyewitnesses rare. The accused’s own admission is powerful evidence. The court must be satisfied that the confession is voluntary, direct, positive, and true. Corroboration is desirable but not mandatory. The judge must carefully test the confession against external circumstances. The rule is well-established in Nigerian law. The principle balances the need for reliable evidence with the realities of criminal investigation. It does not lower the standard of proof—the court must still be satisfied beyond reasonable doubt.