Ratio Decidendi

Per Oguntade, JSC, in Yaro v. State (2007) NLC-123-244-2004(SC) at pp. 12–13; Pars D–E:

"A voluntary confession of guilt, if it be fully consistent and probable, is justly regarded as evidence of the high test and most satisfactory whenever there is independent proof that a criminal act has been committed by someone."
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Explanation / Scope

A confessional statement, where freely and voluntarily made and judicially proved, constitutes strong evidence against the accused. The court must be satisfied that the confession is consistent with the facts and probable in the circumstances. Additionally, the prosecution must adduce independent evidence corroborating the commission of the offence (corpus delicti) — that is, proof that the crime was actually committed by someone, even if the confession is the primary evidence identifying the accused as the perpetrator. The court must also ensure the confession was not obtained through oppression, inducement, or coercion.

Cases Applying This Principle

Musa Yaro v. The State