Ratio Decidendi

Per Rhodes-Vivour, JSC, in Ogudo v. State (2011) NLC-123-341-2010(SC) at p. 10; Paras A—B:

"Relying on an unsigned retracted confessional statement calls for extreme caution and very little or no weight should be attached to such a statement. After all an unsigned document is worthless. See section 91 of the Evidence Act."

Explanation / Scope

This principle establishes that an unsigned retracted confessional statement attracts very little or no weight, as an unsigned document is worthless. The principle applies where unsigned confessions are relied upon. It ensures that such statements are treated with caution. The principle reflects the requirement for signatures. It prevents reliance on unsigned documents. The court must attach little or no weight. The principle provides guidance on unsigned confessions.

Cases Applying This Principle