LEGAL PRINCIPLE: CRIMINAL LAW – Confessional Statements – Conviction on Confession Alone
PRINCIPLE STATEMENT
In Nigeria, a free and voluntary confession of guilt, if direct and positive and duly made and satisfactorily proved, is sufficient to warrant conviction without corroborative evidence, so long as the court is satisfied of the truth of the confession.
RATIO DECIDENDI (SOURCE)
Per Ogwuegbu, JSC, in Effiong v. State (1998) NLC-1441997(SC) at p. 8; Paras B–C.
"In Nigeria, a free and voluntary confession of guilt by a prisoner, whether under examination before a magistrate or otherwise, if it is direct and positive and is duly made and satisfactorily proved, is sufficient to warrant conviction without any corroborative evidence so long as the court is satisfied of the truth of the confession."
EXPLANATION / SCOPE
A voluntary, direct, and positive confession alone can sustain conviction. Corroboration is not required. The principle applies to criminal trials. The court must be satisfied of the truth. The rule is well-established. The judge must test the confession. The principle is fundamental.