PRINCIPLE STATEMENT

Voluntary confessions are deemed to be relevant facts as against only the persons who make them. They are not ordinarily evidence against co-accused persons.

RATIO DECIDENDI (SOURCE)

Per Onu, JSC, in Idowu v. State (1998) NLC-1751997(SC) at p. 20; Paras B–C.
"Voluntary confessions are deemed to be relevant facts as against only the persons who make them. They are not ordinarily evidence against co-accused persons."
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EXPLANATION / SCOPE

A confession is only evidence against the maker. It cannot be used against a co-accused. The principle applies to criminal trials. The prosecution cannot rely on one accused’s confession to convict another. The rule protects co-accused from hearsay. The exception is where the confession implicates the co-accused and is made jointly. The principle is well-established.

CASES APPLYING THIS PRINCIPLE