LEGAL PRINCIPLE: CRIMINAL LAW – Evidence – Circumstantial Evidence – When Court May Convict on Circumstantial Evidence
PRINCIPLE STATEMENT
When strong circumstantial evidence is led against an accused person in a criminal trial and this gives rise to the drawing of a presumption or inference irresistibly warranted by such evidence, the criminal court will not hesitate to draw such a presumption or inference so long as it is so cogent and compelling as to convince the jury that on no rational hypothesis other than the inference can the facts be accounted for.
RATIO DECIDENDI (SOURCE)
Per Iguh, JSC, in Adeniji v. State (2001) NLC-2101999(SC) at p. 17; Paras B–C.
"When strong circumstantial evidence is led against an accused person in a criminal trial and this gives rise to the drawing of a presumption or inference irresistibly warranted by such evidence, the criminal court will not hesitate to draw such a presumption or inference so long as it is so cogent and compelling as to convince the jury that on no rational hypothesis other than the inference can the facts be accounted for."
EXPLANATION / SCOPE
Conviction on circumstantial evidence is permissible where the evidence is so cogent and compelling that no rational hypothesis other than guilt can account for the facts. The inference of guilt must be irresistible. The court must ensure that the circumstances exclude any reasonable possibility of innocence. The evidence must be strong, not merely suspicious. The principle requires that the cumulative effect of circumstances leads inexorably to guilt. Each piece need not individually prove guilt, but collectively they must form an unbroken chain. The court must guard against drawing inferences that are not logically compelled. The standard is proof beyond reasonable doubt. The circumstantial evidence must be consistent only with guilt.