CRIMINAL LAW — Proof Beyond Reasonable Doubt — Standard Not Meaning Proof Beyond Any Shadow of Doubt
Ratio Decidendi
Per Tobi, JSC, in Dibie v. State (2007) NLC-123-103-2005(SC) at p. 18; Paras C–D:
"Proof beyond reasonable doubt does not mean proof beyond any shadow of doubt. Once the proof drowns the presumption of innocence of the accused, the court is entitled to convict him, although there could exist shadows of doubt."
Explanation / Scope
The prosecution’s burden is proof beyond reasonable doubt, not proof beyond all doubt. Reasonable doubt is a practical standard, not a speculative one. The court can convict if the evidence is so strong that it overwhelms the presumption of innocence. Mere possibility or fanciful doubt is insufficient to acquit. The standard does not require absolute certainty, but a high degree of probability.