PRINCIPLE STATEMENT

Where a trial court accepts and believes the evidence of a single eyewitness, it is entitled to convict on that evidence alone; except where specifically provided by law, no particular number of witnesses is required for proof of any fact.

RATIO DECIDENDI (SOURCE)

Per Kutigi, JSC, in Njoku v. The State (1993) NLC-2091991(SC) at p. 16; Paras C–E.
"The trial court having accepted and believed the evidence of P.W.1 was entitled to proceed to convict the appellant on his (P.W.1) evidence alone. The law is that except where it is specifically provided by law, no particular number of witnesses shall in any case be required for the proof of any fact."
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EXPLANATION / SCOPE

One credible witness suffices for conviction unless statute requires corroboration (certain sexual offenses, accomplice testimony in some jurisdictions). Quality, not quantity, determines evidential sufficiency. Courts assess the single witness’s credibility, opportunity to observe, and consistency. If believed, their testimony alone can prove guilt beyond reasonable doubt. This prevents guilty persons escaping due to lack of multiple witnesses while requiring courts to carefully scrutinize single-witness cases. The principle applies to all facts requiring proof—identity, elements of offense, defenses. However, where the sole witness has credibility issues or the evidence is inherently weak, courts should be cautious about convicting without corroboration.

CASES APPLYING THIS PRINCIPLE