PRINCIPLE STATEMENT

A block verdict in respect of the same count is not necessarily fatal so long as it is clear what the verdict is and against whom it is made; ideally, it should refer to each accused individually.

RATIO DECIDENDI (SOURCE)

Per Uwaifo, JSC, in Eyisi & Ors v. State (2000) NLC-1601999(SC) at p. 49; Paras B–D.
"A block verdict in respect of the same count is not necessarily fatal so long as it is clear what the verdict is and against whom it is made. Ideally, it is advisable to give the verdict, even on such a count, in a way that it referred to every one of the accused persons. This can simply be done by adding the word 'each' appropriately. Although, that was not done in this case, the verdict and sentence are unmistakable that they refer to each accused person."
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EXPLANATION / SCOPE

A block verdict (pronouncing guilt collectively) is not necessarily fatal if it is clear what the verdict is and against whom it is made. The preferred practice is to refer to each accused individually, e.g., by adding the word “each.” However, the absence of individual reference does not invalidate the conviction if the intent is unmistakable. The appellate court will examine the entire record to determine whether each accused was properly found guilty. The principle applies the substantial justice rule. The verdict must be unambiguous. If the record clearly shows that the trial court convicted each accused, the block pronouncement is not fatal. The rule prevents technical reversals where substantial justice was done.

CASES APPLYING THIS PRINCIPLE

None recorded.