LEGAL PRINCIPLE: EVIDENCE LAW – Admissibility of Evidence – Judgments in Suits Involving Strangers
PRINCIPLE STATEMENT
Judgments were clearly pleaded as required by law and therefore properly tendered in evidence even though the present plaintiffs were not parties; the High Court acted properly when it admitted the documents (judgments) in evidence.
RATIO DECIDENDI (SOURCE)
"The judgments were clearly pleaded as required by law and therefore properly tendered in evidence by Philip Okongwu (P. W.5) who was from Isu village (a party in that suit) even though the present plaintiffs were not parties... The High court therefore acted properly when it admitted the documents (judgments) in evidence."
EXPLANATION / SCOPE
Judgments in suits between third parties can be admissible if properly pleaded, even when current litigants were not parties to those earlier suits. Requirements for admissibility: (1) Proper pleading of the judgment; (2) Tender by someone with knowledge or connection to the earlier suit; (3) Relevance to current proceedings. However, admissibility differs from evidential weight and binding effect. Such judgments are admissible to show: the judgment was given, what issues were decided, or as evidence of facts judicially determined (subject to limits). But they don’t bind non-parties through res judicata. The judgment’s weight depends on: relevance to current issues, whether parties/issues overlap, and reliability. Here, the judgment was admissible because properly pleaded and tendered by someone from the village party to the earlier suit, even though current plaintiffs weren’t parties. This allows historical evidence about land or property disputes to be considered while respecting that non-parties aren’t bound by earlier judgments.