LEGAL PRINCIPLE: EVIDENCE LAW – Admissions – Effect of Admissions in Pleadings – No Further Proof Required
PRINCIPLE STATEMENT
A fact admitted by the defendants requires no further proof of its truth; they are bound by it, and the trial court is justified in acting on it.
RATIO DECIDENDI (SOURCE)
Per Ogwuegbu, JSC, in Adeye & Ors v. Adesanya & Ors (2001) NLC-1181995(SC) at p. 7; Paras A–B.
"Fact is admitted by the defendants, no further proof of its truth was required and they are bound by it and the trial court was justified in acting on it. This court will not also countenance any argument of the defendants to the effect that the trial court or the court below did not evaluate the evidence relating to such admitted fact."
EXPLANATION / SCOPE
An admission in pleadings is binding on the party making it. No further proof of the admitted fact is required. The court is justified in acting on the admission without evaluating evidence on that point. The party who made the admission cannot later complain that the court did not evaluate evidence on the admitted fact. The principle is derived from Section 75 of the Evidence Act (what is admitted needs no proof). The rule promotes judicial efficiency by eliminating the need to prove uncontested facts. Admissions may be express or implied from failure to traverse. The party is estopped from contradicting the admission. The principle applies to both plaintiffs and defendants.