LEGAL PRINCIPLE: EVIDENCE LAW – Confession – Whether Sufficient Without Corroboration
PRINCIPLE STATEMENT
The law is firmly settled that a free and voluntary confession which is direct and positive and properly proved is sufficient to sustain a conviction without any corroborative evidence, so long as the court is satisfied with its truth. It must, however, be stressed that there is a duty on a trial judge to test the truth of a confession by examining it in the light of the other credible evidence before the court.
RATIO DECIDENDI (SOURCE)
Per Iguh, JSC, in Akinmoju v. State (2000) NLC-11999(SC) at p. 20; Paras A–B.
"The law is firmly settled that a free and voluntary confession which is direct and positive and properly proved is sufficient to sustain a conviction without any corroborative evidence, so long as the court is satisfied with its truth. It must, however, be stressed that there is a duty on a trial judge to test the truth of a confession by examining it in the light of the other credible evidence before the court."
EXPLANATION / SCOPE
A free, voluntary, direct, and positive confession can sustain a conviction without corroboration if the court is satisfied of its truth. However, trial judges must test the confession against other credible evidence. Corroboration is not legally required but is desirable. The judge’s satisfaction must be based on careful scrutiny, not blind acceptance. While a confession alone suffices, examining it alongside other evidence enhances safety. The principle balances respecting confessions as evidence while guarding against false ones. Truth, not corroboration, is the ultimate requirement.