EVIDENCE LAW — Estoppel — Previous Judgments Between Same Parties — Estoppel as Relevant Fact Available to Plaintiff
Ratio Decidendi
Per Onnoghen, JSC, in Ayuya & Ors v. Yonrin & Ors (2011) NLC-123-24-2002(SC) at pp. 15—16; Paras D—A:
"In an action for declaration of title, a plaintiff may plead and rely on a previous judgment in his favour not as res judicata but simply as an estoppel in the sense that it constitutes a relevant fact to the issue in the present action and the judgment will be conclusive of the facts which it decided."
Explanation / Scope
This principle establishes that in a declaration of title action, a plaintiff may rely on a previous judgment in their favour as an estoppel, constituting a relevant fact and conclusive of the facts decided. The principle applies in land title claims. It ensures that previous judgments are given effect. The principle reflects the use of judgments as evidence. It prevents re-litigation of decided facts. The court must treat the judgment as conclusive. The principle provides guidance on estoppel by previous judgment.