LEGAL PRINCIPLE: EVIDENCE LAW – Evaluation of Evidence – Duty of Trial Judge to Resolve Conflicts
PRINCIPLE STATEMENT
It is an elementary and primary principle of our judicial approach to the determination of issues that the appraisal of oral evidence and ascription of probative values to such evidence is within the primary function of the trial court. An appellate court is ill-equipped to defer on decisions involving the credibility of witnesses.
RATIO DECIDENDI (SOURCE)
Per Karibi-Whyte, JSC, in Sagay v. Sajere & Anor (2000) NLC-801994(SC) at p. 12; Paras C–D.
"It is an elementary and primary principle of our judicial approach to the determination of issues that the appraisal of oral evidence and ascription of probative values to such evidence is within the primary function of the trial court. An appellate court is ill-equipped to defer on decisions involving the credibility of witnesses."
EXPLANATION / SCOPE
Trial courts are uniquely positioned to resolve conflicts in oral evidence. They see witnesses, observe demeanor, and assess truthfulness. Appellate courts lack this advantage and are therefore “ill-equipped” to make credibility determinations. Consequently, where conflict resolution requires credibility assessment, the trial court’s findings are entitled to deference. This principle recognizes practical limitations of appellate review and allocates fact-finding responsibility to the tribunal best suited for it. Interference is only justified where findings are manifestly unsupported or perverse.