LEGAL PRINCIPLE: EVIDENCE LAW — Evaluation of Evidence — Primary Function of Trial Court
PRINCIPLE STATEMENT
The evaluation of evidence and ascription of probative value are the primary functions of the trial court; an appellate court should not substitute its own views where the trial court has properly evaluated the evidence.
RATIO DECIDENDI (SOURCE)
Per Iguh, JSC, in Agbeje & Ors v. Ajibola & Ors (2002) NLC-341996(SC) at p. 15; Paras B–C.
"The evaluation of evidence and the ascription of probative value to such evidence are the primary functions of a court of trial which heard and assessed the witnesses. Where a court of trial unquestionably evaluates the evidence and justifiably appraises the facts, it is not the business of the Court of Appeal to substitute its own views for those of the trial court."
EXPLANATION / SCOPE
Trial courts have the primary responsibility to evaluate evidence and assign weight. The trial court sees and hears witnesses, observing demeanour. Appellate courts defer to these findings. The appellate court will not substitute its own views if the trial court properly evaluated the evidence. The principle applies even if the appellate court might have reached a different conclusion. The trial court’s findings are entitled to respect. The appellate court’s role is to correct errors of law, not re-evaluate facts. The rule promotes judicial efficiency. The appellant must show that the trial court failed in its duty. The principle is fundamental to appellate practice.