LEGAL PRINCIPLE: EVIDENCE LAW – Proof of Alibi – Lying Not Proof of Guilt
PRINCIPLE STATEMENT
Mere lying by an accused person is not evidence of guilt. The prosecution must still prove the guilt of the accused beyond reasonable doubt.
RATIO DECIDENDI (SOURCE)
Per Uwais, JSC, citing Muka v. The State (1976) 9-10 S.C. 305 in Kwaghshir v. The State (1995) NLC-351994(SC) at p. 14; Paras D--E.
"Even assuming that the accused persons lied in the defence of alibi put forward by them, we nevertheless, wish to point out that mere lying by an accused person is not evidence of guilt. The prosecution must still prove the guilt of the accused beyond reasonable doubt."
EXPLANATION / SCOPE
A false alibi does not prove guilt. The prosecution must still prove its case. The principle protects the accused from being convicted based on lies alone. The court may consider false alibi as evidence of guilt, but it is not sufficient by itself. The rule applies to all criminal trials. The prosecution must adduce independent evidence of guilt. The court will not infer guilt solely from a false alibi. The principle promotes the presumption of innocence.