EVIDENCE LAW — Proof of Signature — Statutory Method — Comparison of Undisputed Signature with Disputed Signature
Ratio Decidendi
Per Mohammed, JSC, in Ayanru v. Mandilas Limited (2007) NLC-123-61-2002(SC) at p. 15; Paras A–B:
"In line with the provisions of Section 61(1) and (2) of the Evidence Act which provides for the method of proving signature by comparing the undisputed signature on a document with that sought to be proved, the evidence of DW2 who was the Company Secretary of the Respondent and who in the course of his duties had occasion to go through the file of the Appellant's property containing relevant documents signed by the Appellant, is indeed relevant."
Explanation / Scope
Under Section 61 of the Evidence Act, signatures may be proved by comparing a disputed signature with an undisputed or admitted signature. A witness familiar with the person’s signature from documents in the ordinary course of business can testify to the comparison. This method provides a statutory and reliable way to prove the authenticity of signatures without requiring the signatory’s testimony.