EVIDENCE – CONFESSIONAL STATEMENT – Tests for determining the truth or weight to attach to a confessional statement before a court can convict on same


“The test for considering a confessional statement as laid down in R Vs Sykes (Supra) is as follows: (a) Is there anything outside the statement to show that it is true? (b) Is it corroborated? (c) Are the facts stated in it true as far as can be tested? (d) Did the accused have the opportunity of committing the offence? (e) Is the confession possible? (f) Is it consistent with other facts that have been ascertained and proved? See also: Ikechukwu Okoh Vs The State (2014) 18 NWLR (Pt. 1410) 502: Ojegele vs The State (1988)1 NWLR (Pt. 71) 414: Akpa vs The State (2007) 2 NWLR (Pt. 1019) 500.” Per KEKERE-EKUN, J.S.C. in BERENDE v. FRN (2021-LCER-40453-SC)

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