EVIDENCE – CONFESSIONAL STATEMENT – Whether an accused person can be convicted based on his confession; Whether it is desirable to have some other evidence other than the confession


“It is equally firmly settled that a confessional statement alone, once proved to have been voluntarily made, is sufficient to ground a conviction, even though the accused may later resile from it or retract it at the trial. See: Galadima Vs The State (2012) 18 NWLR (Pt. 1333) 610: Egboghonome vs The State (Supra): Okoh vs The State (2014) 8 NWLR (Pt. 1410) 502: Oseni vs The State (2012) 5 NWLR (Pt. 1293) 351; Olanipekun vs The State (2016) 13 NWLR (Pt. 1527) 100. However, it is desirable that there should be some corroborative evidence outside the confession, no matter how slight, to show that the confession is probably true. See: Otufale Vs The State (1968) NMLR 261 @ 265 – 266: Olanipekun vs The State (supra); R vs Sykes (1913) 8 Cr. App. R. 233.” Per KEKERE-EKUN, J.S.C. in BERENDE v. FRN (2021-LCER-40453-SC) (Pp 20 – 21 Paras D – A)

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