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BURDEN TO PROVIDE RECORDS OF PENSION IS ON GOVERNMENT

Dictum

In the case of Registered Trustees of Association of Former Telecom Employees of Nigeria &17,102 Ors. V. Federal Republic of Nigeria & Ors; ECW/CCJ/JUD/20/19, when this court held that: “It follows therefore that once the claimant makes out a prima facie case of entitlement to pension, by proof of employment but lacks access to the key information needed to substantiate his claim same being in the control of Respondent, such claim cannot fail due to being unsubstantiated. It is a recognized fact that salary records and computations matrix are in the normal cause of events in the custody and preserve of the employer in this case the Respondent. The burden to provide records of the pension entitlement of the Applicant having shifted to the Respondent, the Applicants are exonerated from proving their entitlement.”

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THE PERSON WHO WOULD LOSE HAS THE GENERAL BURDEN

In civil cases, the ultimate burden of establishing a case is as disclosed on the pleadings. The person who would lose the case if on completion of pleadings and no evidence is led on either side has the general burden of proof. See Elemo & Ors. v. Omolade & Ors (1968) NMLR 359. See also...

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ACCUSED PERSON HAS NO DUTY TO PROVE HIS INNOCENCE

It is apposite to stress here too, that an accused person has no duty to prove his innocence in criminal cases. See Alabi v State (1993) 7 NWLR (pt.397) 511; Ariche vs State (1993) 6 NWLR (pt.302) 752. — Amiru Sanusi, JSC. Ogunleye Tobi v The State (2019) – SC.714/2017 Was this dictum helpful? Yes...

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HE WHO ASSERTS MUST PROVE

The burden of proving a particular fact is on the party who asserts it. See Okubule v. Oyagbola, (1990) 4 N.W.L.R. (Pt.147) 723; and Ike v. Ugboaja (1993) 6 N.W.L.R. (Pt.301) 539. That is the position in civil cases but the onus does not remain static. It shifts from side to side, where necessary, and...

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EXPERT IS PERMITTED TO GIVE AN OPINION BASED ON HEARSAY

Para. 40: “It is common knowledge that an expert’s opinion is usually based on his training and experience. In law an expert is permitted to give an opinion on the basis of hearsay information, provided that it relates to specific matters of which he does have personal knowledge. Thus a doctor can give evidence of what he was told by a patient about his condition for the purpose of evaluating his diagnosis; though his testimony is inadmissible to show what symptoms were actually being experienced by the patient; see R. V. Bradshaw (1985) 82 Cr. App. R. 79, CA.”

— Saidykhan v GAMBIA (2010) – ECW/CCJ/JUD/08/10

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THE RIGHT TO BE HEARD CONNOTES AN OPPORTUNITY TO MAKE REPRESENTATION

Para. 53: “The Court recognizes the principles of Audi alteram partem (hear the other side) which requires that persons affected by an adverse position must be given an opportunity to make representation. The right to be heard by its own nature connotes an opportunity to be heard within a reasonable time by an impartial court or Tribunal. This right is not limited to a one on one verbal representation but encompasses every avenue accorded to a party to be heard in a matter. This Court 18 reiterated the principle that parties must be given an opportunity to be heard in any matter affecting their interest in the following words: “the right to fair hearing is a human right derived from the concept of fair hearing, in this regard, a fair trial is not only seen as an additional instrument for protection of the rights of defence largo sensu…..” See MOHAMMED TAYYIB BAH V. REP OF SIERRA LEONE JUD NO: ECW/CCJ/JUD/11/15, (Unreported) in its consideration relied on the case of Ugokwe v. Okeke (2008), CCJELR pg. 149@ 146.”

— Uuter Dery v Republic of Ghana (2019) – ECW/CCJ/JUD/17/19

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