Judicial decisions have shown that there is no particular type or quantity of evidence to warrant special damages. See the case of SPDC Ltd v. Tiebo VII & Ors (2005) 9 NWLR (Pt. 931) 439 wherein this Court said:- “…in other words, it is a general guide and arises from the fact that it is impossible to prescribe the quantity and nature of evidence required in a given case to justify entitlement to special damages. In some cases, it may be necessary to show documentary proof of the loss sustained, while in other, it may be unnecessary. The important thing is that the evidence proffered must be qualitative and credible and such as lends itself to quantification. Each case depends on its own facts and circumstances.” Pages 461462 paragraphs F – B of the report.
— C.B. Ogunbiyi, JSC. Ibrahim v. Obaje (2017) – SC.60/2006