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RESPONSIBILITY OF TRIAL COURT TO EVALUATE EVIDENCE

Dictum

It is now settled law, that it is the primary responsibility of the trial court which saw and heard witnesses to evaluate the evidence and pronounce on their credibility or probative value and not the appellate court which neither heard the witnesses nor saw them to observe their demeanors in the witness box. It follows therefore that when a trial court unquestionably evaluates the evidence and appraises the facts of a case, it is not the business of the appellate court to substitute its own views for the views of the trial court. – Musdapher JSC. Gbadamosi v. Dairo (2007)

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COURT TO DECIDE CASE ONLY ON LEGALLY ADMISSIBLE EVIDENCE

Thus where a court wrongfully admits inadmissible evidence, it ought as a duty, to disregard the inadmissible evidence in the consideration of the judgment in the matter. Where such evidence has been wrongfully admitted and acted upon and whether or not the opposing party objects or not, an appellate court has the duty to exclude such evidence and decide the case only on the legally admissible evidence, see Timitimi v Amabebe (1953) 14 WACA 374; Ajayi v Fisher (1956) 1 FSC 90, (1956) SC NLR 279.

— Musdapher, JSC. Shittu & Ors. v Fashawe [2005] – SC 21/2001

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EVALUATION OF EVIDENCE; INTERFERENCE BY APPELLATE COURT

It has long been established that the function of the evaluation of evidence is essentially that of the trial Court, Igago v State (1999) LPELR – 1442 (SC) 27; Onuoha V. The State [1998] 5 NWLR (pt. 548) 118. Where the trial Court has unquestionably, evaluated evidence and, justifiably, appraised the facts, it is not the business of an appellate Court to interfere, and to substitute its own views for the view of the trial Court. – Nweze JSC. Abdullahi v. Adetutu (2019)

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TAKING EVIDENCE BY HIGH COURT INSTEAD OF MAGISTRATE COURT

It seems to me that if under the provisions of Order 23, rule 54 of the High Court Rules of Anambra State, 1988 a Magistrate or any officer of the court is permitted to take the evidence of a witness by way of commission, it cannot, with respect, be right to suggest that a High Court Judge, a judicial officer with much higher jurisdiction and status than a Magistrate or any other officer of the court is incompetent to take such evidence unless there exists any law which stipulates to the contrary. I know of no such law and my attention has not been drawn to any in this appeal. I am therefore of the view that the High Court was right by taking the evidence of the fourth defendant by way of commission as urged upon the court by learned Counsel for the appellant.

— Iguh JSC. Chime v Chime (2001) – SC 179/1991

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EXTRINSIC EVIDENCE CANNOT VARY A WRITTEN CONTRACT

The general rule is that where the parties have embodied the terms of their contract in a written document, extrinsic evidence is not admissible to add to, vary, subtract from or contradict the terms of the written instrument.

– Adio, JSC. UBN v. Ozigi (1994)

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EVIDENCE BY WITNESS IN PREVIOUS PROCEEDINGS CANNOT BE USED IN LATER PROCEEDING

It is settled law that evidence given in a previous case cannot be accepted as evidence in a subsequent proceedings except in conditions where the provisions of section 34(1) of the Evidence Act applies. Even where a witness who testified in a previous proceeding testifies again in a subsequent proceeding, the previous evidence has no greater value than its use in cross-examination of the witness as to his credit. Romaine v. Romaine (1972) 4 NWLR (Part 238) 650 at 669; Ayinde v. Salawu (1989) 3 NWLR (Part 109) 297 at 315; Alade v. Aborishade (1960) 5 FSC 167; Irenye v. Opune (1985) 2 NWLR (Part 5) 1 at 6-8 Sanyaolu v. Coker (1983) 1 SCNLR 168.

— F.F. Tabai JSC. Tijani Dada v Jacob Bankole (2008) – S.C. 40/2003

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ADMISSION OF FRESH EVIDENCE ON APPEAL MUST BE BY CAUTION

The power to admit new, fresh or additional evidence must always be exercised sparingly and with caution. The Court must consider whether there are special circumstances to warrant the grant of the application and whether it would be in furtherance of the justice of the case. See: Uzodinma vs Izunaso (No.2) (2011) 17 NWLR (Pt. 1275) 30 @ 55 B-C.

— K.M.O. Kekere-Ekun, JSC. Williams v Adold/Stamm (2007) – SC.404/2013

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