Section 93 of the Evidence Act, provides that:- “the contents of documents may be proved either by primary or secondary evidence.” Section 94(1) defines primary evidence as “the document itself”. Section 96 of the Evidence Act provides that “documents must be proved by primary evidence,” except in the Cases to be mentioned later. There is no section of the Evidence Act that provides that no primary evidence of a public document is admissible. Section 112 of the Act allows certified true copy to be produced in proof of the contents of public document or part of public document. I do not think the provision of section 112 of the Act renders the primary evidence of public document inadmissible in evidence.
– T.N. Orji-Abadua, JCA. Kabau v. Rilwanu (2013) – CA/K/179/2001