From all the authorities, the salient reasons which appear for the rejection of hearsay evidence include the following: a) That the maker or originator of the statement was not under oath when he made it. b) That there is no opportunity for the cross examination of the maker; c) The likelihood of depreciation of the truth or accuracy of the facts in the process of repetition by the witness reporting it. d) The Court would not have the opportunity to observe the demeanour of the maker as a witness since it is not a direct evidence from him.
– M.L. Garba JCA. Odogwu v. Vivian (2009) – CA/PH/345/05