Waziri Ibrahim v. Shagari (2007) 3 EPR 99 @ 131 where it was again said by the apex court that: “An amended document by itself does not speak of motive behind the amendment. Without more, an altered or amended document is as genuine as an unamended one. Therefore, the admission of Exhibits C to V, the returns from States from which Exhibits B and B1 were collated without any evidence to add a sting to the innocent amendment appearing on some of them offers no help to the case of the appellant. I find myself therefore unable to accept the submission of the learned counsel for the appellant that because returning officers amended and altered the returns in exhibits C to V from 15 States, that fact ipso facto means that the returning officers have not complied with the Sections 65(5), 66, 70 and 119 of the Electoral Act 1982. There must be evidence of indictment or of immoral, unlawful and illegal motive.”
While applications for amendments cannot be totally avoided in the judicial process, they could be reduced to a manageable level, as opposed to the present trend where they are in annoying proliferation. Let me proffer some solutions. And I think they can help to some extent, if not to all extent. Litigants and counsel who do their work diligently will certainly reduce the frequent applications for amendment. So much of it can be avoided if both counsel and his client are intimately involved in pre-trial factual investigations and inquiries before going into litigation and filing their pleadings. Counsel, on his part, can reduce the frequency of applications for amendment if he takes pains during chamber pre-litigation interviews, to ask and seek for relevant information, oral and documentary, from the client. There is also the collateral aspect of the matter and it is this. The client on his part, has a duty to surrender all the facts of the case and I really mean all the facts of the case (including incriminating and exculpating evidence) to his counsel. I say this because one of the basic causes of frequent application for amendment is that some clients are of the habit of dishing out half truths to their counsel or deliberately give facts in installments, only to get stock in open court to the embarrassment of counsel. That is not right. No party has any right to either adulterate the facts of a case or give facts to counsel piece meal.
— Tobi, JCA. Abraham v Olorunfunmi (1990) – CA/L/83/89