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PROOF BEYOND REASONABLE DOUBT

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Dibie v. The State (2007) LPELR 941 (SC) said thus: “Proof beyond reasonable doubt does not mean proof beyond every shadow of doubt. Once the proof drowns the presumption of innocence of the accused, the Court is entitled to convict him, although there exist shadows of doubt. The moment the proof by prosecution renders the presumption of innocence on the part of the accused useless and pins him down as the owner of the mens rea or actus rea or both, the prosecution has discharged the burden placed on it by Section 138(3) of the Evidence Act”.

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EXPLANATION OF PROOF BEYOND REASONABLE DOUBT

Lord Denning explained proof beyond reasonable doubt in Miller v Minister of Pensions (1947) 2 ALL ER p.372 and this explanation was adopted by this Court in Lori & Anor v State (1979-1981) 12 NSC p.269 and in innumerable decisions of this Court. His Lordship said: “Proof beyond reasonable doubt does not mean proof beyond the shadow of doubt. The law would fail to protect the community if it admitted of fanciful possibilities to deflect the course of justice. If the evidence is so strong against a man as to leave only a remote possibility in his favour which can be dismissed with the sentence of course it is possible but not in the least probable the case is proved beyond reasonable doubt but nothing short of that will suffice.”

– Rhodes-Vivour, JSC. Nwankwoala v FRN (2018) – SC.783/2015

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AN OFFENCE MUST BE PROVED BEYOND REASONABLE DOUBT

A fortiori, by virtue of Section 138(1) of the Evidence Act, if the commission of an offence by a party is directly in issue in any criminal or civil proceeding, it must be proved beyond reasonable doubt.

– Saulawa, JSC. Makanjuola v. State (2021)

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WHEN A CASE IS SAID TO BE PROVED BEYOND REASONABLE DOUBT

It must however, be emphasized that the burden of proof of the guilt of an accused person beyond reasonable doubt by the Prosecution in criminal cases should not be taken to mean that the prosecution must sustain its case beyond every shadow of doubt. Absolute certainty is impossible in any human adventure including the administration of justice. Thus, once the Prosecution has been able to prove that an offence has been committed and that no person other than the accused committed the offence, the prosecution is said to have established its case beyond reasonable doubt.

– Abdu Aboki, JSC. Chukwu v. State (2021)

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BURDEN ON PROSECUTION – STANDARD OF PROOF IS REASONABLE DOUBT

The standard of proof required in a murder case as in all criminal cases is proof beyond reasonable doubt. The onus of proof is on the prosecution and not on the defence. It is after the prosecution has produced necessary evidence to establish its case that the burden shifts unto the defence if he has any contradicting evidence to call his own witness to establish such evidence.

– OMOBONIKE IGE, J.C.A. Etumionu v. AG Delta State (1994)

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PROOF BEYOND REASONABLE DOUBT DOES NOT PROOF BEYOND SHADOW OF DOUBT

However, the required proof beyond reasonable doubt which the prosecution is expected to show does not mean proof beyond all shadow of doubt and the evidence adduced by the prosecution is strong enough against a man, as to leave only a remote probability in his favour, which can be dismissed with the sentence; “of course it is possible but not in the least probable,” then the case is proved beyond reasonable doubt. See; Jimoh Michael Vs. The State (2008) 13 NWLR (Pt. 1104) 361; (2008) 10 SCM 83; (2008) 34 NSCQR (Pt.11) 700.

— O. Ariwoola, JSC. Galadima v. State (2017) – SC.70/2013

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ABSOLUTE CERTAINTY IS NOT REQUIRED FOR CONVICTION IN CRIMINAL CASES

It can be discerned from these cases that though certainty is an essential element of proof in criminal liability or guilt, absolute certainly is not required because it is “impossible in any human adventure including the administration of criminal justice.” That’s one reason why the requirement of standard of proof placed on the prosecution is to prove beyond reasonable doubt and not beyond all or any shadow of doubt. The standard of proof and the burden placed on the prosecution are by the endless judicial authorities on the issue, now common place.

– M.L. Garba JCA. Odogwu v. Vivian (2009) – CA/PH/345/05

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