Under Section 83(1) of the same Evidence Act, only the original copy of a document produced by its maker, if it is relevant to the facts in issue, is admissible in evidence. There are, however, other qualifications to the rule in Section 83(1) of the Evidence Act. While Section 88 of the Act directs that documents shall be proved by primary evidence it makes allowance for exceptions including secondary evidence of the existence, condition or contents of a document e.g. as in Section 89 thereof. A secondary evidence of the contents of a document which is not produced in accordance with the material provisions of the Act, though relevant to the issue in the proceedings, will not be admissible in evidence.
— E. Eko, JSC. Kekong v State (2017) – SC.884/2014