4. EVIDENCE - CORROBORATION/CORROBORATIVE EVIDENCE: Definition and nature of corroborative
evidence
"Evidence in corroboration is an independent testimony which affects the accused by connecting or
tending to connect him with the crime in some respects material to the charge in issue but it needs not
consist of direct evidence that the accused committed the offence, nor amount to a confirmation of the
whole account given by the witness. It is sufficient if it corroborates the evidence in some respects
material to the charge. See EZIGBO V. STATE (2012) LPELR - 7855 (SC); R. VS BASKETVILLE (1916-17) ALL
ER REPRINT 38 AT 43; IKO VS STATE (2001) 14 NWLR (PT. 732) 221 AT 241. Indeed corroborative
evidence is confirmatory evidence or additional evidence to that already given. It is supplementary
evidence that tends to strengthen or confirm the evidence already given which it is to corroborate. It is
an additional evidence of a different character on the same point. See Blacks Law Dictionary, 6th Edition
page 344 and MUSA VS THE STATE (2013) ALL FWLR (PT. 692) B - C. In STATE VS GWANGWAN (2015)
LPELR 504/2012 (SC) the Supreme Court held that corroboration means or entails the act supporting or
strengthening the statement of a witness and it does not mean that the witness corroborating the
evidence must use the exact or very like words used by the witness whose evidence is to be
corroborated. Additionally, corroborative evidence, it must be emphasized is sufficient even if it is
circumstantial in nature so long as it connects or tends to connect the accused to the commission of the
offence. See DURUGO VS THE STATE (1992) NWLR (PT. 255 525; OGUNBAYO VS THE STATE (2007) LPELR
- 2323 (SC)." Per WAMBAI, J.C.A. (Pp. 18-19, Paras. D-F) (...read in context)
5. EVIDENCE - CORROBORATION/CORROBORATIVE EVIDENCE: Whether the unsworn evidence of a child
requires corroboration to warrant a conviction
"Learned Appellant's Counsel has argued that the unsworn evidence of PW6 a child of 5 years of age
requires corroboration and that neither the above evidence of PW3 nor that of PW4 corroborates her
evidence. I quite agree with the learned Counsel that the unsworn evidence of PW6, a child below the
age of 14 years, requires corroboration both as a matter of law as stipulated in Section 209 (1) and (3) of
the Evidence Act and by established practice as a matter of prudence. See OBRI VS THE STATE (1997)
LPELR - 2194 (SC); DAGAYYA VS THE STATE (2006) LPELR - 912 (SC)." Per WAMBAI, J.C.A. (P. 18, Paras. AD) (...read in context)