Their well-taken reservations, notwithstanding, Courts, still, clung to the practice
of requiring corroboration of the evidence of such a prosecutrix, Okpanefe v.
State (1969) ANLR 411; Igbine v State (1997) 9 NWLR (pt 519) 101; Iko v State
[2001] 14 NWLR (pt 732) 221; Afolalu v State [2010] 16 NWLR (pt 1220) 584; Ndidi
v State (2005) 17 NWLR (pt 953) 17. In passing, we acknowledge the beneficial
provision of Section 204 of the Evidence Act, 2011 which has, effectively,
bowdlerised sexual offences from the corroboration requirement.
Interestingly, in Habibu Musa v State (2013) LPELR -19932 (SC), this Court noted,
most perspicaciously, that:
...It has to be restated that in offences of a sexual nature it is very desirable that
the evidence of the prosecutrix or complaint (sic, complainant) is buttressed by
other pieces of evidence implicating the accused in a substantial way. This does
not detract from the fact that the Court is not hindered from convicting an
accused on the uncorroborated evidence of the complainant. In the use or
corroborative evidence however little or slight it may be there is no rule as to
what a corroborative piece of evidence Is and how it can be applied. This is
because the trial judge is best suited to make use of the evidence being well
situated and having the opportunity and singular privilege of hearing firsthand the
witnesses, considering their demeanour including that of the appellant. Also,
where there was enough on ground from which the trial judge can reach a
decision then there is no need to warn itself of the danger of acting on the
uncorroborated evidence of the prosecutrix. That in this case anyway it is not
necessary since there was corroborative evidence in the confessional statement,
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