without corroboration, and in this regard an early report of the commission of the
offence is not tantamount to corroboration. Similarly, in Sambov. The State
[1993] 6 NWLR (Pt.300) 399, this Court held ... that it is the law that before the
prosecution can secure conviction for the offence of rape, the evidence of the
prosecuting (the victim of the rape) must be corroborated in some material
particular that sexual intercourse did take place and that it was without her
consent.
It was also held that a piece of evidence offered as corroboration for the offence
or rape must be (a) cogent, compelling, and unequivocal as to show without more
that the accused committed the offence charged:
(b) an independent evidence which connects the accused with the offence
charged; and (c) evidence that implicates the accused in the commission of the
offence charged. See also Upahar v State (2003) 6 NWLR (Pt.816) 230.
The eminent jurist pointed out most insightfully that:
In Iko v. The State (2001) 14 NWLR (Pt.732) 221 in 2001, eight years after the
decision in Sambo, it was held that it is not the rule of law that an accused person
in a charge of rape cannot be convicted on the uncorroborated evidence of the
prosecuting. The proper direction is that it is not safe to convict on the
uncorroborated evidence of the prosecuting. The Court may, after paying due
attention to the warning, nevertheless convict the accused person if it is satisfied
with the truth of her evidence. This Court also held that the fact that the
prosecutrix says that an accused inserted his penis into her vagina is not ipso
facto sufficient proof of penetration in the absence of corroboration. Let me take
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