UNIT 4

RELEVANT FACTS

Relevant facts are those facts that are directly connected to the matters in dispute in a legal case. They are facts that tend to prove or disprove a point at issue. The relevance of a fact is determined by its ability to make the existence of any fact in issue more or less probable than it would be without that fact. The determination of relevant facts is governed by the Nigerian Evidence Act, particularly under sections 4 to 11 which outline what constitutes relevant facts and the conditions under which they may be admissible in court. See the case of F.R.N v. Dairo (2015) 1 NWLR (Pt. 1440) 77, where the Supreme Court emphasized that facts which are logically relevant to the fact in issue should be admitted in evidence. The court held that relevance is a matter of logical connection to the fact in issue. Relevant facts play a crucial role in the administration of justice. They help in establishing the truth and in ensuring that only pertinent information is considered by the court. For example, in a criminal trial, evidence showing the presence of the accused at the scene of the crime is a relevant fact.

RES GESTAE

Res gestae refers to the events, circumstances, remarks, and declarations that are so closely connected to a particular event or transaction that they are considered part of the event itself. This doctrine allows certain statements or facts to be admitted into evidence even if they might otherwise be considered hearsay. The principle of res gestae is encapsulated in section 6 of the Nigerian Evidence Act which allows facts which form part of the same transaction to be relevant whether they occurred at the same time and place or at different times and places. See the case of R v. Bedingfield (1879) 14 Cox CC 341, where a statement made by a victim immediately after being attacked was admitted as part of the res gestae. Although this is an English case, the principles applied are similar to those in Nigeria and the Nigerian case of Akpan v. The State (1992) 6 NWLR (Pt. 248) 439 where the Supreme Court allowed the admission of statements made immediately after the event, as they were considered part of the transaction. Res gestae is crucial in cases where the spontaneity of a statement ensures its reliability. For instance, in a case of assault, an exclamation made by the victim at the time of the attack can be admitted as part of the res gestae, providing immediate context to the event.

COMPLAINTS

Complaints in legal terms refer to the statements made by a victim of a crime or an aggrieved person regarding the commission of the crime or wrongdoing. These statements can sometimes be admitted as evidence in court. Complaints are generally considered under sections 36 and 37 of the Nigerian Evidence Act, which deal with the admissibility of statements and declarations. The relevance and admissibility of complaints are often evaluated based on their spontaneity and consistency with other evidence. See the case of Owhoruke v. C.O.P (2015) 15 NWLR (Pt. 1483) 557, where the Supreme Court held that for a complaint to be admissible, it must be made promptly and be consistent with other evidence presented. Complaints are often crucial in cases involving personal crimes such as assault, theft, or sexual offenses. For example, in a rape case, the immediate complaint made by the victim to a friend or family member can be admitted to corroborate the victim's testimony, provided it meets the legal requirements of admissibility.

CONCLUSION

By understanding and applying the concepts of relevant facts, res gestae, and complaints, legal practitioners can effectively present their cases and ensure that all pertinent information is considered by the court. These concepts are foundational to the Nigerian legal system and are essential for the fair administration of justice.