evidence, so long as the statement is free, voluntary,
direct, positive and properly proved. In some
instance,
depending
on
the
totality
of
the
circumstances of the case, it may be desirable to
have some evidence outside the confession which
would make it probable that the confession was true.
See Adisa Wale Vs. State [2013] 14 NWLR (Pt. 1375)
567; Simon Vs. State [2017] LPELR-41988(SC).
In Ubierho Vs. The State [2002] 5 NWLR (Pt. 819) 644 @
655, the Supreme Court held, per Ogunbiyi, JSC, as
follows:
“A
man
may
be
convicted
solely
on
his
confession. There is no law against it. If a man
makes a free and voluntary confession which is
direct and positive and is properly proved, the
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