As a general rule, no particular number of witness is required in order to discharge the onus of  proof which lies upon a party and a court cannot take into account the number of witnesses who has given evidence for each side as a relevant factor in deciding which should succeed. What should be considered is the quality and not the quantity of the evidence. The court can act on the evidence of one single witness if that witness can be believed given all surrounding circumstances and also if he is able to establish a case beyond reasonable doubt as in the case of  ONAFOWOKAN VS THE STATE. This principle is recognized under section 200 which stated thus:

“Except as provided in section 201 – 204 of this Act, no particular number of witnesses shall in any case be required for the proof of any fact”
In other words, a person can be convicted of any offence on the testimony of a single adult witness just as a plaintiff in a court suit can succeed on the evidence of a single credible witness as in the case of STEPHEN EMOGA VS STATE and EMMANUEL UGWUMBA VS STATE.
The aforementioned really, negated or to an extent do not believe in the evidence by corroboration in order for a submission to be accepted by the court.

To a lay man, corroboration can simply mean to support a substantive information to authenticate if  by given an additional supporting or supplementary evidence as a backup.
·        In a legal parlance, corroboration means conforming, enforcing and reinforcing evidence supporting another evidence of the same fact. This is the definition given by LORD REID in DPP VS KILBOURNE. It is an evidence that shows that a crime has been committed and it has been committed by the accused. It is not a repetition  of the confession of the accused but a confirmation of witness evidence by an independent testimony; it is also the authenticating of a testimony by showing that a crime has actually been committed by the accused charged. According to LORD HEWAIT C.J in the case of R VS WHITEHEAD for any evidence to amount to corroboration, “it must be extraneous to the witness who is to be corroborated”.
·        Corroboration can be oral, real documentary or circumstantial as seen in the case of OLALEYE VS STATE. In that case, a man raped a girl of fourteen years. The girl was examined and was found to have the same gonorrhea found in the man accused of the rape. It held to be enough circumstantial corroborate evidence.
·        Silence at times may amount o corroborate evidence in the circumstance where the accused refuse to talk where he reasonably ought to have talked. However, it is not in all cases, it is often left at the discreation of that court to determine under each condition whether such silence amount to corroboration or not. In the case up OKE VS THE REPUBLIC; a police witness said that he took the complainant to the house of the accused who was charged with  defilement of a girl and that there the complainant  pointed at the accused saying that he was the one who defiled her. The accused said nothing. The trial judge apparently trented this alleged conduct of the accused as corroboration. On appeal, the supreme court held it inadequate to have amounted to corroboration. In the case of R vs kumi, the silence by the accused in that case amended to admission by conduct.
·        In order for an evidence to be capable in law to constitute corroboration, such evidence must be
·        Admissible itself
·        From a source independent of the evidence to be corroborated and
·        Such as to tend to show by confirmation of some material particularly not that the offence charged was committed but also, was committed by the dependent.
However, pursuant to section 200  of the evidence Act  which stated that no particular number of witnesses shall in any case be required for the prove of any fact, the general rule is that corroboration of evidence is not required except where the law demands it as seen in the case of NWAMBE Vs STATE and THEOPHILUS  Vs STATE.  The cases where the law stipulated that there should be corroboration constitute the main exceptions to the rule and also instances in which as a matter of frachie require evidence of corroboration.
      When the problem of reliability of witness arise in a suit, this suggest that in such suit, no conviction should be based wholly or mainly upon the evidence from such a single witness, though recent legislation has gone in the opposite direction and shows that these is little possibility of establishing such a principle. In criminal cases, the rule as to corroboration applies only to witnesses for the prosecution as seen in the case of DAVIES Vs D.P.P. The issue of corroboration therefore can only arise if the evidence needed to be corroborated is given by the prosecution and not the defence. The general rule that no particular number of witness is required in order to discharge the onus of proof which lies on a party is subject to the following exception or cases in which corroboration is required;
A)   Evidence of accomplice
Who is an accomplice?
Previously, the Act did not state or define who an accomplice is. The west African court in the case of NWEKE VS R,  stated that no formal definition is possible because the question whether a person is an accomplice is by and large one of fact in each particular case. The federal supreme court also held in the case of R VS EZECHI following the English House of Lord’s decision in D.P.P VS DRVIES that witnesses who are to be treated as accomplices are:
i)  Participants in the actual crime.
ii) Receivers of property which the accused is charged with stealing and
iii) Participants in other crimes alleged to have been committed by the accused where evidence of such other crimes is admissible to prove system or intent or to negative accident. In common parlance, an accomplice is any person who actually does the act or make the omission that constitute the offence or anybody who does or omit to do any act for the purpose of enabling, aiding or abetting another person to commit an offence.
Anybody who falls under this class of people mentioned above either by propagating, instigating, aiding or abetting the perpetrate or help the actual perpetrator to escape punishment are participants and thus can be charged and punished for the same offence as the actual criminal.
Presently, under the Evidence Act, 2001 (amended) an accomplice is defined under section 198 (2) to mean person who pursuant to section 7 of the criminal code may be deemed to have taken part in committing the offence asthe defendant or is an accessory after the fact to the offence, or a receiver of the stolen goods. Persons that we participants as provided under section 7 (B) of the criminal code, those who enable others or aid others to commit an offence. It envisages that if a person aid an offender to accomplish an actusreus of an offence but with an intent different from that of the offender he is not by virtue of this provision, a party to the offence and consequently, not an accomplice.
Under 198 (1) of the Guidence Act, where the only proof against a person charged with an offence is the evidence of an accomplice uncorroborated in any material particularly implicating the accused, the judge must warn the juy that it is unsafe to convict the accused upon such evidence though they have the legal right to do so, they are expected to look for an independent evidence firstly because the accomplice may invent an offence and accuse someone of committing it and secondly, he may falsely accuse someone else of an offence that had been committed.
In practice, they are additional cases to the ones provided in the evidence Act on where the court will insist on corroboration. They are as follows:
1)     Agent Provocateur
An agent provocateur is not an accomplice. The term “Agent provocateur” has been used by Nigeria courts to mean
a)     Police officers and their aids who positively incite, provoke, then join in the commission of a crime.
b)     Such officers and aids who being aware that a person or group of persons has manifested a clear intention to commit a crime but join in to facilitate the commission of the crime in order that the criminals may be caught.
The evidence of an agent provocateur who fall with the first class must be corroborated in some material particular by independent evidence tending to show that both alleged crime was committed and the accused participated in it. This can be seen in the case of  BROWNS VS J H WATSON. When used in the second sence, public order and safety demand that the evidence of the police or his aides should be sufficient to fund a conviction.
ii) Witness With Interest to Serve in Criminal Cases or Tainted Witness:
The term “tainted” witness does not appear in the evidence Act or in any other Nigerian Act, it will be impossible to give it a fixed definition. However, it has been used to mean an intermediate stage between an accomplice and non accomplice. The term was also used by the supreme court in the famous 1963. “treasonable felony” trials involving the leader of opposition in parliament.
The supreme court in the case of MICHAEL ADEDAPO AND ORS VS R stated that a tainted witness was not an accomplice whose evidence required corroboration. Dissenting to this point, Mbanefo J.S.C was of the view that though a tainted witness was not an accomplice in the strict sense, that a tainted witness is one whose evidence would be unsafe to act upon without corroboration.
Another form of tainted witness is a person who is not an accomplice but a witness with his own interest or who have some purpose of his own to serve. This principle was applied by the supreme court in the case of WILLIAMS  IDAHOSA AND ORS VS R.

iii) Sexual Offence General:
What constitute sexual offences is provided under the Evidence Act and various sections of the CRIMINAL CODE.It provides that a person cannot be convicted of certain sexual offences upon the uncorroborated testimony of one witness. Invariably, it is insisted by the court that in sexual offences, corroboration of the complainant’s evidence is needed though not required by the law. This was the decision of the court in the area of SUNMONU  VS POLICE. The offences are defilement of girls under 13 years of age, defilement of girls between 13 and 16 years of age and of idiots, procuration and procuring defilement of women by threats or of trend or administering drugs contrary to sections 218, 221, 233 and 224 of the criminal code respectively.
It is therefore usual in sexual offences to be way of convicting without corroboration. This can be seen in the case of OKOT VS THE STATE.

If a child understand the nature of an oath, he should give sworn evidence. Even where he testifies an oath, the court should hestitate to convict solely on such evidence. In the case of AKPAN VS STATE, the court held that sworn evidence of child is  not a matter of law to be corroborated but it is desirable not to act immediately because there is a risk in acting on an uncorroborated evidence of young boys and girls.
The failure of a judge to warn himself of the risk of acting on the uncorroborated sworn evidence of a child does not cause any miscarriage of justice if the judge clearly addressed his mind to the fact that the witness was a child of eleven years but understood the nature of the oath and the necessity of telling the truth.
This can be seen in the case of R VS KOFI FRANCIS.
This is a civil matter. It is the only civil matter in which provision for corroboration is made. Section 197 of the Evidence Act stated no plaintiff in any action for breach of promise to marry shall be entitled to succeed unless his or her testimony is corroborated by some other material evidence in support of such promise and the fact that the defendant did not answer letters affirming that he had promised to marry the plaintiff is not such corroboration.
They are other offences for which conviction cannot be heard without corroboration like section, perjury, exceeding, speed limit, e.t.c. In all this offences, no person is meant to be convicted unless a corroborated evidence has been laid.
In Nigeria legal system, there is no particular number of witnesses a party my require in order to prove or disprove a case but they are some offences in which if the court should give their judgment on without calling on witnesses to give their testimony, it will lead to miscarriage of justice and therefore, the judgment would be quashed and then appeal will be held on it like in the case of QUEEN VS OKAGBUE.   
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