REX v. J. A. ONABANJO

Chief Justice Kingdon, writing for the appellate court in Nigeria, considered an appeal from the conviction of a storekeeper employed by Messrs. John Holt & Co. Ltd. for theft of goods valued at £615 15s. The prosecution sought to admit a written statement prepared by Mr. Wood, the company’s agent at Ijebu Ode, and later typed and signed by the appellant in the presence of an office clerk. Although defence counsel initially objected and the statement was marked for identification, the trial judge admitted it after hearing submissions and expressly finding it voluntary, disbelieving an alleged promise of continued work. On appeal, the court reaffirmed the requirement of voluntariness, found no evidence of threats or undue pressure, and noted the judge-alone context. While acknowledging an irregular delay in ruling on admissibility, the court held there was no prejudice and concluded the evidence justified the guilty finding. The appeal was dismissed.