The Supreme Court in F.R.N. v. Akaeze [2024] 12 NWLR (Pt. 1951) 1 decided that the duty of the law enforcement agencies in Nigeria under sections 15(4) and 17(1) & (2) of the Administration of Criminal Justice Act 2015 (“ACJA“) to record electronically confessional statement of suspect during criminal investigation in an audio-visual format is a mandatory obligation which permits no discretion and that failure to comply with the statutory requirement invalidates the purported confessional statement.
This is a sister appeal to an earlier appeal which culminated in the judgment of the Supreme Court reported in Friday Charles v. The State of Lagos (2023) 13 NWLR (Pt. 1901) 213
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