Two Stolen Bulls, a Threatened Curse, and a Grandfather's Death: The Confession That Sealed a Death Sentence: Haladu v. State (2026) 12 NWLR (Pt. 2055) 517— Supreme Court of Nigeria

An elderly man threatens to use charm — traditional spiritual retribution — against whoever stole his bulls. Days later, he's dead, suffocated in his own home. What began as a dispute over livestock ended in a Supreme Court ruling on when a confession alone is enough to send someone to the gallows.

The Facts

An 85-year-old man had bought two bulls and entrusted them to his son's care. That son secretly sold the bulls and handed some of the proceeds to two other relatives — his own son (the appellant) and his brother — while telling his father the animals had simply been stolen. The elderly man initially accepted this explanation. But when he later discovered the bulls had actually been sold, he threatened to use spiritual means to strike down whoever was responsible.

Rattled by that threat, the son who'd sold the bulls reportedly confessed to a witness and begged to be taken to his father to ask forgiveness. The father accepted the apology on condition that the money paid to a "juju man" as transport fare be refunded. But on the very day of that confession, the elderly man was attacked at night in his home by unidentified assailants while he slept. A neighbour heard him shout and rushed over, but the attackers fled before being seen, and the locked door kept the neighbour out. The victim was hospitalised and died six days later; medical evidence attributed his death to suffocation and strangulation.

The Journey Through the Courts

The appellant, along with his uncle and father, was arrested and charged with conspiracy, culpable homicide punishable with death, and abetment. All three pleaded not guilty — but each had reportedly confessed during police investigation, and those statements were admitted into evidence. The trial court convicted all three and sentenced them to death by hanging. They appealed. The Court of Appeal afirmed the sentence. The appellant then appealed to the Supreme Court, challenging his conviction largely on the ground that it rested on a confessional statement he later claimed was made under duress.

The Court's Reasoning

Three Ways to Prove Guilt — and One Is Enough

The Supreme Court restated the three recognised routes to proving a defendant's guilt in Nigerian criminal law: a voluntary confession, circumstantial evidence, or eyewitness testimony. Since there was no eyewitness to the actual killing, the prosecution's case rested mainly on the appellant's own confessional statements — tendered in both English and Hausa versions — and on circumstantial evidence. Critically, when those statements were first tendered at trial, the defence raised no objection to their admissibility or voluntariness. Only later, during his own defence, did the appellant try to argue they'd been extracted under duress.

A Confession Can Convict on Its Own

The court confirmed a long-standing principle: a voluntary confessional statement, by itself, is strong enough evidence to ground a conviction — even a death sentence. The fact that an accused person later tries to disown or discredit their own statement doesn't make it inadmissible; it simply becomes a question for the trial court to weigh, and both the trial court and the Court of Appeal had already found the statements credible.

Conspiracy Doesn't Need a Smoking-Gun Meeting

Conspiracy, the court noted, is rarely provable through direct evidence of an actual agreement — nobody hands over a signed pact to commit a crime. Instead, courts routinely infer conspiracy from surrounding facts, and where the underlying offence itself has been proven, an inference of conspiracy naturally follows. Here, the appellant's own confession pointed to a coordinated plan between him and his co-accused.

Presumed to Intend What You Do

Applying the principle that a person is presumed to intend the natural and probable consequences of their actions, the court found that suffocating and strangling an elderly, defenceless man could only point to an intention to cause his death.

Public Documents Have Rules — But an Original Confession Isn't One of Them

The appellant also tried a technical evidentiary argument, contending that the confessional statements should have been excluded as improperly certified copies of public documents. The court dismissed this, clarifying that an original confessional statement — not a photocopy — is primary evidence and doesn't need certification at all; the strict certification rules for public documents simply don't apply to it.

Concurrent Findings Are Hard to Dislodge

Finally, the court reiterated its general reluctance to disturb factual findings that two lower courts have already agreed on, absent some special or exceptional circumstance — a bar the appellant, in the court's assessment, came nowhere close to clearing.

The Final Verdict

The Supreme Court unanimously dismissed the appeal, affirming the conviction and the death sentence.

Key Takeaways

• A single voluntary confession can be enough to convict, including for the most serious offences — corroborating eyewitness evidence isn't a strict requirement.

• Object early or risk losing the point. Failing to challenge a confession's admissibility when it's first tendered can make it much harder to attack later.

• Conspiracy is usually proven by inference, not direct proof of an agreement — the surrounding facts do the work.

• Two courts agreeing on the facts is a high bar to overturn at the Supreme Court; only truly perverse findings will be disturbed.

Questions for You

Given how much weight a single confession can carry, do you think Nigerian courts strike the right balance in also permitting a defendant to challenge a confession's voluntariness at any stage of trial? What safeguards, if any, would you want to see strengthened around confession evidence in capital cases?

This post is a plain-language summary and commentary based on a reported judgment of the Supreme Court of Nigeria. It is provided for general informational purposes only and does not constitute legal advice. Readers with a specific legal question should consult a qualified legal practitioner.