Admissibility of Electronic Bank Statements in Nigeria

The article discusses the complexities surrounding the admissibility of electronic bank statements and documents as public documents under the Evidence Act 2011, particularly sections 84, 89, 90, 102, and 104. It highlights the central issue of whether compliance with section 84 alone is sufficient for electronic bank statements to meet the dual statutory threshold required for admissibility.

The article references significant case law, including the Supreme Court's decision in Kubor & Anor v. Dickson (2012) and the Court of Appeal's ruling in Kalu & Anor v.

Ohuabunwa (2015), which affirmed that electronic public documents must comply with section 84 and be certified under section 104 to be admissible. The article also discusses the implications of these rulings on the admissibility of electronic records, emphasizing the need for proper certification and the conditions under which entries in banker’s books can be admitted as evidence.