ADMISSIBILITY OF ELECTRONIC DOCUMENTS: Whether the reliability and functionality of a computer used in generating a document can be made by oral evidence

“The Appellant has also sought to impugn the integrity of Exhibit 7 contending that the Respondent failed to tender the certificate of trustworthiness of the computer used in printing the documents, in compliance with Section 84(a) of the Evidence Act. However, where such a certificate is not produced, it has been held that oral evidence of a person familiar with the operation of the computer can be given of its reliability and functionality; and that such a person need not be a computer expert. See R v Shephard (1993) AC 380. This condition was satisfied by the testimony of PW17 on oath when he explained the process of how he scanned the emails from Saybolt Concremat Brazil, produced and printed them in colour and then sent them to the EFCC. I therefore have no reason to interfere with the finding of the trial Court in this regard. I resolve issue two in favour of the Respondent.”Per SANKEY, J.C.A. (Pp. 42-43, Paras. F-C); JUBRIL v. FRN (2018) LPELR-43993(CA)