EVALUATION OF PROVOCATION AS A DEFENCE TO CRIMINAL LIABILITY

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ABSTRACT

Provocation is one of such human weaknesses that constitute defence in criminal charges. However, justice may not be manifestly done if decisions on plea of provocation are solely based on legal interpretations of the Criminal Code. More often than not, the defence of provocation under the administration of Criminal Justice System in Nigeria has become a subject of abuse by the criminals. The courts too are not fully abreast with the scope of the word “provocation”. It therefore brings to fore the need to take a holistic approach to checkmate any arbitrary reliance on the concept to commit crime. In realizing this goal, both primary and secondary sources of informations were used to illustrate and analyze the research questions under the study. It was discovered that the concept under the Nigerian Criminal Justice System has not taken cognizance of the realities inherent in human psychology to some extent. The study therefore recommends that the Courts in Nigeria should interpret the Criminal Code and the Penal Code free from external interpolations, and should refrain from propounding the Common Law of England. Also the legislature has to look into the inadequacies of drafting and irregularity of sections in the Criminal Code concerning the defence of provocation..

 






 

TABLE OF CONTENTS


CHAPTER ONE - INTRODUCTION

1.1       Background to the Study

1.2       Statement of the Problem

1.3       Aim and Objectives

1.4       Scope of Research

1.5       Justification

1.6       Research Methodology

1.7       Organizational Layout

CHAPTER TWO – LITERATURE REVIEW

2.0       Introduction

2.1       Conceptual framework

2.1.1    Concept of Provocation

2.1.2    Defence to Criminal Liability

2.2       Theoretical Framework

2.2.1    Partial Excuse

2.2.2    A Heretical View: Partial Justification

CHAPTER THREE - DOCTRINE OF PROVOCATION: HISTORICAL DEVELOPMENT

3.1       Historical Analysis of Doctrine of Provocation

3.2       Historical Analysis of Doctrine of Provocation in Nigeria

CHAPTER FOUR - USE OF PROVOCATION IN DEFENCE TO CRIMINAL LIABILITY

4.1       Introduction

4.2       A Reasonable Man Rule

4.3       Suddenness of Provocation and Reaction under the Heat of Passion

4.4       Proportionality of Mode of Resentment to the Provocation Offered

CHAPTER FIVE - CONCLUSION

5.1       Conclusion

5.2       Recommendations






 

CHAPTER ONE

INTRODUCTION


1.1       Background to the Study

In the early 16th century, Common law introduced the defence of provocation in an effort to reduce the severity of the death sentence for capital offenders.[1] This was mostly considered as a recognition of human weakness.[2] In most homicide cases, the accused may use the defence of provocation in connection with murder.[3] When an individual loses control of their emotions and inflicts physical injury as a consequence of being provoked, even if they do not mean to murder, the defence of provocation may come into play.

The defence of provocation, just like any other defences to criminal liability, originates from common law as a result of Nigeria history being a colony of the Britain.[4] It is based on the law’s compassion for human weakness, as it has been recognised that human beings are prone to losing control under extreme anger.[5] Hence, if they react spontaneously in a violent manner, justice demands that the cause of their spontaneous reaction be taken into consideration when inflicting punishment.[6] Provocation has received legislative and judicial recognition over time and is contained in both the Penal Code Act and the Criminal Code Act, applicable in the Northern and Southern parts of Nigeria respectively.[7] Although the Penal Code merely describes its legal consequence, the Criminal Code gives a lucid and comprehensive definition of provocation and its scope. However, unlike the Criminal Code, the Penal Code does not recognise provocation as an absolute defence to the crime of assault.[8] Both Acts are ad idem on the fact that provocation as a legal defence to criminal responsibility does not exonerate completely; rather if successfully proved and accepted by the court, it will merely reduce the finding of murder to manslaughter.[9] The test of what constitutes provocation is not settled, as what may be taken as extreme rage varies from person to person and even from society to society. This is why it is based on the objectivity test as, what might inflame an individual in certain circumstances might not have such an effect on others.

 

1.2       Statement of the Problem

The defence of provocation in a murder charge has a chequered history. It developed in English courts in the 16th and 17th centuries.[10] During this period, the death penalty was a mandatory punishment for anybody convicted of murder. The defence of provocation was borne out of the consideration that it is virtuous for a man of honour to respond with controlled violence to some forms of offensive behaviour. Overreaction of a proportionate degree was considered a natural human frailty and if death occurred, it was regarded as manslaughter rather than the offence of murder.[11] The defence of provocation can, thus, be described as a concession to human frailty, introduced by the common law to mitigate the strictness of the single penalty of death for a convict in a murder charge. Before 1965, there were conflicts in the courts as to whether recourse has to be made to the common law to determine what provocation means while others were skeptical that provocation has been defined in the definition of assault under Section 283 of the criminal code.[12] Provocation can be raised as a defence to criminal responsibility. But despite this, it is worthy of note that it is not a complete defence such as: accident, intoxication, automatism, self-defence and the host of other defences to criminal liability. When raised as a defense, it is only capable of reducing murder to manslaughter. Thus, no amount of provocation can ever justify a killing either voluntary manslaughter or involuntary manslaughter.


1.3       Aim and Objectives

The main aim of this study is to investigate the legal framework of provocation as a defence to criminal liability.

The specific objectives are:

1.     To analyse the nature of provocation as a defence to criminal liability.

2.     To analyse the elements of provocation as a defence to criminal liability.

3.     To examine the limit of the defence of provocation in criminal liability

1.4       Scope of Research

This study focused on the legal framework of provocation as a defence to criminal liability. It will also cover how the courts have interpreted some salient principles of provocation as a defence to criminal liability.

 

 

1.5       Justification

The Nigerian Criminal Procedure System is such that when a defendant is charged with or accused of the commission of a crime, there are certain defences which the said defendant can raise. One of them is the defence of provocation. This research found it necessary to find out the extent and limits of the said defence as far as criminal liability is concerned.

More often than not, the defence of provocation under the administration of Criminal Justice System in Nigeria has become a subject of abuse by the criminals. The courts too are not fully abreast with the scope of the word “provocation”. It therefore brings to fore the need to take a holistic approach to checkmate any arbitrary reliance on the concept to commit crime.

1.6       Research Methodology

The research methodology adopted is doctrinal, essentially. Hence, primary and secondary sources shall be put to use. Most significantly, statutes, law reports and important gazette, information, hansards are to be consulted. Textbooks, magazines, newspapers, committee reports and journals shall also form part of the sources of the research.



[1] Famakinwa v. State (2012) LPELR-9748(CA)

[2] Rafiu v. People of Lagos (2021) LPELR-58368(SC)

[3] Uwaekwegghinya v. State (2005) LPELR-3442(SC)

[4] Kharisu Sufiyan Chukkol, The Law of Crimes in Nigeria, (2010) Ahmadu Bello University Press, 69-281; Cyprian Okechukwu Okonkwo, Okonkwo and Naish: Criminal Law in Nigeria, (1980) Spectrum Books Limited, 97-155.

[5] Adeleke L. A. ‘Psycho-social Analysis of Elements of Provocation in Nigerian Criminal Justice: A Jurisprudential Desideratum’ (2014) University of Bostwana Law Journal, 18 & 19: 28; Hart H. L. A., ‘Prolegomenon to the Principles of Punishment’ (1991) Feinberg, Joel, Gross, Hyman, (eds.) Philosophy of Law, Wadsworth publishing: 662; Clarkson C. M. V., Understanding Criminal Law, (1995) 2nd ed., Fontana Press :73.

[6] Chukkol, note 1, 202.

[7] Adeleke, note 2, 27-28; 6ixthform, ‘Reforms - provocation’ <http://sixthformlaw.info/01_modules/mod3a/3_70_reforms/13_provocation.htm> accessed on 24th July, 2019.See Section 222 of the Penal Code Act, Cap. P. 17 Laws of the Federation of Nigeria 2004 and section 318 of Criminal Code Act Cap C38 Laws of the Federation of Nigeria 2004.

[8] Chukkol, note 1, 202.

[9] Fitzpatrick B. & Reed A., ‘Provocation: A Controlled Response’ (2000) 12 Transnational Lawyer 393; Hart, note 2, 73-74; Adeleke note 2, 28; Clarkson, note 2, 73.

[10] O. J. Jejelola, LL.B (Hons), BL.; LL.M (IFE); Ph.D (EKSU), Head, Department of Commercial Law, Adekunle Ajasin University, P. M. B 001, Akungba – Akoko, Ondo State, Nigeria. E-mail: oj-_jejelola@yahoo.co.uk. Telephone No: - 08034074645; 08022376353; 080779916301 United Kingdom Law Commission. ‘Partial Defences to Murder’, Consultation Paper No. 173, (2003), P.6.

[11] ibid

[12] Nwankolu v. R3. (1937)3 WACA, 208.

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