Identification

There is a settled line of authorities to the effect that the domestic or internal affairs of a political party are not Justiciable, that the Courts will not dabble into the membership of a party or who it chooses to sponsor for an election. See: Onuoha Vs Okafor (1983) 2 SCNLR 244; P.D.P Vs Sylva (2012) 13 NWLR (Pt. 1316) 85; APGA Vs Anyanwu (2014)1-2 SC (pt. 1) 1; Emenike Vs P.D.P (2011) LPELR 1975 2(CA).
However, in making its choice, a political party must act within the law and must comply with its own constitution and guidelines. Prior to 2006 political parties acted with impunity in the selection, sponsorship and substitution of candidates for election.

SHUAIBU LAU V. PEOPLES DEMOCRATIC PARTY [PDP] &

Identification parade by its nature is the means of establishing whether a person charged with an offence is the same person who committed the offence. It is essential in instances where:-
(a) The victim did not know the accused before and his first acquaintance with him was during the commission of the offence.
(b) The victim or witness was confronted by the offender for a very short time.
(c) The victim due to time and circumstances might not have had the full opportunity of observing the features of the accused.
This Court had stated in ARCHIBONG VS STATE (2006) 5 S.C. (Pt III) 1 that:-
Identification parade is not the only way of establishing the identification of an accused person in relation to the offence charged, where the witness has ample opportunity to identify the accused, a parade is not necessary, Recognition of an accused may be more reliable than identification.
See also, EYISI VS THE STATE (2000) 12 S.C. 24; OSUAGWU vs THE STATE (2013) 1-2 S.C (Pt.1) 37; THE STATE VS SALAWU (2011) 12 S.C. (PT.IV) 191; OCHIBA VS THE STATE (2011) 12 S.C. (Pt. IV) 79.

On the issue as to whether the appellant was one of those who participated in the robbery, the law is trite that it is not in every circumstance that an identification parade must be conducted to determine the identity of the robber. ln Adeyemi vs The State (1991) 2 NWLR (Pt. 170) 679 @ 694 G. His Lordship, Olatawura, JSC had this to say:
"It is fallacious to think that the only identification of an accused person acceptable when an issue of identification is raised is an orchestrated identification parade. Identification depends on mental ability and perception of individuals. Where a witness who gave evidence of visual identification was not cross-examined nor shaken under cross-examination, nothing stops a trial judge from accepting his evidence."
See also:Adamu Vs The State (1991) 4 NWLR (Pt. 147) 530, where this Court held that it is the entire circumstances of a case that determines the type of identification necessary.