The Supreme Court of Nigeria has affirmed the death sentence of Sunday Jackson, convicted of culpable homicide for the 2015 killing of Ardo Bawuro in Adamawa State.
The court dismissed Jackson’s appeal, ruling that his claim of self-defense was unfounded and his actions exceeded lawful retaliation.
In 2015, Jackson stabbed Bawuro three times in the neck during a confrontation in Kodomti Village, Numan LGA. Arrested and charged under Section 221(a) of Adamawa’s Penal Code, Jackson pleaded self-defense, alleging Bawuro attacked him first. The trial court and Court of Appeal rejected his claims, citing his detailed confession and the severity of the injuries.
The Supreme Court emphasized Jackson’s voluntary confession (Exhibits B1/B2), where he admitted disarming Bawuro and stabbing him. The court noted his trial testimony contradicted this confession without explanation, rendering it unreliable.
Justices ruled Jackson failed to prove self-defense. After seizing the dagger, he could have retreated but instead inflicted fatal wounds, indicating intent.
The court found provocation incompatible with self-defense claims. Stabbing a disarmed assailant three times was deemed retaliatory, not impulsive.
Quotes from the Judgment: Download Judgment

“Stabbing the deceased thrice in the neck was not proportional to any perceived threat. The appellant’s actions were vengeful, not defensive.” – Justice Mohammed Baba Idris.
“A confession, when credible, is sufficient for conviction. The appellant’s confession left no doubt about his guilt.” – Justice Haruna Tsammani.

The five-member panel, including Justices Helen Ogunwumiju and Emmanuel Agim, unanimously upheld the lower courts’ rulings. They referenced precedents like Edoko v. State (2015), stressing that self-defense and provocation cannot coexist legally.
SUNDAY JACKSON V THE STATE JUDGMENT SC TheNigeriaLawyer
The judgment reinforces strict standards for self-defense claims in homicide cases. Excessive force, even after disarming an aggressor, negates lawful defense. The decision also underscores the weight of confessions in securing convictions.
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