On the morning of 10 May 1979, something was wrong at 13 Dawaki Road, Nasarawa, Kano.
The gate was still locked.
Inside the house was Hajiya Fati Mohammadu Nafiu, the wife of businessman Nafiu Rabiu. She had been alive and apparently well only hours earlier. By the afternoon, she was dead.
But what made the case particularly striking was not only the death.
It was what happened that morning to a bundle of soiled blankets and clothes.
They were placed inside the boot of a Peugeot 504. Later, when the driver returned to retrieve them, they had disappeared.
That unexplained disappearance became one of the details surrounding a case that moved from the High Court of Kano to the Federal Court of Appeal and eventually to the Supreme Court of Nigeria.
The Supreme Court judgment in Nafiu Rabiu v. Kano State, delivered on 21 November 1980, would become important not only because of Fati’s death, but because of the legal questions raised by the prosecution’s appeal and the trial judge’s treatment of the medical evidence.
The Night Before Fati Died
The previous evening, 9 May 1979, had appeared completely ordinary.
Nafiu, Fati and three friends had dinner together in the garden of their home at 13 Dawaki Road.
One of the guests was the District Head of Jahun. According to his evidence, he left the house sometime between 10 p.m. and 11 p.m. and Fati was then “quite alright.”
The household driver and cook gave similar evidence.
The cook said that when he left Fati that night, she was in good health and was joking.
There appeared to be nothing that suggested that by the following afternoon, the household would be the centre of a homicide investigation.
After the final guest left, Nafiu asked the driver for the key to the main gate.
He said he would lock the gate himself.
The driver then went to his room in the boys’ quarters.
The cook also retired for the night.
Fati and Nafiu were left in the house.
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The Locked Gate
The following morning, the household routine began to unravel.
The cook arrived and discovered that the gate was still locked.
The driver did not have the key.
For about two hours, there was no explanation for why the gate remained shut.
Then, at about 10 a.m., Nafiu appeared at a window and threw the gate key down to the driver.
He also told the cook to open the kitchen door.
His explanation was that he had misplaced the key to the front door.
Then came one of the most significant moments in the evidence.
Nafiu emerged carrying a briefcase and some soiled blankets and clothes.
He asked the driver to put them inside the boot of his Peugeot 504.
The driver did so.
The bundle would not remain there for long.
The Blankets in the Peugeot
After the blankets and clothes had been placed in the Peugeot, Nafiu instructed the driver to take a Mercedes-Benz saloon car to Kano Airport.
He said his mother-in-law was expected to arrive from Niamey.
Nafiu then left in the Peugeot.
Before leaving, he told the cook to give Fati anything she needed whenever she woke up.
He also gave the cook a key to the lounge and main house.
According to the evidence, this was unusual. It was the first time the cook had been given access to those parts of the house.
The driver eventually returned from the airport and went to Nafiu’s office.
Nafiu instructed him to take the Peugeot to a mechanic.
But before doing that, the driver checked the boot.
He wanted to remove the soiled blankets and clothes that had earlier been placed there.
They were gone.
The judgment does not establish what happened to the blankets or clothes after they disappeared. It does not establish that they contained blood, nor does it establish that they were used to conceal evidence.
Their disappearance simply remained one of the unexplained circumstances surrounding the case.
The Children Discover Their Mother
Later that afternoon, another disturbing discovery was made.
A driver brought Nafiu’s children from elsewhere in Kano to visit their mother.
They went upstairs to Fati’s room.
They tried to wake her.
She did not respond.
The cook advised them to wait for their father.
Nafiu soon arrived in the Mercedes.
He and the children went into the room.
Fati was dead.
The ordinary household of the previous evening had become a crime scene.
What the Autopsy Found
A postmortem examination was conducted by Dr. Bansi Badan Tribedi, a senior consultant pathologist in Kano.
The examination recorded several external injuries, including abrasions and contusions around the face and neck, wounds on the forearm and shoulder, injuries to the back, a laceration around the knee and scratches on the thighs.
Dr. Tribedi ultimately gave the cause of death as asphyxia resulting from strangulation, or choking by hands.
Chemical analysis also found alcohol in some of the organs, but the evidence did not establish that the alcohol itself had caused death.
The medical evidence became central to the prosecution’s case.
It also became central to the eventual appeal.
Why the High Court Acquitted Nafiu
Nafiu was tried before Jones, CJ, in the High Court.
The prosecution alleged that he had caused the death of his wife.
But the trial judge was not satisfied that the medical evidence established strangulation beyond reasonable doubt.
The High Court therefore acquitted him.
The case might have ended there.
It did not.
Kano State appealed.
The Case Moves Beyond Kano’s High Court
The Federal Court of Appeal considered the matter and, on 5 May 1980, reversed the High Court’s decision.
Nafiu was convicted of culpable homicide not punishable with death and sentenced to four years’ imprisonment.
He then appealed to the Supreme Court.
The question before the highest court was not simply whether Fati had died or whether the evidence surrounding her death was disturbing.
A major issue was whether the prosecution had the legal right to appeal an acquittal from a High Court sitting at first instance in the Northern States under the law then applicable.
The Supreme Court held that such an appeal was possible, but it had to be confined to points of law.
The court also considered whether the trial judge’s treatment of the medical evidence amounted to an error of law.
What the Supreme Court Said About the Medical Evidence
The Supreme Court found serious problems with the way the trial judge had interpreted the medical evidence.
In particular, the Supreme Court held that the trial judge had misunderstood aspects of Dr. Tribedi’s evidence and the purpose of the chemical analysis.
The court considered the trial judge’s conclusion to be a serious misdirection.
This mattered because a finding of fact can, in certain circumstances, amount to an error of law where the finding is one that no reasonable tribunal properly directing itself on the evidence could have reached.
That principle became an important part of the judgment.
The Supreme Court ultimately dismissed Nafiu Rabiu’s appeal and affirmed the Federal Court of Appeal’s conviction and four-year sentence.
And Then There Were the Missing Blankets
For all the legal arguments that followed, one detail from the morning of 10 May 1979 remains remarkably vivid.
Nafiu had left the house carrying a bundle of soiled blankets and clothes.
The driver had placed them in the boot of the Peugeot.
Later, when the driver returned to remove them before taking the vehicle to a mechanic, they were no longer there.
The judgment records the disappearance.
But it does not provide a definitive explanation for where they went.
That distinction matters.
The blankets were part of the circumstances presented to the court, but the surviving judgment does not establish that they were the instrument of Fati’s death or that they contained incriminating material.
Their disappearance therefore remains an unresolved detail in the story rather than a proven explanation for the killing.
A Death That Became a Landmark Legal Case
The death of Fati Mohammadu Nafiu became more than a criminal prosecution.
It became the case through which the Supreme Court examined the limits of prosecutorial appeals following an acquittal and the circumstances in which an apparently factual finding can become an error of law.
The case also illustrates how a criminal trial can turn on details that initially appear ordinary: who had a key, who locked a gate, who entered a room, what was placed inside a car and what was missing when someone returned.
In this case, those details formed part of a chain of circumstances that travelled through three levels of the Nigerian court system.
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The Unanswered Detail
The Supreme Court judgment settled the legal appeal.
It did not answer every question that a reader might still have about the events inside 13 Dawaki Road that morning.
Among those details, the fate of the missing blankets and clothes stands out.
They were seen.
They were put into the Peugeot.
They were later looked for.
They were gone.
And the surviving judgment does not tell us what became of them.
That small detail has endured because it captures something larger about historical criminal cases: courts may settle questions of law and guilt, while some individual mysteries surrounding an event can remain buried in the evidence.
Fati’s death ultimately produced a conviction for culpable homicide not punishable with death and a four-year sentence. But the case also left behind a legal precedent that would continue to be studied long after the events of that May morning in Kano.
Author’s Note
The story of Nafiu Rabiu v. Kano State is remembered not simply because a woman died under troubling circumstances, but because the evidence surrounding her death produced a major legal battle over how Nigerian courts should treat acquittals, medical evidence and errors of law. At the centre of the story is also a deceptively simple detail: a bundle of soiled blankets and clothes that was placed in a car and later disappeared, without the surviving judgment establishing what ultimately happened to them.
References
Nafiu Rabiu v. Kano State, Supreme Court of Nigeria, SC.49/1980, judgment delivered 21 November 1980.
LawCare Nigeria, reproduction of the Supreme Court judgment in Nafiu Rabiu v. Kano State.
JurisAid Nigeria, Nafiu Rabiu v. The State (1980) 8–11 SC 130.
Law reports citation: Nafiu Rabiu v. Kano State, 3 PLR/1980/26 (SC); (1980) 8–11 S.C. (Reprint) 85.
