Meanwhile, Ali Jammeh, a staff member of the Ministry of Justice at the Company Registrar, testified yesterday on behalf of the Registrar. In his testimony, the witness provided an overview of how their office operates; the process of business registration and the types of details included in business registration, among other aspects.
The witness also confirmed that prior to 2013, business registration was not digitised. However, he was quick to add that the digitisation of business registration commenced in 2014.
However, when the State attempted to tender the three certificates into evidence as exhibits, the defence counsel objected to their admissibility.
Ruling on the Admissibility of Business Registration Certificates and Search Report, the presiding Judge, Justice Jaiteh, said: “The learned Prosecuting Counsel M. Singhateh, applied to tender three certificates of business registration belonging to the 1st accused, Paulo Djabi, together with a search report issued by the Office of the Registrar of Companies, into evidence as exhibits.”
“Learned Defence Counsel objected to the tendering of these documents on the grounds that the said certificates do not represent all the businesses registered in the name of the 1st Accused, and further questioned whether a comprehensive search of the 1st accused's registered businesses had been properly conducted.”
“In response, the prosecution submitted that the defence had not challenged the authenticity or genuineness of the documents, but rather raised an issue as to whether these were the only businesses registered in the name of the 1st accused. Counsel argued that the proper test for admissibility of documentary evidence is relevant, as provided under Section 3 of the Evidence Act, 1994, and urged the court to dismiss the objection and admit the documents into evidence.”
Jaiteh added: “I have carefully listened to the submissions of both counsels and examined the documents sought to be tendered. The law is settled that the primary test of admissibility of evidence is relevant, not the number or exclusivity of the documents tendered. Once a document is relevant to a fact in issue, it is admissible irrespective of any perceived inadequacy or incompleteness raised by the opposing party.”
“Upon review, the certificates of business registration are in the name of Paulo Djabi, and the accompanying search report emanates from the Office of the Registrar of Companies.
Considering that the information and bill of indictment relate to charges of money laundering, these business registrations are clearly relevant to establishing the financial and business activities of the 1st accused, which form material facts in issue.”
“The objection by defence counsel that the documents may not cover all the businesses owned by the 1st accused does not in my view, affect their admissibility. Such an argument goes to the weight to be attached to the evidence, not its admissibility. I therefore find the objection to be misconceived and devoid of merit, and it is accordingly overruled.”
“The documents are hereby admitted into evidence and marked as follows:
- Exhibit P16: Certificate of Business Registration in the name of Paulo Djabi, trading as Envy Club House, SRN 2100394256, dated 18th November 2024.
- Exhibit P17: Certificate of Business Registration in the name of Paulo Djabi, trading as Always Win, SRN 2100394256, dated 28th July 2025.”
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