COMPARATIVE ANALYSIS OF CORPORATE HOMICIDE LEGISLATIONS IN SELECTED JURISDICTIONS: LESSONS FOR NIGERIA

Abstract

The issue of corporate homicide, a globally relevant concern involving unlawful killings resulting from corporate misconduct, is a significant focus within legal and regulatory frameworks. This paper provides a comparative analysis of corporate homicide legislation in selected jurisdictions—Australia, Canada, the United Kingdom, and the United States of America—to extract insights applicable to Nigeria. It compares these jurisdictions' statutory provisions, judicial interpretations, and enforcement strategies to identify best practices and areas for improvement in Nigeria's legal framework. Through a comparative approach utilising doctrinal methodology, the paper examined essential elements such as the scope of corporate liability, standards of proof, penalties, and the effectiveness of enforcement mechanisms, using primary and secondary sources of data collection. The findings revealed diverse approaches, from the strict penalties in the United Kingdom to comprehensive liability standards in the United States of America and the balanced approaches in Canada and Australia, reflecting nuanced legislative developments and judicial interpretations. Strengths and weaknesses in each system were identified, leading to specific recommendations for Nigeria, including adopting explicit statutory definitions, suitable penalties for corporations, and enhanced enforcement mechanisms aimed at addressing gaps in Nigeria’s current legal framework and improving the effectiveness of corporate homicide legislation. This comparative analysis contributes to the broader discourse on corporate responsibility and provides actionable insights for enhancing Nigeria’s approach to corporate homicide, ultimately promoting greater corporate accountability and public safety.