Introduction
The convergence of law and technology is reshaping the global legal landscape, with Virtual Reality (VR) emerging as a transformative tool in common law jurisdictions. From immersive courtroom simulations to advanced dispute resolution platforms, VR is revolutionising how legal professionals learn, litigate, and deliver justice.
In Nigeria, Africa’s largest common law system by population, VR presents a unique opportunity to modernise legal practice, enhance judicial efficiency, and expand access to justice. The Evidence (Amendment) Act 2023 (The Amended Act) has updated Nigeria’s legal framework to accommodate technological advancements, including electronic records and digital signatures, providing a robust foundation for VR’s integration into judicial processes.1 This article explores global VR applications in legal practice, proposes implementation models for Nigeria, and examines the legal and ethical considerations under the amended Evidence Act to ensure VR’s effective adoption.
1. From Gaming to the Gavel: How Common Law Jurisdictions Are Using Virtual Reality
Technology is not merely enhancing legal tools—it is redefining the practice of law. In common law jurisdictions, VR is being integrated into judicial processes, legal education, and evidence presentation, offering valuable lessons for Nigeria.
In June 2022, the UK Ministry of Justice launched a pioneering VR training initiative aimed at improving the capabilities of magistrates and legal aid professionals in managing domestic abuse cases.2 This program formed part of a wider strategy to strengthen the family court system’s approach to domestic violence, aligning with the objectives of the Cafcass Domestic Abuse Learning and Improvement Plan.2B The VR training was designed to deepen participants’ understanding of domestic abuse dynamics and enhance their skills in navigating related legal proceedings.
Similarly, the University of Westminster’s Virtual Courtroom Project, evaluated through the JUSTICE virtual trial experiments, illustrates the transformative potential of VR in legal education and courtroom simulation. These trials enabled jurors, witnesses, and observers to participate in realistic courtroom environments remotely, fostering improved comprehension of courtroom roles, clearer sightlines, and synchronized document viewing. Respondents reported that the VR-enabled interactions closely mirrored the dynamics of physical trials, enhancing both procedural understanding and advocacy skills.3
In the United States, the historic use of VR occurred in the landmark case of State of Florida v. Miguel Rodriguez Albisu on December 14, 2024, when Broward County Judge Andrew Siegel donned an Oculus Quest 2 headset to view a virtual reality simulation of the incident from the defendant’s perspective—believed to be the first time VR was formally introduced into a criminal hearing in American courtrooms. Also, a study by the University of South Australia supports this innovation, showing that VR, through 3D headsets, enhances jury comprehension by immersing them in crime scenes, such as car crashes or violent incidents. Developed with input from legal professionals and law enforcement, these VR simulations improve the precision of evidence presentation, enabling jurors to make better-informed decisions. The increasing use of VR in courtroom settings and legal training highlights its capacity to modernise justice delivery in the digital age—presenting a forward-looking model that Nigeria could adapt and implement.5
These global precedents highlight VR’s versatility in judicial and educational settings. For Nigeria, the Amended Act provides a legal framework for admitting VR-generated electronic records as evidence, facilitating courtroom integration.6
2. Beyond the Bar: VR as a Tool for Legal Education and Continuing Professional Development
VR can democratise legal education in Nigeria, equipping young lawyers with practical skills before they’re assimilated into professional practice. By simulating real-world scenarios, VR addresses disparities in training opportunities across regions.
Globally, legal education is embracing innovation through VR, offering immersive, simulation-based learning experiences that mirror the demands of real-world legal practice. Much like the U.S. shift toward practical skill-building in the NextGen Bar Exam, VR is being integrated into law school curricula to develop key competencies such as advocacy, client counseling, and dispute resolution.
By placing students in curated, role-play scenarios, VR enables them to apply legal principles in dynamic contexts while receiving immediate, iterative feedback. This approach not only reinforces core lawyering skills but also supports the formation of professional identity, helping students see themselves as future practitioners.
As experiential learning becomes central to legal education, VR emerges as a powerful pedagogical tool—enhancing realism, promoting reflective practice, and surpassing traditional, lecture-based instruction in preparing students to meet the complex challenges of modern legal practice.7 These tools provide experiential learning that traditional methods cannot replicate.
In Nigeria, the Nigerian Law School/Continuing Legal Education (CLE) authorities can also leverage VR to standardise training. By partnering with edtech firms, law schools in Yola, Enugu, and Abuja could develop VR-based legal clinics and trial simulations, enabling students to practise advocacy in simulated disputes/trials. The Amended Act 2023 supports this by recognising electronic records, such as VR-generated training materials, as admissible documents, provided they meet authentication requirements.8 This legal backing ensures that VR-based educational tools can be seamlessly integrated into Nigeria’s legal curriculum.
3. Virtual Adjudication: Dispute Resolution in the Age of Immersive Technology
VR’s immersive neutrality can enhance Alternative Dispute Resolution (ADR), litigation, and court processes, particularly in emotionally charged disputes. By creating virtual environments that reduce anxiety and improve focus, VR offers a novel approach to dispute resolution.
The UK Civil Justice Council (CJC) has recommended the adoption of VR to improve the court experience for victims of domestic abuse by providing immersive environments that reduce intimidation and enhance understanding of courtroom procedures. According to BBC, it’s being used to enhance judicial understanding of domestic abuse victims’ experiences in family courts. A VR film titled Through the Eyes of Another, developed by Police and Crime Commissioners from Cleveland, Durham, and Northumbria in collaboration with Teesside University, immerses viewers in the journey of an abusive relationship. The resource, based on real victim testimonies and endorsed by former Supreme Court President Baroness Hale, aims to humanise court proceedings by helping judges and court staff better grasp the psychological impact of abuse. It is described as a transformative, empathetic judicial training tool9 demonstrating VR’s potential to enhance access to justice.
In Nigeria, the Lagos Multi-Door Courthouse (LMDC) and National Industrial Court of Nigeria (NICN) could adopt VR mediation rooms for tenancy disputes or trade, labour disputes respectively. The Amended Act supports this by recognising information in electronic form, such as VR mediation records, as equivalent to written documents, provided they are accessible for subsequent reference.10 Additionally, the Amended Act allows electronically deposed affidavits, facilitating remote VR-based mediation.11 These provisions enable Nigeria to implement VR in ADR, making justice more accessible, especially in remote areas.12
4. Judicial Innovation in Nigeria: From e-Filing to Immersive Justice
Nigeria’s judiciary has recently embraced technology in phases, from e-filing to virtual hearings. VR represents the next frontier in this digital evolution, with the Amended Act providing a legal foundation for its adoption.
Pilot programmes in courts like the Federal High Court or Lagos State Judiciary could test VR in criminal and civil trials. For instance, VR reconstructions could enhance evidence presentation in land/property and construction disputes or accident cases in factories, making complex evidence more accessible to judges. The Amended Act deems electronic records, such as VR-generated simulations, admissible as documents if authentication conditions are met, ensuring their reliability in court.13 Partnerships with LegalTech startups could develop VR-integrated evidence platforms, which aligns with the Amended Act, empowering the Minister of Justice to prescribe conditions for admitting new classes of evidence.14
VR can also address Nigeria’s case backlog by streamlining pre-trial processes. Virtual pre-trial or case management conferences, supported by the provisions of the Amended Act, allow for audio-visual proceedings, which could reduce physical court appearances, saving time and resources.15 The National Industrial Court’s adoption of virtual hearings demonstrates the judiciary’s readiness for VR adoption.
5. Legal and Ethical Considerations: What Must Be in Place for VR to Thrive
VR’s adoption in Nigeria must be grounded in a formidable legal and ethical framework to ensure procedural fairness and public trust. The Evidence (Amendment) Act 2023 provides a starting point, which requires further regulatory clarity needed in areas such as:
- Standards for authentication and integrity of VR-based evidence or simulations
- Guidelines for admissibility of immersive or reconstructed experiences in court
- Judicial protocols for the use of headsets or virtual environments during hearings
- Safeguards against prejudicial impact and bias in immersive presentations
- Privacy and data protection for individuals involved in VR-based legal education or proceedings
Until such specific procedural rules and evidentiary standards are developed—possibly through amendments to court practice directions—VR’s use in Nigerian legal practice will remain experimental and limited in formal settings.
The Amended Act outlines authentication requirements for electronic records, which implications extend to VR simulations, including verifying digital signatures.16 The rules of Courts must establish guidelines to ensure VR evidence meets these standards, balancing probative value against risks of manipulation. a safeguard crucial for maintaining the security and credibility of VR-generated evidence. 17 In parallel, ethical guidelines must be established—especially for non-litigious uses such as mediation and client consultations—to ensure data privacy, informed consent, and responsible use. Accordingly, the development of certification standards for VR tools, as contemplated by the Act, should include rigorous testing for accuracy, reliability, and neutrality, to prevent unintended bias or unfair influence in judicial outcomes.18
The Nigerian Bar Association (NBA) and National Judicial Council (NJC) should collaborate with technology experts to develop these frameworks, ensuring VR’s integration aligns with Nigeria’s legal and cultural context.
6. VR Courtroom Challenges & Practical Considerations
While VR offers transformative potential, its integration into courtrooms raises significant challenges that Nigeria must address to ensure fairness and reliability. The historic use of VR in State of Florida v Miguel Rodriguez Albisu, underscores both the promise and pitfalls of VR evidence.19
A key challenge is ensuring the accuracy and authenticity of VR simulations. As Judge Scott Schlegel noted, “How do we ensure the data used to create these environments is complete and untampered with? What expertise is needed to verify the accuracy of a VR recreation? In Nigeria, courts must establish protocols to validate VR data, aligning with requirement that electronic records meet specific conditions for admissibility.20
Furthermore, expert testimony may be required to authenticate VR simulations, ensuring they are not manipulated to favour one party. Additionally, VR’s immersive nature can evoke strong emotional responses, potentially overshadowing factual evidence and introducing bias. Different viewing angles or headset adjustments may lead to inconsistent interpretations with a judge, complicating fair adjudication.
Practical considerations include accessibility and cost. VR headsets and software require significant investment, which may strain Nigeria’s judicial budget. Ensuring equitable access for all parties, including indigent litigants, is critical to prevent disparities in justice delivery.21 Cybersecurity is another concern, as VR data could be vulnerable to hacking or unauthorized access, necessitating robust protection protocols under authentication requirements of the Amended Act.22
Courts must also train judges, lawyers, and staff to use VR effectively, as inadequate training could undermine its benefits. Nigeria can address these challenges by developing clear admissibility rules, investing in training, and partnering with technology experts to create cost-effective, secure VR solutions.
7. Conclusion: A Call for Strategic Adoption—Leadership from the Bar and the Bench
VR’s integration into Nigeria’s legal system is a strategic imperative to enhance justice delivery in a digitally evolving world. The Evidence (Amendment) Act 2023 provides foundational legal framework for adopting VR, recognising electronic records and audio-visual proceedings as valid components of judicial processes.
The NBA, its sections and fora should integrate VR pilots into CPD programmes, offering workshops to familiarise lawyers with immersive technologies. The judiciary also should conduct VR awareness workshops and sandbox trials to test applications in real-world settings.
At the 19th International Business Law Conference in July, the NBA-SBL featured a fringe show exploring how virtual reality (VR) can be deployed in legal practice. Building on this, the ongoing NBA Conference continues the conversation, with the breakout plenary session on 25 August addressing both the advantages and challenges of deploying VR. Introducing a dedicated “FutureTech and the Law” track in the NBA Section on Business Law’s Annual Conference would further enrich these discussions, providing a structured platform for dialogue on VR’s role in shaping the future of legal practice. By leveraging the Evidence (Amendment) Act 2023, Nigeria can position itself as a promoter of judicial innovation in Africa, ensuring equitable access to justice and preparing legal professionals for a technology-driven future.
Endnotes
1. Evidence (Amendment) Act 2023, ss 84(a)–84(d) & 255.
2. Ministry of Justice, The Family Court and Domestic Abuse: Achieving Cultural Change (Gov.uk, 25 June 2020)<https://www.gov.uk/government/publications/the-family-court-and-domestic-abuse-achieving-cultural-change/the-family-court-and-domestic-abuse-achieving-cultural-change-accessible-version> Accessed 27 June 2025
2B. The Cafcass Domestic Abuse Learning and Improvement Plan, initiated in response to the 2020 Ministry of Justice’s Expert Panel on Harm in the Family Courts report, is a comprehensive strategy by the Children and Family Court Advisory and Support Service (Cafcass) to improve its response to domestic abuse in family court proceedings
3. Wend Teeder, Linda Mulcahy and Emma Rowden, Virtual Courtroom Experiment: Data Report (JUSTICE, 2020) https://files.justice.org.uk/wp-content/uploads/2020/10/06165906/FINAL-JUSTICE-III_Exploring-the-case-for-Virtual-Jury-Trials-during-the-COVID.pdf accessed 27 June 2025
5. Lars Daniel, ‘Historic First—Judge Dons Oculus VR Headset To Experience Crime’ (Forbes, 6 January 2025) https://www.forbes.com/sites/larsdaniel/2025/01/06/historic-first-judge-dons-oculus-vr-headset-to-experience-crime Accessed 27 June 2025
6. Dr Andrew Cunningham, ‘Bringing the Jury to the Crime Scene via a 3D Headset’ (22 July 2021) https://www.unisa.edu.au/media-centre/Releases/2021/bringing-the-jury-to-the-crime-scene-via-a-3d-headset/ Accessed 27 June 2025.
7. Ibid Footnote 1.
8. Mitch Zamoff, ‘The Seven Essential Law School Simulation Courses’ (2024) 2024 Utah L Rev 997. Also find out more about NextGen Bar Exams here: https://nextgenbarexam.ncbex.org/
9. EAA 2023, s 84(b).
10. Louise Hobson, ‘Virtual Reality Should Be Used in Court, Judges Say’ (BBC News, 16 September 2024) https://www.bbc.com/news/articles/cp8n67wxgjro accessed 27 June 2025.
11. EAA 2023, s 84(a).
12. EAA 2023, s 108(2).
13. ibid.
14. EAA 2023, s 84(b).
15. EAA 2023, s 255.
16. EAA 2023, ss 109–110.
17. EAA 2023, s 84(c).
18. EAA 2023, s 84(d)
19. Ibid (n14).
20. Ibid (n4)
20. Ibid (n13)
21. Ibid (n19)
22. (n16)
Written by Adeola Osifeko LLB,BL,LLM,ACIS,ABR. She can be reached on 07074453571, adeola@aeolawpractice.com
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