CASE IDENTIFICATION
EDITORIAL SUMMARY
Editorial — not part of the judgment as delivered
Facts of the Case
The appellant was charged before the High Court of Jigawa State, Ringim Judicial Division, on five counts of causing grievous hurt and one count of culpable homicide, arising from an attack on 3 September 2013 at Nagarta Block Company, Ringim. Upon arraignment, he pleaded not guilty. The prosecution called five witnesses and tendered the appellant’s extra-judicial confessional statement (exhibits A1 and A2). The appellant testified in his defence and called no other witness.
The trial Court acquitted and discharged the appellant of the offence of culpable homicide but found him guilty on four counts of causing grievous hurt under Section 248(2) of the Penal Code Law of Jigawa State, 2012. He was sentenced to seven years imprisonment on each count, with the sentences to run consecutively. His appeal to the Court of Appeal was dismissed on 22 September 2021. Being further dissatisfied, he appealed to the Supreme Court.
Issues for Determination
ISSUE 1:
Whether the lower Court was right in affirming that the respondent proved the offence against the appellant beyond reasonable doubt in view of the discrepancies, inconsistencies and contradictions in the case of the Respondent.
Decision / Holding
The Supreme Court dismissed the appeal and affirmed the decisions of the trial Court and the Court of Appeal, holding that the prosecution proved its case beyond reasonable doubt through uncontroverted direct evidence of the victims and the appellant’s confessional statement, and that the alleged discrepancies were minor and immaterial.
Ratio Decidendi / Principles
Obiter Dicta
Orders of Court
Appeal dismissed. The decisions of the trial Court and the Court of Appeal were affirmed. Consequential orders as per the lead judgment.
APPEARANCES
Counsel for the Appellant(s)
Chief Uche F. Ewule, with him, G.C. Uche-Ewule, Esq.
Counsel for the Respondent(s)
Mohammed Sani Abba, Esq. (with fiat of the Attorney General of Jigawa State)
Amicus Curiae
None
JUDGMENTS / OPINIONS OF THE COURT
Authoritative judicial text as delivered
Lead / Majority Opinion
— (DELIVERED BY MOORE ASEIMO ABRAHAM ADUMEIN, J.S.C. (DELIVERING THE LEADING JUDGMENT):)
The appellant was the defendant in Charge No: JDU/49C/2017 wherein he was charged as follows:
“FIRST HEAD OF THE CHARGE
That you, ABBA ABBANI ‘m’ on or about the 3rd day of September, 2013 at about 1230 hrs at Nagarta Block Company, Ringim Town, Ringim Local Government Area within the Jigawa Judicial Division did commit an illegal act to wit used machete and inflicted serious injury on one Ahmed Abdullahi by cutting him on his hand and you thereby committed an offence of causing grievous hurt punishable under Section 247 of the Penal Code Law Cap P3, Laws of Jigawa State, 2012.
SECOND HEAD OF THE CHARGE
That you, ABBA ABBANI ‘m’ on or about the 3rd day of September, 2013 at about 1230hrs at Nagarta Block Company, Ringim Town, Ringim Local Government Area within the Jigawa Judicial Division did commit an illegal act to wit used machete and inflicted injury on one Hafiszu Aminu by cutting him with a machete on his hand as a result of which he got fracture and you hereby committed an offence of causing grievous hurt punishable under Section 247 of the Penal Code Law Cap. P3 Laws of Jigawa State, 2012
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THIRD HEAD OF THE CHARGE
That you ABBA ABBANI ‘m’ on or about the 3rd day of September, 2013 at about 1230hrs at Nagarta Block Company, Ringim Town, Ringim Local Government Area within the Jigawa Judicial Division did commit an illegal act to wit used machete and inflicted injury on one Abubakar Usman by cutting him with a machete on his hand, neck and head and you thereby committed an offence of causing grievous hurt punishable under Section 247 of the Penal Code Law, Cap. P3 Laws of Jigawa State, 2012.
FOURTH HEAD OF THE CHARGE
That you ABBA ABBANI ‘m’ on or about the 3rd day of September, 2013 at about 1230hrs at Nagarta Block Company, Ringim Town, Ringim Local Government Area within the Jigawa Judicial Division did committed an illegal act to wit used machete and injured one Auwalu Maje and you thereby commit an offence of causing grievous hurt punishable under Section 247 of the Penal Code Law Cap P3 Laws of Jigawa State, 2012.
FIFTH HEAD OF THE CHARGE
That you ABBA ABBANI ‘m’ on or about the 3rd day of September, 2013 at about 1230hrs at Nagarta Blocks Company, Ringim Town, Ringim Local
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Government Area within the Jigawa Judicial Division caused the death of one Magaji Abdullahi ‘m’ by cutting him with machete on his head, an act that is probable to cause his death, you thereby committed an offence punishable under Section 221(b) of the Penal Code Law Cap P3 Laws of Jigawa State, 2012.”
Upon his arraignment in the High Court of Jigawa State, holden at Ringim, the appellant pleaded not guilty and the case proceeded to trial. The prosecution fielded five witnesses and tendered exhibits ‘”A1″ and “A2” – Hausa and English versions, respectively, of an alleged extra-judicial confessional statement of the appellant. In his defence, the appellant testified as DW1 and did not call any witness. At the close of evidence, and after the learned counsel for the contending parties waiving their rights to address the trial Court, judgment was delivered on 06/12/2017 whereby the appellant was acquitted and discharged of the offence of culpable homicide. However, the appellant was found guilty of the offence of causing grievous hurt, punishable under Section 248(2) of the Penal Code Law, Cap.P3, Laws of Jigawa State, 2012. The appellant was sentenced “to
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7 years imprisonment on each count of the offence of causing grievous hurt with the sentences to consecutively (one after the other) commencing from the date the victim(sic) was detain(sic) to await his trial” – see page 49 of the record of appeal.
The appellant appealed to the Court of Appeal which, on 22/09/2021, delivered its judgment affirming the decision of the trial Court. Being further dissatisfied, the appellant appealed to this Court vide a notice of appeal filed on 20/10/2021 and which contains five grounds.
In his brief of arguments, Chief Uche F. Ewule, learned counsel for the appellant formulated lone issue for determination:
“Whether the lower Court was right in affirming that the respondent proved the offence against the appellant beyond reasonable doubt in view of the discrepancies, inconsistencies and contradictions in the case of the Respondent.”
The above sole issue isolated by the appellant was adopted by Mohammed Sani Abbas, Esq., learned counsel who settled the respondent’s brief.
The substance of the appellant’s arguments is that the respondent did not prove its case beyond reasonable doubt because: “There
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are a lot of discrepancies, inconsistencies and contradictions in the evidence of the prosecution”. In this respect, learned counsel for the appellant contended specifically that “exhibits A1 and A2 are not consistent with the evidence of PW1, PW2, PW3 and PW4”. Counsel further submitted that the appellant’s confession in exhibits “A1″ and “A2” was in respect of culpable homicide in count No.5 of the charge for which he was discharged and, in exhibit A2, the appellant never confessed to have injured PW1, PW2, PW3 and PW4. Learned counsel, for the appellant therefore, posited: “how did the trial Court link the said confessional statement to convict him in respect of the offences of grievous harm in counts 1-4”?
Amongst other reasons, the learned counsel urged the Court to resolve the lone issue in favour of the appellant and allow the appeal because:
“…all counts in the charge stated that the Appellant used machete to inflict serious injuries on all the victims of the offences whereas PW1 gave evidence that the Appellant attacked them at the frontage of Abba Kassim’s (Garkuwar Ringim’s) house with an axe. PW2 testified that Appellant
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attacked them with Cutlass and a dagger. PW3 stated that the Appellant attacked him with dagger. PW4 testified that the Appellant attacked them with an axe. In the purported confessional statement accepted by the lower Courts the Appellant used machete.”
In opposition to the appellant arguments, it submitted, inter alia, as follows:
“On the issue of discrepancies as to date, time and place as well as different weapons stated by the evidence of PW1-PW4, the law is trite that peripheral discrepancies or variations in description of the weapon used or date of the offence and place is not enough to discharge an accused of guilt especially as those variations or discrepancies do not go to the root of the case. My Lords, it is pertinent to state here that the lower Court dealt with the issue of inconsistency or variations between the contents of the charge and the witnesses evidence aptly, upon which the Appellant contends that based on such variations and inconsistencies, the lower Court and trial Court were in error. The Court of Appeal succinctly settled this issue very appropriately and aptly and reiterated the correct principle of law on the
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issue.”
In urging the Court to resolve the issue against the appellant, learned counsel for the respondent submitted that the alleged inconsistencies in the prosecution’s case were not material, as the appellant clearly admitted committing the offences.
In the lower Court, the appellant raised a sole issue for determination which he couched thus:
“Whether from the evidence before the trial Court, the Respondent proved its case beyond reasonable doubt to warrant the conviction of the Appellant on counts 1, 2, 3 and 4”.
A perusal of the record of appeal, especially the appellant’s brief spanning pages 60 to 79, shows that the learned counsel for the appellant canvassed arguments in the Court below which are substantially the same as he has done in this Court. In dismissing the appeal, the Court of Appeal held, inter alia, that: “It is obvious that the alleged contradictions upon which counsel to the appellant built his contentions against the judgment of the lower Court were nothing more than minor discrepancies that did not in any way affect the substance and materiality of the case made out against the appellant”.
In its judgment,
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the trial Court per Hon. Justice Abubakar M. Sambo, made the following specific findings, amongst others:
(i) that the evidence of PW1 was “uncontroverted and clear in identifying the accused person and … that the accused person struck him on his left elbow while he was seated in the company of PW2 (Ahmed Abdullahi) PW4 (Auwalu Maje) and one Yaya”;
(ii) that the injuries caused by the acts of the appellant were “grievous in nature hence PW1 sustained a fracture which took him about 2 months to treat” at two different hospitals;
(iii) that the appellant used “an axe” to cause the injuries on PW1;
(iv) that PW2’s evidence was uncontroverted, cogent and credible to the effect that the appellant who was his (PW2’s) co-worker at Nagarta Block Industry, Ringim, inflicted severe wounds on PW2 with a “cutlass/dagger”
(v) PW3 was also uncontroverted and credible and that the appellant, who was PW3’s co-worker at Nagarta Block Industry, caused PW3 severe bodily injury when he struck him with a dagger”;
(vi) PW4’s evidence that the appellant, his neighbour at Majiya Quarters, Ringim, “struck him with an axe on the 3rd of September,
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2013” and caused him (PW4) “severe and grievous injuries”; and
(vii) that the appellant’s confessional statement, recorded by PW5 (Sule Yelmi) – a police officer attached to the Police Criminal Investigation Department Office, Dutse was properly made.
A careful examination of the record of appeal reveals clearly that none of the above specific findings of the trial Court was appealed against by the appellant. The principle of law, which is now trite, is that findings not appealed against are deemed to be correct. See, for example, the cases of Ijale v. Leventis (1959) 4 FSC 108, Odiase v. Agho (1972) 3 SC 73; – Dibia v. State (2017) 12 NWLR (Pt.1579) 196 and Col. Mohammed Sambo Dasuki v. Federal Republic of Nigeria (2018) 10 NWLR (Pt. 1627) 320 at 337.
The lower Court rightly refused to interfere with the findings made by the trial Court. The findings in this case are, therefore, concurrent by the two lower Courts.
This Court, from a long line of its decisions, is usually hesitant in disturbing concurrent findings by a trial Court and the Court of Appeal, unless an appellant convincingly demonstrates such findings to be perverse. See
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Kenneth Ogoala v. The State (1991) 2 NWLR (Pt. 175) 509; Gambo Musa v. The State (2009) 15 NWLR (Pt. 1165) 467; Mohammed Ibrahim v. The State (2015) 11 NWLR (Pt.1469) 164; Yohanna Danjuma v. The State (2019) 10 NWLR (Pt.1679) 184; Yusuf Sani v. The State (2021) 5 NWLR (Pt.1770) 502; Taiwo Hassan v. The State (2021) 17 NWLR (Pt. 1804) 45 and Oliver Sunday v. The State (2021) 17 NWLR (Pt.1804) 115.
The appellant’s main grouse is that there are contradictions in the evidence of the prosecution witnesses because PW1 and PW4 stated that the appellant attacked them with an “axe”; PW2 said the appellant attacked him with a “cutlass” and a “dagger”; while PW3 testified that he was attacked with a “dagger”; whereas the charge claimed that the appellant used a “machete” in inflicting injuries on these witnesses.
As stated earlier, the appellant was convicted of the offence of causing grievous hurt under Section 248(2) of the (Penal Code Law of Jigawa State, 2012. One of the recognized ingredients, relevant in this case, to be proved in a criminal accusation of causing grievous bodily hurt is that the defendant “caused the bodily harm by means of any weapon that is
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likely to cause death” as stated at page 200 of “Annotated Copy of the Penal Code” by S.S. Richardson.
In this case, the appellant made an extra-judicial statement in the Hausa language (exhibit (“A1″), which was translated into English language and admitted as exhibit “A2”. In exhibit “A2″, the appellant stated that he used a “machete” to cause the grievous bodily harms or hurts in issue on his victims (PW1, PW2, PW3 and PW4). Therefore, it made no difference when these victims, all of who became unconscious after the attacks, described the weapon used by the appellant differently. Whether the appellant attacked his victims with a machete, an axe or a dagger is irrelevant or immaterial. What is important is that a bodily harm by any of these weapons can cause death.
It should be noted that the alleged contradictions or discrepancies in the evidence of the prosecution witnesses are quite minor or trivial and did not cause any damage to the prosecution’s case.
The law is that a mere minor contradiction, in the evidence of witnesses presented by a party, is inconsequential and will not affect the case of that party. For any
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contradictions in the evidence of the witnesses to adversely affect the prosecution’s case, the contradictions “must be material and fundamental to the case… And go to the root of the charge against the accused” – per Chima Centus Nweze, JSC in the case of Taiwo Hassan v. The State (2021) 17 NWLR (Pt. 1804) 45 at 68 – 69. See also the cases of Kalu v. State (1988) 4 NWLR (Pt. 90) 503; Ochemaje v. State (2008) 15 NWLR (Pt. 1109) 57; Adonike v. State (2015) 7 NWLR (Pt. 1458) 237; (2015) 1 SCNJ 146 and Ifedayo v. The State (2019) 3 NWLR (Pt. 1659) 265.
The law is settled that there are three accepted ways of proving a crime and they are:
(a) direct evidence of an eye-witness or eye- witnesses;
(b) confessional statement made by the defendant; and
(c) circumstantial evidence.
The authorities, for the trite principle of law that a criminal allegation can be proved by any of the above three means or ways, are many and they include the cases of Mathew Agu v. The State (1985) NSCC Vol.16 (Pt.11) 1195; Patrick Ikemson v. The State (1989) 3 NWLR (Pt.110) 455; Nkwuda Edamine v. The State (1996) 3 NWLR (Pt.438) 350; Agboola v. The State
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(2013) 11 NWLR (Pt.1366); State v. Isah (2012)16 NWLR (Pt.1327) 613; Mbang v. State (2013) 7 NWLR (Pt.1352) 48; Ibrahim v. State (2014) 3 NWLR (Pt.1394); Michael Agboola Adeyemo v. The State (2015) 16 NWLR (Pt.1485) 311; Joseph Bille v. The State (2016) 15 NWLR (Pt. 1536) 363; Ifeanchukwu Akwuobi v. The State (2017) 2 NWLR (Pt.1550) 421; Wahab Alao v. The State (2019) 17 NWLR (Pt. 1702) 501; Andrew Koye Fekolomoh v. The State (2021) 6 NWLR (Pt. 1773) 461; Taiwo Hassan v. The State (2021) 17 NWLR (Pt.1804) 45; Nura Aliyu v. The State (2021) 17 NWLR (Pt.1805 197 and The State v. Abdulhadi Sadiq (2022) 5 NWLR (Pt. 1824) 413.
In the trial Court, the prosecution proved its case beyond reasonable doubt by the uncontroverted direct evidence of its witnesses and the confession of the appellant. The lower Court was right in affirming the decision of the trial Court.
In view of all the foregoing reasons, I hereby resolve the lone issue against the appellant. This appeal lacks merit and I dismiss it. I affirm the decision of the lower Court.
Appeal dismissed.
Concurring Opinion(s)
— MOHAMMED LAWAL GARBA, J.S.C.:
I have carefully considered the evidence adduced by the
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Respondent at the trial of the Appellant, the findings of facts by the trial Court on the basis of which he was convicted after a proper evaluation of the evidence and the decision by the Court of Appeal (Court below) affirming the conviction of the Appellant for the offences of conspiracy and causing grievous hurt. There is no reasonable doubt that the concurrent findings by the two (2) lower Courts are amply supported by the credible and uncontroverted evidence of the victims of the attack as well as the direct, unequivocal and cogent confession by the Appellant.
In that regard, after reading a draft of the leading judgment written by my learned brother, M. A. A. Adumein, JSC in this appeal, I agree with him that the appeal is bereft of merit and ought to be dismissed on the ground that this Court has no justification to interfere with the decision of the lower Courts.
See Dahiru v. State (2018) 14 NWLR (pt. 1640) 567 (SC), Aminu v. State (2020) 6 NWLR (pt. 1720) 197 (SC).
The appeal is dismissed by me too in terms of the leading judgment.
— TIJJANI ABUBAKAR, J.S.C.:
The discrepancy in the description of the weapon of attack by
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prosecution witnesses- whether it was an axe, dagger, or machete- does not amount to a material contradiction that would vitiate the conviction of the Appellant. Such a discrepancy is immaterial if the prosecution’s evidence is consistent and credible regarding the core elements of the crime: the occurrence of the attack, the fatality/injury resulting from it, and the culpability of the accused. In the instant case, the evidence of the prosecution witnesses was consistent on the fact that they were attacked by the Appellant with a weapon, and they also testified on the various degrees of injuries suffered because of the said attack. In my view, the specific description of the weapon used by the Appellant is a minor detail, and a misdescription of same in the circumstance of this case, cannot vitiate the conviction of the Appellant. I do not consider the alleged contradiction to be so material as to affect the case of the prosecution, it is so immaterial and insufficient to discredit the overall evidence adduced by the prosecution at the trial.
For this short reason and the more elaborate reasons set out in the leading judgment just delivered by my learned
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brother, ADUMEIN, J.S.C, I also hold the view that the appeal is unmeritorious and therefore deserves to be dismissed. It is hereby dismissed in its entirety by me.
Appeal dismissed.
— JUMMAI HANNATU SANKEY, J.S.C.:
I had a preview of the lead judgment just delivered by my learned brother, Moore Abraham A. Adumein, JSC. I agree with his lordship that this appeal is destitute of any redeeming feature, and must therefore be dismissed.
The complaint of the Appellant against the judgment of the Court below is basically hinged on alleged contradictions in the evidence of the prosecution witnesses. However, an examination of the alleged contradiction is in relation to the weapon used by the Appellant to inflict the grievous injuries on the prosecution witnesses (PW1 to PW4), who were his victims. The victims of the attack variously described the weapon as an axe, a dagger or a machete. The Appellant himself, in his confessional statement, said it was a machete. I am in agreement with the leading judgment that it is immaterial by what name the weapon was described by these witnesses. The injuries inflicted on the witnesses and the trauma experienced by
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them was so grave that they all passed out after the attack. What is important is that the prosecution proved that the Appellant caused the victims bodily harm by means of a weapon that is likely to cause death, and that the victims, PW1, PW2, PW3 and PW4, gave eyewitness testimonies, i.e., direct evidence, of this.
The law is trite that minor discrepancies in evidence only serve to make the case more believable. This is because when the evidence of witnesses is completely identical without any variation at all in the way and manner it is told, it is suspicious and there is a likelihood that the witnesses were schooled and the evidence rehearsed. It is only to be expected that when a story is told about an incident by individuals, they may have different perceptions of what was witnessed as human beings. A discrepancy is found in evidence where there is a variation or slight difference in the details of the testimonies of witnesses; whereas a contradiction in evidence is where witnesses give divergent accounts of the same event which cannot be reconciled. They would tell a story which would be diametrically opposed such that it would cast a doubt
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on the case presented by the prosecution. See Zakirai V The Muhammad (2017) LPELR-42349(SC); Kwenev V The State (2022) LPELR-57661 (SC). This Court has been consistent in holding that it is not every discrepancy in the evidence of witnesses that would suffice to vitiate the judgment of a trial Court. Any contradiction alleged must be shown to be material in nature and of such gravity that the Court would doubt the veracity of the witnesses and thus cast doubt on the case presented by the prosecution. See Agboola V The State (2023) LPELR-59954(SC); Idi V The State (2017) LPELR42587(SC); Kaza V The State (2008) LPELR-1683(SC); Eke V The State (2011) LPELR-1133(SC). In Agboola V The State (2023) LPELR-59954-(SC), this Court held per Augie, JSC that:
“A piece of evidence is contradictory to another when it asserts or affirms the opposite of what the other asserts. Witness testimonies can only be depicted as contradictory when they give inconsistent accounts of the same event and for the contradictions to vitiate a Court’s decision, they must be so material that they cast doubt on the case as presented. All the same, the law leaves room for minor
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discrepancies in the evidence of witnesses, which may not be fatal to the prosecution’s case…Contradictions definitely arise in evidence of witnesses-That explains the human nature and the humanity in witnesses. Although witnesses see and watch the same event, they may narrate it from different angles, in their individual peculiar focus, perspective or slant. This does not necessarily mean that the event that they are narrating did not take place. It only means most of the time that the event took place, but what led to the event was given different interpretations, arising from the senses of sight and mind dictated by their impressions and idiosyncrasies. That is why the law says that contradictions, which are not material or substantial will go to no issue. The main interest of the Court is that the witnesses are in union or unison as to the happening of the event but gave different versions in respect of the peripheral surrounding the event.”
This issue was also canvassed before the Court below. After due consideration of the Appellant’s submissions thereon, the lower Court found that the discrepancies in the evidence of the witnesses were not so
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substantial and fundamental as to warrant a rejection of the Respondent’s evidence. I agree. Therefore, I am not inclined to disturb the sound finding of the trial Court on this.
In the result, it is for these reasons and the detailed reasons set out in the lead judgment that I also dismiss this appeal. I abide by the consequential order therein.
— MOHAMMED BABA IDRIS, J.S.C.:
I have had the honour to read before now, the judgment of my Lord, Moore Aseimo Abraham Adumein, JSC, just delivered. For the reasons so comprehensively set out which I respectfully adopt as mine, I too do hereby dismiss the appeal and affirm the decision of the lower Court.
Dissenting Opinion(s)
None
REFERENCES
Research enhancement — dynamically linked
Referenced Judgments
Adonike v. State (2015) 7 NWLR (Pt. 1458) 237; (2015) 1 SCNJ 146 — cited at p. 12
Agboola v. The State (2013) 11 NWLR (Pt.1366) — cited at p. 12
Agboola v. The State (2023) LPELR-59954(SC) — cited at pp. 18–19
Aminu v. State (2020) 6 NWLR (Pt. 1720) 197 (SC) — cited at p. 14
Andrew Koye Fekolomoh v. The State (2021) 6 NWLR (Pt. 1773) 461 — cited at p. 13
Col. Mohammed Sambo Dasuki v. Federal Republic of Nigeria (2018) 10 NWLR (Pt. 1627) 320 — cited at p. 9
Dahiru v. State (2018) 14 NWLR (Pt. 1640) 567 (SC) — cited at p. 14
Dibia v. State (2017) 12 NWLR (Pt.1579) 196 — cited at p. 9
Eke v. The State (2011) LPELR-1133(SC) — cited at p. 18
Gambo Musa v. The State (2009) 15 NWLR (Pt. 1165) 467 — cited at p. 10
Idi v. The State (2017) LPELR-42587(SC) — cited at p. 18
Ifeanchukwu Akwuobi v. The State (2017) 2 NWLR (Pt.1550) 421 — cited at p. 13
Ifedayo v. The State (2019) 3 NWLR (Pt. 1659) 265 — cited at p. 12
Ibrahim v. State (2014) 3 NWLR (Pt.1394) — cited at p. 13
Ijale v. Leventis (1959) 4 FSC 108 — cited at p. 9
Joseph Bille v. The State (2016) 15 NWLR (Pt. 1536) 363 — cited at p. 13
Kalu v. State (1988) 4 NWLR (Pt. 90) 503 — cited at p. 12
Kaza v. The State (2008) LPELR-1683(SC) — cited at p. 18
Kenneth Ogolaa v. The State (1991) 2 NWLR (Pt. 175) 509 — cited at p. 10
Kwenev v. The State (2022) LPELR-57661 (SC) — cited at p. 18
Mathew Agu v. The State (1985) NSCC Vol.16 (Pt.11) 1195 — cited at p. 12
Mbang v. State (2013) 7 NWLR (Pt.1352) 48 — cited at p. 13
Michael Agboola Adeyemo v. The State (2015) 16 NWLR (Pt.1485) 311 — cited at p. 13
Mohammed Ibrahim v. The State (2015) 11 NWLR (Pt.1469) 164 — cited at p. 10
Nkwuda Edamine v. The State (1996) 3 NWLR (Pt.438) 350 — cited at p. 12
Nura Aliyu v. The State (2021) 17 NWLR (Pt.1805) 197 — cited at p. 13
Ochemaje v. State (2008) 15 NWLR (Pt. 1109) 57 — cited at p. 12
Odiase v. Agho (1972) 3 SC 73 — cited at p. 9
Oliver Sunday v. The State (2021) 17 NWLR (Pt.1804) 115 — cited at p. 10
Patrick Ikemson v. The State (1989) 3 NWLR (Pt.110) 455 — cited at p. 12
State v. Abdulhadi Sadiq (2022) 5 NWLR (Pt. 1824) 413 — cited at p. 13
State v. Isah (2012) 16 NWLR (Pt.1327) 613 — cited at p. 13
Taiwo Hassan v. The State (2021) 17 NWLR (Pt. 1804) 45 — cited at pp. 10, 12, 13
The State v. Abdulhadi Sadiq (2022) 5 NWLR (Pt. 1824) 413 — cited at p. 13
Wahab Alao v. The State (2019) 17 NWLR (Pt. 1702) 501 — cited at p. 13
Yohanna Danjuma v. The State (2019) 10 NWLR (Pt.1679) 184 — cited at p. 10
Yusuf Sani v. The State (2021) 5 NWLR (Pt.1770) 502 — cited at p. 10
Zakirai v. Muhammad (2017) LPELR-42349(SC) — cited at p. 18
Referenced Statutes
Penal Code Law, Cap. P3, Laws of Jigawa State, 2012, Sections 221(b), 247, 248(2) — cited at pp. 1–3
