offence contrary to Section 122 of the Penal Code Law and punishable under the
same law.
That you Ibrahim Usman ‘M’, 35 years, civil servant of Gwagwalada FCT Abuja,
and Shuaibu Yinusa ‘M’, 25 year of the same address within the jurisdiction of this
Court on or about the 18th of April, 2015 do criminally conspired together and forged
Nigeria Security and Civil Defence Corps appointment letters and fraudulently issued
same to so many Nigerians as original and genuine appointment letters and thereby
committed an offence contrary to Section 362 of the Penal Code and punishable
under Section 362 of the same Code.
The Four Count Charge was separately read over to each of the Defendants; they
understood same and pleaded Not guilty to each and every count.
The prosecution opened its case and called four witnesses in proof thereof
The 1st Prosecution Witness is Audu Gambo Jankada. He stated that he lives at 133
Phase 3, Gwagwalada. That he is a public servant with the NSCDC Gwagwalada
Divisional Office but presently at Kwali. That he joined the Corps in 2005. He is a

That his duties are to carry out intelligence and information

gathering, investigating complaints of cases, arresting offenders and protection of
critical infrastructures. That he knows the Defendants in this case.
On the 29th day of April, 2015 one Abutu James Simon came to their office with an
appointment letters of NSCDC to find out if it was authentic. They scrutinized it and
found it to be fake.
On interrogation he informed them that one Eze Peace helped him to procure the
letter. They invited the said Peace Eze who admitted but stated that he got the letter
from the Defendants at the rate of N200,000 per letter. That he paid N600,000 in
four installments to him. They went together with Eze Peace to the house of the


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