2) Secondly, the Doctrine of Issue Estoppel was inapplicable to Criminal Cases and does not apply to this case. He distinguished the cases cited by the Defence, starting with the case of ARO VS FABOLUDE (1983) NSCC PAGE 43, which he argued was a Land Dispute Matter. Further, the case of HUNTER VS CHIEF CONSTABLE OF WEST MIDLANDS POLICE (1981) 3 ALL ER AT 727 was in regard to a Claim for Damages filed by Hunter against the Police Officers he claimed assaulted him, and this was a Civil Suit. The House of Lords, in this case went on to hold that the Doctrine of Issue Estoppel has no place in English Criminal Law. Finally distinguished, was the case of DPP VS HUMPHREYS (1976) 2 ALL ERAT 497, PER LAW LORDS VISCOUNT DILHOURNE; DEVLIN AND HAILSHAM, where it was severally held that there was a lack of mutuality between the application of the Rule against Double Jeopardy in Criminal Cases and the Rule of Finality in Civil Litigation. They also had held that to hold Issue Estoppel applicable in Criminal Cases would be to import a new doctrine, as it had not and never had a place in English Criminal Law. In Criminal Cases, it takes the form of Double Jeopardy of which the simplest application is to be found in the Plea of Autrefois Convict and Autrefois Acquit. Further, it was held that the Civil Doctrine of Issue Estoppel is based on the necessity for Finality between Private Litigants, whereas the Doctrine in Criminal Proceedings is based on the Prohibition of Double Jeopardy. Learned Silk, representing the Prosecution also referred to Archbold on Criminal Pleading, Evidence and Practice 2012, at Paragraph 4-221, where it was stated that the Civil Doctrine of Issue Estoppel has no application to Criminal Law. Rotimi Jacobs SAN, further referred the Court to the 1999 Constitution, As Amended in Section 36 (9), on Double Jeopardy as well as Sections 238, 239, 240 and 277 of the Administration of Criminal Justice Act 2015, to submit that the Doctrine of Issue Estoppel was not recognized in Criminal Proceedings, and cited the cases of FRN VS IGBINEDION (2015) 2 NWLR PT. 1444, AT 475 PER OGUNWUMIJU JCA AND FRN VS NWOSU (2016) 17 NWLR PT. 1542, 226 AT 294-295 AND 305-306. According to Learned Silk, there is no question of Double Jeopardy, as the Defendant was not charged or acquitted as per Exhibit D21B and the Order of Acquittal made by the Federal High Court in Kaduna, cannot be extended to the Defendant as guaranteed by the 1999 Constitution. Also for the Defendant to fall under the above-cited Sections of the Administration of Criminal Justice Act, providing for Autrefois Convict or Acquit, he must show that he had been earlier tried, convicted or acquitted for the same Offence. He pointed out that even Sections 239 and 240 created an exception to the Rule as an acquitted or convicted Defendant may afterwards be tried for a distinct Offence on separate Charges in certain circumstances. In this case, he argued that the Defendant was not a Party to Exhibit D21B and he pointed out that the cases cited by the Defence of IKENI VS EFAMO (2001) 10 NWLR PT 720 AT 1; AJIBOYE VS ISHOLA (2006) 13 NWLR PT 998, AT 628 AND ADEDAYO VS BABALOLA (1995) 7 NWLR PT 408 AT 383, all referred to situations where the Parties were the same. Further, on the reliance by the Defence on the case of TIJANI IKOTUN VS OBA SAMSON OYEKANMI (2008) 10 NWLR PT 1094 AT 100, Learned Silk submitted that the Supreme Court never held that the Parties in Issue Estoppel need not be the same. What is required is that Parties or their Privies must be involved. The provisions of Section 173 of the Evidence Act (2011) was also cited by Learned Silk, Jacobs to the effect that every Judgment is conclusive proof, as against the Parties and their Privies, of facts directly in issue, unless evidence was admitted in the action in which Judgment was delivered, which 18