after his victim had died. It was held that he was estopped from denying that he caused grievous bodily harm to the deceased without lawful excuse and with intent to do so. The result was that only issues as whether the grievous bodily harm committed by Hogan and the availability of a plea of provocation could be treated as live issues, nonetheless, Hogan was acquitted. However, R VS HOGAN, was overruled in DIRECTOR OF PUBLIC PROSECUTIONS VS HUMPHRYS (1977) AC PAGE 1; (1976) 2 ALL ER PAGE 497, where the House of Lords unanimously declared that Issue Estoppel does not apply in English Criminal Proceedings. Humphrys was acquitted on a charge of driving a motor vehicle on July 18, 1972 while disqualified from doing so. The only issue at the Trial was whether the Constable was correct in identifying him as the man he had stopped after seeing him drive a motorcycle on the day in question. He was subsequently charged with perjury with evidence tendered to show that he had driven his motorcycle at various times during 1972. After the Judge had overruled a submission that there was an Issue Estoppel, the same Constable gave the same evidence as that which he had given on the former occasion, identifying Humphrys as the driver he had stopped on the 18th of July 1972. Humphrys was convicted, his Appeal to the Court of Appeal was allowed on the ground that the Constable’s evidence was precluded by Issue Estoppel, but the House of Lords restored his Conviction and held further that the facts disclosed neither a breach of Double Jeopardy nor an Abuse of Process. According to the House, even if Issue Estoppel does apply in English Criminal Law, it would have been inapplicable in Humphrys’ case because no estoppel is created by a Judgment obtained by fraud (including wilfully false evidence). According to Archbold Criminal Pleading, Evidence and Practice 2008, PARA 4-157 PAGE 437, the Civil Doctrine of Issue Estoppel, as distinct from that of Res Judicata, has No Application to the Criminal Law. In certain cases, an attempt to raise again an issue that has, in effect, been decided in a Previous Criminal Trial will amount to an Abuse of Process and may be stayed, even though it does not come within Principle of Res Judicata. The Doctrine of Res Judicata does apply to the Criminal Law in the form of the maxim nemo debet bis vexari pro eadem causa or nemo debet bis puniri pro uno delicto- “no-one should be twice put in jeopardy of being convicted and punished for the same offence” (the Rule against Double Jeopardy. The Pleas of Autrefois Convict and Acquit are founded on these Maxims. In a Criminal Action, every Defendant must stand or fall on his own Merit and Representations and even the Representation of a Common Principal does not by itself, lead to Privity. On the authority of ALADE VS OLUKADE (1976) 2 SC AT 183 PER IDIGBE JSC AT PP 188-189, it is clear that where a Judgment is admitted in evidence, a Trial Court is entitled to make use of every relevant fact contained in that Judgment. It is therefore imperative to analyze this Issue of Estoppel in the light of the Judgments delivered on the 29th Day of July 2005 by my Learned Brother Liman J., in Suit N0: FHC/KD/144C/2004, which was tendered into evidence as Exhibit D21Bas well as another Judgment by Liman J., delivered on the 26th of October 2006 in Suit N0: FHC/KD/43C/2004, which was tendered into evidence as Exhibit Y. This is because these Two Judgments centered on the Bankers of AllStates Trust Bank Plc. In 2005, Six Bankers were charged with Conspiracy, Abetment and Two Offences under the Miscellaneous Offences Decree As Amended by the Tribunals (Certain Consequential Amendment etc.,) Decree N0. 62 of 1999, which were in regard to Aiding, Counselling, Procuring or Conspiring to commit an Offence under this Act and Fraudulently or Knowingly Altering, Forging, 22