requirement outside the authoritative statement of the Supreme Court in numerous cases. It should be noted that the Third Ingredient of Criminal Breach of Trust, uses the technical words, “Committed a Criminal Breach of Trust”. Once the Count contains these technical words, it would be said to have taken into consideration that the act is dishonest as defined in Section 311 of the Penal Code in its entirety. By that definition, to commit Criminal Breach of Trust in respect of a Property, is to dishonestly misappropriate or convert or use or dispose off that Property. He argued that the case of YAKUBU IBRAHIM VS COP (SUPRA) could not avail the Defendant because in that case, the Defendant was charged under Sections 311 and 312 and not Section 315 of the Penal Code. He referred the Court to the Notes on Penal Code Law by S. S. RICHARDSON, 1987, 4th Edition at Page 243 where the Learned Author had in setting out the Ingredients under Sections 311 and 312, listed Dishonestly as an element, whereas when setting out the Ingredients under Section 315, he did not include dishonestly, but stated the need to establish that the Defendant committed Criminal Breach of Trust. The Author also set out a Precedent on how to formulate a Charge under Sections 314 and 315 and noted that he did not bother to spell out what constitutes Criminal Breach of Trust as defined in Section 311 of the Penal Code because the technical words had already been covered in the Definition. Learned Silk illustrated his point with the Sample of Charge in AKWULE’S CASE (SUPRA), which captured the Charge of Criminal Breach of Trust. Further, the Supreme Court in the case of ONOGWU VS THE STATE (1995) 6 NWLR PART 401 PAGES 276 AT 291 relied on and adopted S. S. RICHARDSON in this case. Further, Learned Silk submitted that the Charge had sufficiently captured the Offence of Criminal Breach of Trust and had also sufficiently given Notice to the Defendant as to the Charge he is facing before this Court. The issue of “dishonestly” is already embedded in the technical words of “committed Criminal Breach of Trust” and therefore, the argument of the Defendant is spurious and cannot vitiate his Trial. According to him, the Prosecution adhered strictly to the words used under the Section and cannot be said to have omitted any ingredient, whether stipulated or envisaged under the Section. He urged the Court to look at other Provisions in the Penal Code that defined Other Offences and used Sections 286 and 287 of the Penal Code, as examples of the Definitive and Prescriptive Style of Drafting Charges and this Style recommended by the Learned Author S. S. Richardson was accepted by the Courts in the case of AJIBOYE VS FRN (2014) LPELR CA/IL/C51/2014, as capturing all the ingredients of the Offences of Theft and Criminal Breach of Trust. Finally on this point, Learned Silk for the Prosecution submitted that the Defendant did not state that he was misled by the alleged error, by stating what he presumed to be the omission in the Particulars of the Offence. He pleaded Not Guilty to the Charge, and had even appealed from the High Court through to the Supreme Court on Interlocutory Issues without stating he was misled by the manner in which the Charges were drafted before the Three Tiers of Courts. He submitted that the Prosecution used the wordings of Section 315 of the Penal Code under which the Defendant was charged and the Defendant cannot be right in contending that the Prosecution omitted the essential ingredients of the offence. A Senior Advocate of Nigeria also represented the Defence and he did not show how he was misled. Many of the Offences of Criminal Breach of Trust and Offences under the Penal Code were copied directly from the Indian Penal Code of 1860. Though the Indian Penal Code has had various 32