IHUEBEKA VS THE STATE (2000) 7 NWLR PT 665, AT PARAS G-A, on Questions freely and fairly put by an IPO, was referred to by His Lordship and relied on. GALADIMA J.S.C in his contribution distinguished the facts of the case of NAMSOH with that under consideration, where he drew on the fact that in NAMSOH, the Police were putting Questions already prepared by his Superiors on a Sheet of Paper to the Defendant, while the answers were recorded. This, he held was a clear statement obtained as a result of questioned prepared and answer obtained from the defendant. NGWUTA J.S.C. in his dissenting judgment held that though an IPO can question a suspect on the subject of investigation, once the suspect has been charged with a crime, he cannot be questioned without caution. It appears flowing from this that it is generally recognized that questions may be put to a suspect as long as he is cautioned beforehand that he was not obligated to say anything etc. In the case of F.R.N. VS DAIRO (2015) 6 NWLR PT 1454, confirm 16 NWLR PT 1325 at 129; NWEZE J.S.C found considerable merit in the proposition that if a witness is asked whether he voluntarily signed the statement and he answered that he did, then that is clearly an unequivocal admission that the signing was voluntary and further held that the admission that the defendant voluntarily signed his statement was tantamount to a confession. The Court further held that “An investigator may adopt the approach of questions arising from investigation for clarification but it must be under an environment that is not encumbered by threat or promise. Where an approach of question and answers is adopted in obtaining a confessional statement, once there is doubt that it was truly voluntary, it should not be admitted.” In STATE VS JIMOH SALAWU (2011) 6-7 SC PT IV AT 147, the Supreme Court held, whilst distinguishing Namsoh’s case that the police officer was armed with a sheet of paper, which contained selected questions already prepared by his superiors and designed to excite from him self-implicating answers. It was held that “there was no evidence of the specific questions asked by the police, in response to which the admissions in the exhibits under consideration were made. Nor was there evidence that the facts constituting the admissions in the said statements were prompted by questions from the police. This case emphasised the point that it is not a rule of our Criminal Procedure Law and the Law of Evidence that where in the course of recording the Statement of a Defendant, a Police Officer asks questions and records the answers by the accused therein; the statement automatically becomes involuntary and inadmissible in law. That was not the principle upon which Namsoh’s Case was decided by this Court. The questions were specially prepared and were oppressive of the defendant in the sense that they meant to sap and indeed sapped the freewill of the accused Person and thus rendered his ensuing statement involuntary”. His Lordship, Francis Fedode Tabai JSC held that the mere assertion by the police prosecutor that in the course of recording the statement of accused Person, he asked questions and recorded the answers, does not ipso facto render the statement involuntary. The defence ought to have led evidence during the Trial and not in his Final Address, on the specific Questions that were put to the Defendant, in order to elicit Answers. It was imperative that this be set out for the Court to decide during Trial, whether or not the Statement was recorded, and for the Court to construe its wordings or how it was recorded. It is in this manner that the flow will reveal whether or not it was the Product an Oppressive Conduct. The degree of prolonged questioning by the police or interrogators is always to be weighed against the Defendant’s Intelligence and Level of Education. See R VS PARKER (1995) CRIM LR AT 233 42