Section 220 of the Administration of Criminal Justice Act 2015, the Defendant was expected not only to show there was error in the Particulars of the Offence, but that he was misled by the error or omission. The Defendant was ably represented by a Senior Advocate of Nigeria, and had even appealed through the Three Tiers of Courts on Interlocutory Issues without mentioning the fact that he was misled by reason of the manner the charges were drafted. Further, Learned Silk submitted that the Prosecution, as recommended in the case of AMADI VS THE STATE (1993) 8 NWLR PART 314 PAGE 644 AT PAGE 664 PARAS A-D, (which incidentally was referred to by the Defence), actually used the Language or the wordings of Section 315 of the Penal Code and the Defendant cannot be right in contending that the Prosecution omitted an essential ingredient of this Offence. According to him, all the ingredients in Section 315 were clearly captured in all the Counts relating to Criminal Breach of Trust. Learned Silk then drew out each Count of Offences in regard to Specific Transactions relating to Specific Properties or Funds, to show that the Prosecution had proved its case beyond reasonable doubt. His analysis would be discussed when the Court is determining the Counts of Offences relating to Criminal Breach of Trust. In the Defendant’s Reply on Points of Law dated and filed on the 28th day of February 2018, Learned Silk, set out certain issues, which he felt was not specifically addressed by the Prosecution. For the purposes of now, his Reply will be confined to his submissions on Criminal Breach of Trust. As regards to the omission of the word dishonestly, Learned Silk for the Defence, replied stating that the Prosecution’s position is contrary to all known Rules relating to the Drafting of Charges as well as the Constitutional Provision requiring the Defendant to be informed of the Offence in clear terms. He re-emphasised Sections 311 of the Penal Code and Section 36(6)(a)- (e) of the 1999 Constitution (As Amended) and re-stated his earlier submission that dishonesty was not only essential, but the Law required the word to be expressly stated when framing the Charge. He re-stated yet again the earlier cases cited by him, emphasising that the elements constituting the Offence must be explicit and not left to speculation or inference. It is not the intention of the Draftsman to hide or subsume the word “dishonesty” under any technical word, because “dishonestly” was mentioned twice in Section 311 of the Penal Code. Further, he argued that there was no reason to resort to the Indian Penal Code’s definition of Criminal Breach of Trust, when both the Court of Appeal and the Supreme Court in Nigeria had adequately defined it. He argued that the Phrase, “Technical Words” is a vague expression, not defined in our Laws or Courts and none of the Appellate Courts had ever approved technical words as sufficient in stating the elements of an Offence. The elements of an Offence cannot be left to mere assumptions and speculations. Learned Silk rehashed all the Case Law Authorities and Submissions earlier made in his Written Address and there is little point in re-stating them here again. Learned Silk submitted that a Written Address is not an avenue for the Prosecution to give evidence. The fact that the Central Bank of Nigeria’s Cheque was cleared timeously is not one of the elements of Criminal Breach of Trust or Misappropriation and the Prosecution did not lead evidence to show the Authority that is vested with special powers to collect Cheques on behalf of State Governments in Nigeria, nor did it proffer any Law that disqualifies the Defendant, as Executive Governor of Plateau State, from doing so. No Witness stated this fact. 63