confession therefore only arises where the voluntariness of the confessional statement is challenged by the Defence. See: NOAH v STATE (2014) LPELR23810(CA), per Onyemenam, JCA at pages 25 – 26, paras. F – G. In NWACHUKWU v STATE (2004) 17 NWLR (Pt. 902) 262 at 273 – 290, it was held by the Supreme Court that: A trial within trial is necessary only where a confessional statement is effectively challenged and not where all the opportunities at trial for such denial were never utilized. Thus, only where an issue arises as to whether a confession was made voluntarily should the exceptional procedure of holding a trial within trial be adopted by the court........." See also: ALO v. STATE (2015) LPELR-24404(SC) Per OGUNBIYI, J.S.C (Pp. 24-25, paras. G-D) In the instant case, I have earlier pointed out that the Defendant herein jumped bail after he was arraigned before the Court, and the Court had to invoke Section 352(4) to order a trial of the Defendant in absentia. Hence, the confessional statements of the Defendant in Exhibits PW2A, PW3A and PW3B were admitted without any challenge as to their voluntariness by the Defendant. Having been so admitted, the Court is entitled to rely on same as evidence of the Prosecution in this case. It is trite that the proof of the offence of conspiracy which is the first count of the charge against the Defendant herein, lies in the agreement between two or more 27