persons to do an unlawful act or to do a lawful act by unlawful means. Whilst considering the nature of and proof of the offence conspiracy however, the Supreme Court in the classical case of NJOVENS & ORS. v THE STATE (1973) LPELR-2042(SC), held that: The overt act or omission which evidences conspiracy is the actus reus and the actus reus of each and every conspirator must be referrable and very often is the only proof of the criminal agreement which is called conspiracy. It is not necessary to prove that the conspirators, like those who murdered Julius Ceasar, were seen together coming out of the same place at the same time and indeed conspirators need not know each other. See R. v. Meyrick and Ribuffi (1929) 21 C. App. R. 94. They need not all have started the conspiracy at the same time for a conspiracy started by some persons may be joined at a later stage or later stages by others. The gist of the offence of conspiracy is the meeting of the mind of the conspirators. This is hardly capable of direct proof for the offence of conspiracy is complete by the agreement to do the act or make the omission complained about. Hence, conspiracy is a matter of inference from certain criminal acts of the parties concerned done in pursuance of an apparent criminal purpose in common between them and in proof of conspiracy the acts or omissions of any of the conspirators in furtherance of the common design may be and very often are given in evidence against any other or others of the conspirators. Per COKER J.S.C. (P. 57, paras. A-F) 28