The Decision in ONUOHA VS THE STATE (1988) 7 SC PT 1 PAGE 74 AT PAGE 94 recognized that it is sufficient to construe dishonestly in its natural meaning, i.e., intended to cheat, deceive or mislead.See also His Lordship, PETER-ODILI, J.C.A. (AS HE THEN WAS) in the case of HON. YAKUBU IBRAHIM & ORS VS COMMISSIONER OF POLICE (2010) LPELR-8984 (CA) per (P. 18, PARAS B-E). Further reference is made to the cases of TIRAH VS COMMISSIONER OF POLICE (1973) NNLR PAGE 143 (CA); OKONKWO VS COMISSIONER OF POLICE (1985) HCNLR PAGE 1277;J. ONIBANIYI & ANOR VS THE STATE (1972) SUIT NO: SC.235/1971 8-9 SC PAGE 97 PER UDO UDOMA JSC. In Australian Jurisprudence, the words, “Honesty” and “Dishonesty” as discussed in the case of R VS SALVO (1980) VR PAGE 40 AT PAGE 407, are used in ordinary parlance to connote respectively, “noncompliance with or disregard of the dictates of the Moral Virtue of Justice, which acknowledges and gives effect to the rights of others to, or in respect of material things, or of the relationship of one person to another, e.g. Master and Pupil, Vendor and Purchaser, Employer and Employee, etc. The Terms may in certain contexts connote respect for or disregard of the Moral Virtue of Truth. The word “Dishonestly” implies reference to a Standard of Morality underlying the Law: they derive not from the Law but from the Standard of Ethics accepted by the Community. The Law sets Standards of Legality and Illegality but cannot set and never has purported to set Standards of Morality.” The Court of Appeal in England in the case of R VS GHOSH (1982) 2 ALL ER PAGE 689 AT PAGE 696 at RATIO 154, held that Dishonesty is an element of Mens Rea, clearly referring to a State of Mind, and that overall, the Test that must be applied is Hybrid, but with a Subjective Bias which "looks into the mind" of the person concerned and establishes what he was thinking. The Test was Two-Stage, namely: • "Where the Person's Actions honest according to the Standards of Reasonable and Honest People?" If a Jury decides that they were, then the 44