In the Cases of R VS MAKANJUOLA; R VS EASTON (1995) 2 CR. APP. R. 469, CA, Lord Taylor C.J., giving the Judgment of the Court, said that they had been invited to give guidance as to the circumstances in which, as a matter of discretion, a Judge, in summing up, ought to urge Caution in regard to a Particular Witness and the terms in which that should be done. His Lordship continued: “The circumstances and evidence in Criminal Cases are infinitely variable and it is impossible to categorize how a Judge should deal with them. But it is clear that to carry on giving ‘discretionary’ warnings generally and in the same terms as were previously obligatory would be contrary to the Policy and Purpose of the 1994 Act. Whether, as matter of discretion, a Judge should give any warning and if so its strength and terms must depend upon the content and manner of the Witness’s Evidence, the circumstances of the Case and the issues raised. The Judge will often consider that no special warning is required at all. Where, however, the Witness has been shown to be unreliable, he or she may consider it necessary to urge Caution. In a more extreme Case, if the Witness is shown to have lied, to have made previous false Complaints, or to bear the Defendant some grudge, a stronger warning may be thought appropriate and the Judge may suggest it would be wise to look for some supporting material before acting on the impugned Witness’s Evidence. We stress that these observations are merely illustrative of some, not all, of the factors which Judges may take into account in measuring where a Witness stands in the Scale of Reliability and what response they should make at that level in their directions to the Jury. We also stress that Judges are not required to conform to any Formula and this Court would be slow to interfere with exercise of Discretion by a Trial Judge who has the advantage of assessing the manner of a Witness’s evidence as well as its content.” (Underlining Mine) As regards PW6, Mr. Abdulkadir Umar, and the Evidence he rendered before the Court, this Witness was the Assistant Chief Accountant of the Ministry of Finance, who by his function, had to be involved, whether he liked it or not, in the Financial Transactions before the Court. This Witness was consistent in his Testimony that he only obeyed Orders and when he sensed a Breach, 56