8. Personal income tax in respect of (a) Members of the armed forces of the .il Federation; (b) Members of the Nigeria Police force ; (c) Residents of the Federal Capital Territory, Abuja; and ( d) Staff of the Ministry of Foreign Affairs . As can be seen from the list above, taxes and levies from motorists (as in the Charge) are not within those to be collected by the Federal Government. Road Taxes are listed in Part II of the Schedule which only the State Government is entitled to collect . The defendants are alleged to · committed offences relating to taxes and levies . They were not collecting lawful taxes and levies on behalf of any government. Section 251(3) of the Constitution of the Federal Republic of Nigeria 1999 does not apply in this case. See also the case of A.G. & CJ Anambra State vs. Registered Trustees of the Cattle dealers Association Lagos State (2016) LPELR-40474 (CA) . Even if the offences the defendants are charged with were committed on a Federal High way or that they are 9

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