On the counts of forgery and using as genuine forged documents, it is the submission that the offence of forgery can be committed when a person is said to make a false document. To prove the offence of forgery, the prosecution must establish the following: (a) That there is a document or writing (b) That the document or writing is forged (c) That the forgery is by the accused person (d) That the accused person knows that the document or writing is false. (e) That he intends the forged document to be acted upon to the prejudice of the victim in the belief that it is genuine. See AMADI v FRN (2008) 18 NWLR (Pt 1119) 259 at 277 – 278 Paras H – B. It is submitted that the document in issue are Exhibits A, B, C and G and also Exhibits D and F were not written and signed by Mohammed Abubakar the Account holder, but they were written and signed by one Ojeyinka Omotosho (now at large). Court is referred to Exhibit Q the confessional statement of Ojeyinka Omotosho which is to the effect that he wrote the said forged documents. Court is urged to hold that the prosecution has proved and established a prima facie case against the accused person in respect of the counts of forgery and therefore the accused be convicted. See the case of AGWUNA v A.G. OF THE FED (1995) NWLR 9Pt 396) 418 at 438 Para G – H. 18

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