It is submitted that the prosecution have failed to prove the offences as charged against the accused person; that justice must be done to both the accused and the prosecution, but most importantly where there is any iota of doubt such doubt must be resolved in favour of the accused p0erson. See case of ALIYU v state (2000) 2 NWLR Pt 644 at 78. Court is urged to discharge and acquit the accused person for lack of proof of all the allegations against him by the prosecution. The prosecution on its side filed a 37-page final written address dated 6/11/15 wherein counsel formulated an issue for determination, thus: “Whether from the quantum of evidence adduced by the prosecution, it could be said it has discharged the burden on it by proving the offences for which the accused is charged beyond reasonable doubt” On this singular issue, it is the submission that the guilt of an accused person may be proved by: (a) The confessional statement of the accused; or (b) Circumstantial evidence; or (c) Evidence of eye witnesses. See case of EMEKA v THE STATE (2001) 14 NWLR (Pt 734) 666 at 683. It is submitted that from the totality of evidence adduced at the trial, the prosecution has proved its case against the accused person as required by law. Court is referred to Section 135(1) of Evidence Act 2011. 15

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