Sokoto State Penal Code Law Cap 104 Laws of Sokoto State 1996 is hereby reproduced below as follows:“298 whoever commits robbery shall be punished.” (a) with imprisonment for life with or without fine; and (b) if the robbery is committee by any person armed with any dangerous of offensive weapon or instrument, to imprisonment for life without fine. By section 296(2) of the Sokoto State Penal Code Law Cap. 104 Laws of Sokoto State 1996 which prescribed circumstances when theft can become robbery, the section provides as follows:“296(2) theft is robbery if, in order to commit the theft or in committing the theft or in carrying away or attempting to carry away property obtained by the theft, the offender for that end voluntarily causes or attempts to cause to any person death or hurt or wrongful restraint or fear of instant death or of instant hurt or of instant wrongful restraint.” By the foregoing prescription, for theft to be robbery, the offender must voluntarily causes or attempt to course death to someone, or hurt or wrongful restraint or fear of instant death, or of instant hurt or of instant wrongful restraint. Furthermore, in the recent case of Aliyu V. State {2023} 18 NWLR pt 1915 p 1 Ratio 3 at P4, the Supreme Court held that to prove the offence of robbery, the following elements must be established:(i) That there was robbery; (ii) That the robbery was on armed robbery and Page 13 of 18