At paragraph 4:12:5 respondent’s counsel submitted that the ginger were bought with the intention of same to be stored and sold at a future time when the market price appreciated. Respondent’s counsel then concluded at paragraph 4:12:6 of their adopted written address that the respondent was in fact entrusted with 345 bags of ginger and 10 bags of Zobo belonging to the complainant PW1. As to the 2nd element that the respondent misappropriated/converted or dispose of the property entrusted to him in breach of contract or violation of law, respondent’s counsel submitted that the prosecution has not proved this second element as no evidence was led to that effect, instead the goods were sold with the complainant’s instruction through the involvement of PW2 one Muhammed Bashir Aliyu and his statement exhibit AA as well as instructed the respondent to invest the proceeds of sale in another business. As to the element that the respondent acted dishonestly, respondent counsel submitted that the prosecution has failed to show from the circumstances of the case that the respondent acted dishonestly. - Bakare V. State {1968} ALLN.R 364 - Section 2 of the Sokoto state penal code law 2019 As to the offence of criminal misappropriation, respondent’s counsel submitted that from the evidence led by the prosecution the prosecution has only proved one {1} element out of the 3 major ingredient. Page 12 of 25