(366) whoever fraudulently or dishonestly uses as genuine any document which he knows or has reason to believe to be a forged document, shall be punished in the same manner as if he had forged such document. The ingredients to be established by the prosecutor to sustain the charge under 364 are as follows: (a) (i) That the accused made, signed, sealed or executed the document in question or any part thereof or (ii) (b) That it was made by someone else. That it was made under any of the circumstances stated in Section 363. (c) That the accused made it dishonestly or fraudulently or with any of the specific intents enumerated in Section 362. See also the case of ODUAH v F.R.N. (2012) 11 NWLR Pt 76 where the Court of Appeal held as follows: “The offence of forgery can be committed without the element of fraud. All that needs to be established is that: (a) The document is false (b) Knowledge that the false document or writing is false. (c) Intention that same be used or acted upon as genuine 10

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