LPELR 23811 (CA), SAMSON AIGBE & ORS V THE STATE, (1976) 9 – 10 (SC) 77. Having said the above position of the law, it has also been held in plethora of judicial authorities that it is difficult for the prosecution to prove agreement as an ingredient of Conspiracy. The reason being that Conspiracy is hatched by the Conspirators in utmost secrecy and it is therefore practically impossible to prove mens rea or intention to commit the offence of Conspiracy. However, as rightly submitted by the learned prosecuting Counsel at paragraph 3.1.2 of page 6 that the overt act or omission which evidences conspiracy is the actus reus. I quite agree with the view of the learned prosecution. The reason being that it is the act(s) or role played by each Defendants that the count will look and infer whether those acts are in pursuance to the commission of an offence or the doing of an illegal thing. In the instant case, PW1, Engineer Ben Ogun is the nominal complainant. In PW1’s testimony, he states: “Sometimes in July 2009, I came to Abuja from London, United Kingdom and in company of my relative, Emmanuel Ikhuria, we met with Augustine James (2nd Defendant) with the intention of buying me a landed property to develop for an Estate in Abuja.” PW1 testified further: - “He told us that he has land for sale in Goza Village along Airport Road Abuja. He presented to me two allocation papers. The 1st was in the name of Abshat Global Concept Ltd and the 2nd in the name of Ogagwu Ventures. We cited the papers in his office and we told him that we are interested in the land.” PW1 testified further thus: - “He (2nd Defendant) now called C. Y Richard (3rd Defendant) whom he said he knows the exact location of the plot of land.” PW1 stated: - “Then myself 25