suggesting that they are confessional in nature. To what amount to confession in law learned senior counsel referred the court to the case of NWACHUKWU v THE STATE (2007) 17 NWLR Pt 1062 Pg 32. It is submitted that whatever evidence the prosecution intends to rely upon must establish the following ingredients of the offence beyond reasonable doubt thus: (a) That the Defendant corruptly accepted from Societe D’ Equipment Internationaux Nigeria Limited. a contractor with the Nigerian Air Force in the performance of his official act the sums of money mentioned in each count or their value in vehicles. (b) That it was an inducement or reward for doing, forbearing to do, or for having done, or forborne to do, any act or thing? It is submitted that for a statement to be accepted as “confessional” it must be made voluntarily and satisfy the tests laid down in R v SKES. It follows therefore that a trialwithin-trial is not the only procedure or means by which the trial court can make a determination. That a statement(s) alleged to be “confessional” was not made voluntarily. Consequently, where evidence surfaces in the 20