Nigeria in KANU v R. In SHODIYA v STATE (2013) LPELR 20717 the Apex court held thus: “that conviction made solely on the basis of an appellants confessional statement survives an appeal where the statement is not only voluntarily obtained but the statement is direct, positive and unequivocal as to the entire ingredients of the offence for which the appellant is convicted as well.. where, however, the extra judicial statement of the appellant is not that comprehensive or total in relation, to the offence the appellant is convicted, the existence of such evidence outside the statement becomes a necessity to justify the persistence of the conviction on appeal” From the foregoing statement for an extra judicial statement to amount to a confession, it must be made voluntary and satisfy the tests, laid down in R v SYKES, It follows therefore that a trial-within-trial is not the only procedure or means by which the trial court can made a determination that a statement(s) alleged to be “confessional” was not made voluntarily. Consequently, were evidence surfaced in the cause of a trial showing that the statement(s) were obtained by 41