purpose of discharging his role as a legal practitioner” In the instant case, it is the evidence of the Defendant that he was not given access to the services of a lawyer despite several requests by him and even when he had a lawyer from the NAF who also doubled as Liaison Officer of the NAF to EFCC that escorted him to EFCC, the Defendant’s request to have the said lawyer present at his interrogation and when his statement was obtained was rejected by the EFCC operatives. In the unreported decision of the Court of Appeal in CA/L/727A/2017 AKAEZE CHARLES v FRN delivered on the 19/3/2018, the court held that it has been established by a long line of decided case that the courts would interprete the word “may” as mandatory wherever it is used to impose a duty upon a public functionary to be carried out in a particular form or way for the benefit of a private citizen. The court went on to state that Section 17(2) of ACJA impose a duty on public functionaries (police officers and other officers of any law enforcement agency established by an Act of the National Assembly and this includes the EFCC to record electronically or retrievable video 48

Select target paragraph3