compact disc or such other audio visual means, the confessional statements of a suspect and to take statements of suspects in the presence of the persons set out in Section 17(2) of ACJA. The Court of Appeal further held that the provisions are for the benefit of private citizens who are suspected of committing crimes so that the enormous powers of the police or other law enforcement agencies may not be abused by intimidating them or bullying them in the course of taking their statements. That the provisions also have another side of it, viz: to protect law enforcement agents from false accusation of coercion in taking statements from suspects. The use of the word “may” in those provisions are in those circumstances mandatory and not permissive. Also in the case of FABIAN MATHEW v STATE, unreported decision of the Court of Appeal in Appeal No. CA/L/1126/2011 delivered on 11/12/15 and JOSEPH ZHIYA v THE PEOPLE OF LAGOS STATE (2016) LPELR – 40562 (CA) the Court of Appeal held that failure to comply with Section 9(3) of the ACJL which is pari material with Section 15(4) and 17(2) of ACJA 2015, which requires video recording of the making of a confessional 49