Prosecuting counsel further submitted that in criminal cases the state is always the complainant and that there is no law that made it mandatory for a nominal complainant to give evidence in criminal cases. She submitted that the evidence of PW1, PW2, and PW3 all pointed to the fact that a letter of complainant was sent from the American embassy reporting that a certain mobile number 09150266355 was used to demand a ransom in respect of a white American citizen that was kidnapping in Masalata village in Niger Republic and brought to Kalmalu forest in Illela Local Government Areas of Sokoto state. Prosecuting counsel further contended that by the wardings of Section 17(2) of the ACJL of Sokoto state the use of the word “May” shows that compliance with the subsection is discretionary and not mandatory - Awuse V. Odili (2004)8 NWLR PT 876 P 481. Prosecuting counsel submitted that the police officers are the persons who recorded the statement of the defendant and therefore perfectly proper to tender the statements of the defendant through them. As to the offence of conspiracy prosecuting counsel submitted that the offence is often not proved by direct evidence as it is normally inferred. - Aliyu V. State (2022) 3 NWLR PT 1818 P 521. She submitted further that both the defendants confessed to being part of a gang that planned to and indeed carried out the kidnapping and detention of the victim which establishes the offence of conspiracy. Page 5 of 13