He finally submitted that the prosecution having discharged the burden of prove placed on him of the three offences of criminal conspiracy, causing grievous hurt and robbery he urge the court to convict the defendants as charged. Let me start by saying that it is trite law that the burden of proving a criminal allegation against a defendant beyond reasonable doubt has always rested on the prosecution. This is because under our adversarial system of Criminal Justice, a defendant standing trial for any criminal offence, is constitutionally presumed innocent until he is proved guilty. - Ajibade V. State [2013]8NCC221 - Smart V. State [2016] LPELR 40827 - Akinolu V. State (2015) LPELR 25986 - Ibrahim V. FRN {2016} LPELR 40059 - Section 36(5) of the CFRN 1999 as amended. Furthermore, section 135(1) of the Evidence Act 2011 also provides as follows:“if the commission of a crime by a party to any proceeding civil or criminal, it must be proved beyond reasonable doubt.” As to the offence of criminal conspiracy punishable under section 97(1) of the penal code, and which is the first count charge against the defendants, it is trite law that in a charge of criminal conspiracy, all that is necessary, is for the prosecution to lead evidence of an agreement to commit an offence, and in the absence of an agreement, then evidence of some community efforts on the part of all the accused persons aimed at committing a crime and once either of these two {2} is established by the prosecution before the trial court it will be safe to convict for the offence Page 9 of 18