be untrue and therefore the 1st Defendant is entitled to be discharged and acquitted in the instant case. ISSUE THREE At paragraphs 4.19 – 4.26 of the written address of the 1st Defendant, learned Counsel submitted that for the prosecution to secure conviction for forgery against the 1st Defendant, the prosecution must prove the following ingredients: (a) That the Accused utters or forges a document. (b) That he know the document to be false (c) That he presented the said document to the other party with the intention that it could be acted upon. (d) That the document was acted upon by the other party to his detriment. He relied on the cases of IDOWU V STATE, (1998) 11 NWLR (pt 574) page 354 at 363 para E, ONTARIO OIL & GAS (NIG) LTD V FRN (2015) LPELR 24651 (CA), ODIAWA V FRN (2008) LPELR 4230 (CA) ALAKE V THE STATE, (1991) 7 NWLR (pt 205) page 567. Learned Counsel submitted further that calling of a hand writing analyst to establish a prima facie case of forgery by the prosecution is a necessity and indispensable requirement. He relied on the case of AITUMA V STATE, (2006) 10 NWLR (pt 989) page 452 at 468 – 469 para D – A. He submitted also that a party alleging forgery must of necessity produce two documents before the Court i.e. the original document before it was forged and the forged document before the Court can determine whether indeed there was a forgery. He relied on the case of ALL PROGRESSIVE CONGRESS V PEOPLES DEMOCRATIC PARTY & ORS, (2015) LPELR 24587 (SC). In conclusion, the learned Counsel for the 1st Defendant submitted that the prosecution failed to make out a prima facie case of forgery against the 1st Defendant in that the prosecution failed to call a hand writing analyst and also failed to tender two sets of documents as required by law. He 23