that a person is deemed to have committed forgery if he makes a false document in any of the circumstances mentioned in section 362 of the Penal Code and then enumerated the ingredients of the offence of forgery or making a false document. He relied on the case of MALACHI ELISHA BROWN & ANOR V THE STATE (2011) LPELR 4465 (CA) MARK ONOCHIE ODUAH V FRN, (2012) LPELR 9220 (CA) AND AITUMA V THE STATE, (2007) 5 NWLR (pt1028) page466. In the instant case, learned Counsel for the 2nd Defendant submitted that the prosecution failed to show any link between the alleged forged documents and the 2nd Defendant. He submitted that the only thing the prosecution was able to prove against the 2nd Defendant was that the 2nd Defendant was an agent of PW1 and nothing more. He submitted that the actus reus or the mens rea was not proved by the prosecution. He relied on the cases of LIMAN V STATE, (2016) LPELR 9843 (CA) AND ORENO v STATE, (2014) LPELR 22806 (CA). At paragraph 4. 16 of the written address of the 2nd Defendant, Counsel submitted that there are material contradictions in the case of the prosecution and it would be unsafe to convict the 2nd Defendant with such evidence. Then at paragraphs 4.22 of the written address learned Counsel pointed out the material contradictions in the evidence of PW1 and PW3 on whether the forged documents emanated from the 2nd Defendant. On exhibit 8 (a) –(c), the statements of the 2nd Defendant, learned Counsel submitted that these statements did not qualify as a confessional statement because it did not satisfy the tests or criteria for the admission of such statement under section 28 of the Evidence Act. He also relied on the case of SOLOMON THOMAS ANKPAN V THE STATE, (1992) NWLR (pt248) page 449 AND YESUFU V STATE, (1976) 6SC167. ISSUE TWO At paragraphs 4.32-4.34 of the written address, Counsel for the 2nd Defendant submitted that the 2nd Defendant is not liable for 16