same punishment as is prescribed for that offence under this Act.” To prove the offence of conspiracy by the prosecution against the 1st, 2nd and 3rd Defendants, the Supreme Court of Nigeria in the case of IKECHUKWU OKOH V THE STATE (2014) LPELR 22589, it held thus:“It is also well settled that the essential ingredients of the offence of conspiracy lies in the bare agreement and association to do an unlawful thing, which is contrary to or forbidden by law whether that thing be criminal or not and whether or not the accursed persons had knowledge of its unlawfulness. Evidence of conspiracy is usually a matter of inference from surrounding facts and circumstances. The trial Court may infer conspiracy from the fact of doing things towards a common purpose.” See also CLARK V THE STATE, (1986)4 NWLR (pt 35) page 381, GBADAMOSI V THE STATE, (1991)6 NWLR (pt196) Page 182, AJE V THE STATE, (2006) 8 NWLR (pt982) page 345 at 363 paragraph A-C. It is clear from the above judicial decisions that the essential ingredients of the offence of conspiracy lies in the bare agreement of two or more persons with a common intention to prosecute an unlawful purpose. But because conspiracy is usually hatched in utmost secrecy amongst the conspirators, to prove agreement and intention is always difficult or practically impossible by the prosecution. However, the Supreme Court in the case of IKECHUKWU OKOH V THE STATES (supra) states:“Evidence of conspiracy is usually a matter of inference from surrounding facts and circumstances. The trial Court may infer conspiracy from the fact of doing things towards a common purpose.” In otherwords, it is sufficient proof if the prosecution can lead evidence from the surrounding circumstances of doing things by the Defendants towards achieving the purpose and as a result an offence is committed. For more understanding as to the duty of the trial Court in inferring from fact of doing things whether 31

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