World English Dictionary, page 972. In very plain English, "instructions" means "detailed information on how to do or use something" - Oxford Advanced Learner's English Dictionary page 622. Under criminal procedure, "statement" means "An account of a person's knowledge of a crime, taken by the police during their investigation of the offence" - page 1539 of Black's Law Dictionary, Deluxe Ninth Edition. Exhibit "B" in this case is a statement allegedly made by the appellant when he was a suspect of the offence with which he was later charged and eventually convicted of. Exhibit "B" does not qualify as a "letter" or "document" under Section 3 of the Illiterates Protection Law and it is not a necessary requirement that an illiterate jurat should be inserted therein. One of the requirements for admissibility of an extra-judicial statement made by a suspect, if the statement is a confession, is that it must be free and voluntary. A procedural requirement, non-compliance of which is not fatal to admissibility, is the taking of the suspect before a Superior Police Officer for confirmation of his confessional statement, known as the Judges Rules. See Egboghonome v. The State (1993) 7 NWLR (Pt. 306) 383 and Igago v. The State (1999) 14 NWLR (Pt.637) 1. ?There is evidence on record that the appellant attended primary school. The appellant stated so when he testified under cross-examination, at page 34 of the record of appeal, as follows: "I stopped my education while I was in the primary school. I cannot rember (sic) the class I was in primary school before I stopped going to school. The name of my primary school is Umiaghwa. It is true that Umiaghwa is a name of a village but that is also the name that the villagers call the primary school. I stayed both at Abraka and Agbarho. I did not attend primary school at Abraka. It was at Agbarho that I went to primary school." In any case, the erudite professor of law, Prof. I. E. Sagay, opined that the intention of an Illiterates Protection Law is to protect persons by ensuring that they fully understand their obligations and rights in contractual documents before signing them so that they will not be cheated. The learned professor wrote on page 468 of his book: Nigerian Law of Contract, as follows: "The illiterates protection laws are meant to protect a person illiterate in the language of a contractual document from being cheated if in fact he did not understand the document he has signed." The trial Court, per Hon. Justice Emudain-Owho, was eminently right by holding that: "An illiterate jurat on a document executed by an illiterate is only applicable to contractual documents." I agree with the decision of the trial Court on this issue." Per ADUMEIN, J.C.A. (Pp. 20-24, Paras. E-F) (...read in context) 7. CRIMINAL LAW AND PROCEDURE - SENTENCING: When does a sentence begin to run "Section 395 of the Criminal Procedure Law, Cap. C22, Laws of Delta State, 2006 provides that: "395. Commencement of imprisonment Where any person is brought to any prison to be imprisoned by virtue

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