On this singular issue, it is the submission that with the avalanche of credible, cogent and material evidence before the court, the prosecution has proved his case against the accused person beyond reasonable doubt. It is submitted that the accused person severally abused the victim of this case (PW3). The PW3 narrated without missing words how her father started having unlawful sexual intercourse with her since 2014. On the issue of corroboration, it is submitted that the evidence of PW5 couple with Exhibit B and C are material, cogent and convincing enough to corroborate the evidence of PW3. See case of POSU v STATE (2011) 3 NWLR (Pt 1234) 393 at 416. It is submitted that not all the contradiction in the evidence of the prosecution can vitiate his case. Contradiction that do not go to the root of the case will in no way affect the case of the prosecution. See HABIBU MUSA v STATE (2013) 8 NLC 464 Page 468 at 487. Para H – F. It is submitted that in considering the evidence before the court to determine whether the prosecution has proved his case, the court is duty bound to take into account the totality of the evidence adduced by the prosecution. See case of OGIDI v STATE (2005) 5 NWLR Pt 918 Pg 286 at 298 R 12. It is the submission that the evidence of DW1, DW2 and DW3 are tainted because the witnesses are blood relation to the accused person; they never knew what offence the accused person is charged; they have no knowledge of the crime of the accused. Their evidence are nothing but hearsay. Court is urged to convict 19

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