21 that the document fully and correctly represents the instructions of the illiterate person. The word instructions has two meanings as follows: 1. printed information about how to do, make, assemble, use, or separate something; and 2. the relevant information about a legal case given by a client to a solicitor or a solicitor to a barrister. See Encarta World English Dictionary, page 972. In very plain English, instructions means detailed information on how to do or use something - Oxford Advanced Learners English Dictionary page 622. Under criminal procedure, statement means An account of a persons knowledge of a crime, taken by the police during their investigation of the offence page 1539 of Blacks 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 22 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, noncompliance 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

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