Rex v. Eters Udo Akpabio is an important Nigerian criminal law case on stealing by agent, fraudulent false accounting, the meaning of acting as a clerk or servant, fraudulent intent and, most importantly, the burden of proof in criminal proceedings.
The case arose from the handling of money entrusted to the appellant, Eters Udo Akpabio, in his capacity as the Honorary Treasurer of the Ikot Ekpene Branch of the Ibibio Union. The money was intended for payment into a “Win-the-War Fund.” Some of the money was not entered in the Union’s books and was eventually paid into the Government Treasury considerably later.
The appellant was initially charged with three offences. The first and third counts alleged stealing by agent under section 390(8)(b) of the Criminal Code, while the second count alleged fraudulent false accounting under section 438(c).
Although the trial court acquitted the appellant on the first count, it convicted him on the second and third counts.
On appeal, the West African Court of Appeal carefully examined whether the prosecution had actually established the necessary elements of the offences beyond the required standard of proof.
The appellate court ultimately allowed the appeal and quashed the convictions and sentences.
The case is particularly valuable because it teaches a fundamental principle of criminal law: suspicion, however strong, cannot replace proof. Where the prosecution bears the burden of establishing an essential fact, that burden does not shift to the accused merely because the accused’s explanation appears doubtful.
CASE INFORMATION
Case: Rex v. Eters Udo Akpabio
Court: West African Court of Appeal
Coram: Kingdon, C.J., Baker and Brooke, JJ.
Originating Court: High Court, Calabar-Aba Judicial Division
Area of Law: Criminal Law and Criminal Procedure
Principal Offences: Stealing by Agent; Fraudulent False Accounting
Key Legislation: Criminal Code, sections 390(8)(b), 438(c) and 383
CASE SUMMARY.
Eters Udo Akpabio was the Honorary Treasurer of the Ikot Ekpene Branch of the Ibibio Union. In that capacity, he was entrusted with money intended for a “Win-the-War Fund.”
The prosecution alleged that the appellant received £4 10s. 5d. but failed to account for it in the Union’s books. The money was eventually paid into the Government Treasury on 16 April 1943, despite having been received much earlier.
The appellant was also alleged to have received another £7 intended for the same fund. That amount was eventually paid into the Treasury on 26 April 1943.
The trial court acquitted the appellant of stealing the £4 10s. 5d. because it considered that the prolonged retention of the money, although suspicious, did not establish the necessary fraudulent conversion.
However, the trial judge convicted him of fraudulent false accounting because he had failed to enter the £4 10s. 5d. in the Union’s books.
The judge also convicted him on the third count after finding that he had received the £7 before 16 April 1943 and had fraudulently converted it.
The appellant appealed.
The West African Court of Appeal held that the conviction on the second count could not stand because the necessary fraudulent intent had not been proved.
The conviction on the third count also failed because the prosecution had not discharged the burden of proving that the appellant received the £7 before 16 April 1943.
The convictions and sentences were therefore quashed and a verdict of acquittal was entered on all three counts.
FACTS OF THE CASE REX v.UDO AKPABIO
The appellant, Eters Udo Akpabio, occupied two official positions during the relevant period.
He was the Honorary Treasurer of the Ikot Ekpene Branch of the Ibibio Union. Although this position was unpaid, he voluntarily performed the duties associated with it.
At the same time, he held a paid position as Native Administration Treasurer of the Ikot Ekpene Division.
At a meeting of the Ibibio Union held on 22 November 1941, arrangements were made for the collection of contributions towards a “Win-the-War Fund.”
The appellant received £4 10s. 5d. in connection with this fund.
The money was not entered in the Union’s books.
The appellant eventually paid the £4 10s. 5d. into the Government Treasury on 16 April 1943.
A second sum of money was also collected from members of the Union. The Union had resolved that members in nineteen different court areas should contribute £1 each towards the fund.
The appellant admitted receiving a total of £15 from the various court areas.
He eventually paid £8 into the Treasury on 16 April 1943 and the remaining £7 on 26 April 1943.
The handling of these sums resulted in the three criminal charges.
THE THREE COUNTS.
COUNT ONE
The first count charged the appellant with stealing by agent contrary to section 390(8)(b) of the Criminal Code.
It alleged that he stole £4 10s. 5d. entrusted to him as Honorary Treasurer of the Ibibio Union for payment into the Win-the-War Fund.
COUNT TWO
The second count charged him with fraudulent false accounting contrary to section 438(c) of the Criminal Code.
The prosecution alleged that while acting as Honorary Treasurer, he intentionally omitted the receipt of £4 10s. 5d. from the Union’s books with intent to defraud.
COUNT THREE
The third count charged him with stealing by agent under section 390(8)(b).
This count concerned the £7 which the appellant allegedly received for payment into the Win-the-War Fund.
DECISION OF THE TRIAL COURT
The trial court acquitted the appellant on Count One.
The judge considered that although the appellant’s prolonged retention of the £4 10s. 5d. was suspicious, the evidence did not establish a sufficiently definite act of conversion to constitute stealing.
However, the judge convicted the appellant on Count Two.
The judge found that the appellant was acting in the capacity of a clerk or servant of the Union even though he was an unpaid Honorary Treasurer.
The judge also found that the appellant had a duty to account for the money and that the omission of the receipt from the Union’s books demonstrated fraudulent intent.
On Count Three, the trial judge found that the appellant had actually received the £7 before 16 April 1943.
The judge rejected the appellant’s explanation that he received the money later.
The judge therefore concluded that the appellant had fraudulently converted the £7 and convicted him.
He was sentenced to twelve months’ imprisonment with hard labour on each count, the sentences to run concurrently.
ISSUES FOR DETERMINATION REX v.UDO AKPABIO
The appeal raised several important questions:
2.Whether an unpaid Honorary Treasurer could be regarded as acting in the capacity of a clerk or servant for the purposes of the offence of stealing by agent.
2.Whether the prosecution had established that the appellant had a duty to account for the £4 10s. 5d. in the Union’s books.
3.Whether the omission of the £4 10s. 5d. from the Union’s books was sufficient to establish fraudulent intent.
4.Whether the acquittal on the first count affected the finding of fraudulent intent on the second count.
5.Whether the prosecution had proved that the appellant received the £7 before 16 April 1943.
6.Whether the trial judge improperly placed the burden on the appellant to disprove the prosecution’s allegation concerning the date on which he received the £7.
7.Whether the convictions on Counts Two and Three could safely be sustained.
DECISION OF THE WEST AFRICAN COURT OF APPEAL in REX v.UDO AKPABIO
The appeal was allowed.
The convictions and sentences on Counts Two and Three were quashed.
The court directed that a judgment and verdict of acquittal be entered in respect of all the counts.
The appellant was discharged.
PRINCIPLE ONE: AN UNPAID TREASURER CAN BE A CLERK OR SERVANT
One of the interesting issues in the case was whether the appellant could be regarded as a clerk or servant even though he was an unpaid Honorary Treasurer.
The appellant argued that he was not a clerk or servant because he received no salary.
The appellate court rejected that argument.
The court considered the nature of the functions actually performed by the appellant.
The important question was not simply whether he received wages.
Rather, the court considered whether, by voluntarily undertaking the duties of Treasurer, he was acting in the capacity of a clerk or servant to the Union.
The court concluded that he was.
Therefore, the fact that his position was honorary and unpaid did not automatically exclude him from the legal category of clerk or servant.
This is an important lesson in statutory interpretation.
A student should not assume that an ordinary word used in legislation must always be interpreted according to its narrow everyday meaning.
The legal context and the statutory purpose must be considered.
THE TEST IS FUNCTION, NOT SIMPLY PAYMENT
The case demonstrates an important distinction.
A person may perform functions associated with a clerk or servant even where the relationship does not involve an ordinary salary.
The court referred to the reasoning in Reg. v. Foulkes, where the relevant consideration was the nature of the duties undertaken and the obligation to perform them honestly.
Therefore, the better way to approach such a question is to ask:
What duties did the accused voluntarily undertake?
Did the accused act on behalf of the organization?
Did the accused have responsibility for money or property belonging to another?
Did the accused undertake duties ordinarily performed by a clerk or servant?
The existence or absence of remuneration may be relevant, but it is not necessarily decisive.
PRINCIPLE TWO: THE PROSECUTION MUST PROVE EVERY ESSENTIAL ELEMENT
This is one of the strongest lessons from the case.
Criminal prosecution is not based on the accused proving innocence.
The prosecution bears the burden of establishing the ingredients of the offence.
Where an essential fact is disputed, the prosecution must prove it with evidence.
The accused is not required to prove a negative merely because the prosecution’s case appears suspicious.
This principle becomes particularly important in Count Three.
THE £7 AND THE DATE OF RECEIPT
The prosecution alleged that the appellant had received the £7 before 16 April 1943.
The appellant’s case was that he had not received the money by that date.
The trial judge rejected the appellant’s explanation and concluded that he must have received the £7 before 16 April.
The appellate court held that this reasoning was legally defective.
The burden was on the prosecution to prove the earlier receipt.
It was not the responsibility of the appellant to prove that he had not received the money.
This distinction is fundamental.
If the prosecution’s case depends on Fact X, the prosecution must establish Fact X.
The court cannot say:
“The accused has failed to convince me that Fact X did not happen, therefore Fact X must have happened.”
That would improperly reverse the burden of proof.
THE BURDEN OF PROOF IN CRIMINAL CASES
The general principle is that the prosecution bears the burden of proving the accused’s guilt.
In Nigerian criminal law, this principle is constitutionally recognized and is one of the foundations of a fair criminal trial.
The prosecution must establish the ingredients of the offence beyond reasonable doubt.
This does not mean that every imaginable doubt must be eliminated.
It means that the evidence must be sufficiently strong and convincing that, after considering the whole case, there remains no reasonable doubt as to the essential facts necessary for conviction.
Where a reasonable doubt remains concerning an essential element, the accused must receive the benefit of that doubt.
APPLICATION TO REX v. ETERS UDO AKPABIO
In Count Three, the date on which the appellant received the £7 was not a minor detail.
It was directly connected with the prosecution’s allegation of fraudulent conversion.
If the appellant had already received the £7 before 16 April and then dishonestly converted it, the prosecution might establish the necessary ingredients.
But if he did not receive the money until after that date, the prosecution’s particular theory of the offence could not stand in the same way.
Therefore, the date of receipt was an essential factual issue.
The prosecution had to prove it.
The appellate court noted that the prosecution could have called the people who actually made the payments to establish when the appellant received the money.
The prosecution failed to do so.
Consequently, the required burden was not discharged.
BEST EVIDENCE AND FAILURE TO CALL AVAILABLE WITNESSES
Another useful evidential lesson emerges from the case.
The prosecution had access to persons who could potentially establish when the £7 was paid to the appellant.
Those persons were not called to provide direct evidence of the relevant dates.
Instead, the prosecution relied substantially on inference and the rejection of the appellant’s explanation.
The appellate court considered this inadequate.
Now please take note this does not mean that a prosecution must always call every possible witness.
Rather, where a particular fact is central to the prosecution’s case and direct evidence is reasonably available, the absence of that evidence may create a serious evidential weakness.
So you should therefore learn to distinguish between:
“The accused’s story is unbelievable”
and
“The prosecution has proved its alternative version beyond reasonable doubt.”
They are not automatically the same thing.
PRINCIPLE THREE: SUSPICION IS NOT PROOF
The first count provides another valuable lesson.
The trial judge considered the appellant’s retention of the £4 10s. 5d. highly suspicious.
However, the judge still acquitted him because the evidence did not establish the necessary conversion.
This was important.
The fact that conduct appears suspicious does not automatically establish the offence charged.
Criminal conviction requires proof of the legal ingredients of the offence.
A court must therefore resist the temptation to transform suspicion into proof.
This principle is especially important where the accused’s conduct appears dishonest or unusual.
The question is not merely:
“Does this look suspicious?”
The question is:
“Has the prosecution proved every element of the offence beyond reasonable doubt?”
FRAUDULENT INTENT AND COUNT TWO
Count Two concerned fraudulent false accounting.
The allegation was that the appellant deliberately omitted the £4 10s. 5d. from the Union’s books with intent to defraud.
The trial judge concluded that the omission demonstrated fraudulent intent.
However, the appellate court disagreed.
The prosecution could not successfully maintain that fraudulent intent had been established on Count Two when the appellant had already been acquitted on Count One on the same essential factual circumstances.
The appellate court accepted the position taken by Crown counsel that the acquittal on Count One negatively affected the prosecution’s attempt to establish the necessary fraudulent intent for Count Two.
The conviction on Count Two therefore could not stand.
WHAT IS FRAUDULENT FALSE ACCOUNTING?
Fraudulent false accounting is an offence concerned with dishonest manipulation or omission of information in accounts or accounting records with the requisite fraudulent intention.
The important point for students is that an omission from an account is not automatically criminal.
There must be evidence establishing the statutory ingredients of the offence.
The prosecution must therefore establish matters such as:
- The existence of the relevant accounting record.
- The accused’s responsibility or involvement in making or maintaining the record.
- The relevant act or omission.
- That the omitted or altered matter was material under the statutory provision.
- The required fraudulent intention.
The precise statutory wording should always be consulted when answering an examination question.
MATERIAL PARTICULAR
One of the grounds of appeal questioned whether the omitted £4 10s. 5d. amounted to a material particular.
This highlights an important criminal law technique.
Where legislation uses a specific legal expression such as “material particular,” a student should not simply repeat the phrase.
The student should explain what makes the particular material in the context of the account and the statutory offence.
The court must consider whether the omitted information was sufficiently significant to the account or transaction that the omission falls within the statutory provision.
However, the ultimate difficulty in this case was fraudulent intent.
Even where an omission is material, the prosecution must still establish the other statutory ingredients.
THE RELATIONSHIP BETWEEN COUNTS ONE AND TWO
This is one of the more intellectually interesting parts of the decision.
Count One alleged that the appellant stole the £4 10s. 5d.
Count Two alleged that he omitted the same amount from the Union’s books with intent to defraud.
The trial court acquitted the appellant of the first allegation because it was not satisfied that the prosecution had established the necessary conversion.
It then convicted him on the second count on the basis of fraudulent intent.
The appellate court considered that the necessary fraudulent intent could not properly be sustained in light of the acquittal on Count One.
This demonstrates why courts must carefully examine the relationship between different counts arising from the same factual transaction.
A prosecution cannot simply divide one factual allegation into several offences and assume that failure on one count has no implications for another.
Each count must independently satisfy its legal requirements, while the evidence as a whole must remain logically coherent.
CRIMINAL LIABILITY AND THE ACCUSED’S EXPLANATION
The case also demonstrates an important rule concerning the accused’s explanation.
An accused person may provide an explanation that the trial judge finds unconvincing.
But rejecting the explanation does not automatically prove the prosecution’s case.
The prosecution must still establish the positive facts necessary for conviction.
This is particularly important where the prosecution relies on circumstantial evidence.
A court may draw reasonable inferences from established facts, but the inference must be supported by the evidence.
The court cannot simply reason:
“The accused has not given a satisfactory explanation, therefore the prosecution’s allegation must be true.”
That approach risks reversing the burden of proof.
EXAM FOCUS
Those who are students should remember this case under five major headings:
STEALING BY AGENT
The case illustrates the significance of the accused’s capacity as a clerk or servant and the relationship between the accused and the property entrusted to him.
HONORARY OR UNPAID POSITION
The absence of salary does not necessarily prevent a person from acting in the capacity of a clerk or servant.
The court focused on the duties actually undertaken.
FRAUDULENT FALSE ACCOUNTING
An omission from an accounting record does not automatically establish criminal liability. The statutory requirements, particularly fraudulent intent, must be proved.
BURDEN OF PROOF
The prosecution bears the burden of proving the essential elements of the offence.
Where the prosecution alleges that money was received on a particular date, it must prove that fact.
SUSPICION IS NOT PROOF
Suspicious conduct may justify investigation, but suspicion alone cannot sustain a criminal conviction.
COMMON MISTAKES STUDENTS SHOULD AVOID
Mistake 1: “Because the accused was unpaid, he could not be a servant.”
Wrong.
The court considered the nature of the duties undertaken, not merely remuneration.
Mistake 2: “Because the accused’s explanation was unbelievable, he should be convicted.”
Wrong.
The prosecution must still prove its case.
Mistake 3: “The accused had to prove when he received the £7.”
Wrong.
The prosecution alleged that he received it before 16 April. The prosecution therefore bore the burden of proving that allegation.
Mistake 4: “Failure to enter money in a book automatically amounts to fraudulent false accounting.”
Wrong.
The statutory ingredients must be established, including the necessary fraudulent intention.
Mistake 5: “Suspicion is sufficient where money is involved.”
Wrong.
Criminal conviction requires proof, not suspicion.
Mistake 6: Ignoring the relationship between different counts.
Where multiple counts arise from closely connected facts, students should examine the evidence supporting each count and whether the prosecution has established every ingredient separately.
WHY REX v. ETERS UDO AKPABIO MATTERS
The case is important beyond the particular amounts of money involved.
Its real significance lies in the principles of criminal justice that it illustrates.
First, criminal offences are statutory creations. The court must identify and apply the actual ingredients of the offence.
Second, the accused’s status can matter. A person may fall within a statutory category such as clerk or servant based on the functions performed.
Third, the prosecution carries the burden of proof.
Fourth, the burden does not shift merely because the accused’s evidence appears doubtful.
Fifth, a court must distinguish suspicion from proof.
Sixth, where a fact is essential to the prosecution’s case, that fact must be established by evidence.
Seventh, criminal procedure and evidence operate together. The prosecution must present sufficient admissible evidence to establish the statutory ingredients.
RELATED AUTHORITY: REG. v. FOULKES
The court referred to Reg. v. Foulkes, 13 Cox’s Criminal Cases 63 at 67, in considering whether a person voluntarily performing duties could nevertheless be regarded as acting in the capacity of a clerk or servant.
The importance of this authority lies in its functional approach.
The question is not simply whether the person receives wages.
The nature of the duties undertaken and the obligation to perform them honestly are relevant.
This reasoning helped the court conclude that the appellant’s honorary position did not prevent him from falling within the statutory category.
LEGAL PRINCIPLE TO REMEMBER
For examination purposes, remember:
“Capacity may depend on the function performed, not merely on remuneration received.”
RELATED PRINCIPLE: ONUS OF PROOF
The stronger and more enduring lesson from the case is the burden of proof.
In criminal proceedings, the prosecution must prove the facts necessary to establish guilt.
If the prosecution alleges:
“The accused received the money before 16 April,”
the prosecution must prove that proposition.
The accused does not acquire a legal burden to disprove it merely because the prosecution’s evidence appears persuasive.
This is especially important in cases involving:
- stealing
- fraud
- conversion
- false accounting
- obtaining property
- breach of trust
- possession of property
- disputed dates of receipt
- circumstantial evidence
PRACTICAL APPLICATION
Suppose A is accused of stealing ₦500,000 entrusted to him for payment into an organization’s account for instance.
The prosecution alleges that A received the money on Monday and converted it that same day.
A says he did not receive the money until Friday.
The prosecution cannot simply argue:
“A’s explanation is unbelievable, therefore he must have received the money on Monday.”
The prosecution should produce evidence establishing when A actually received the money.
That evidence might include testimony from the person who handed over the money, documentary records, receipts, bank records, messages, or other admissible evidence.
The precise evidence will depend on the case. The important legal principle is that the prosecution must establish the essential fact.
HOW TO ANSWER AN EXAMINATION QUESTION ON THIS CASE
If asked:
“Discuss the decision in Rex v. Eters Udo Akpabio with particular reference to the burden of proof in criminal proceedings.”
A strong answer should proceed as follows:
INTRODUCTION
Identify the case and the general principle involved.
FACTS
Briefly explain the appellant’s position as Honorary Treasurer, the money involved, and the three counts.
ISSUE
Identify whether the prosecution established the necessary elements of the offences and whether the burden of proving receipt of the £7 had been discharged.
LAW
Explain the statutory offence and the general principle that the prosecution bears the burden of proving guilt.
APPLICATION
Explain why the prosecution failed to prove the date on which the appellant received the £7.
DECISION
State that the conviction on Count Three could not stand.
BROADER PRINCIPLE
Explain that the accused cannot be required to disprove an essential allegation made by the prosecution.
CONCLUSION
You can simply state that the appeal was allowed and the convictions were quashed.
POSSIBLE EXAMINATION QUESTIONS
- Discuss the decision in Rex v. Eters Udo Akpabio and explain the principle governing the burden of proof in criminal proceedings.
- Can an unpaid Honorary Treasurer be regarded as a clerk or servant for purposes of criminal liability? Discuss with reference to Rex v. Eters Udo Akpabio.
- Explain the distinction between suspicion and proof in criminal proceedings with reference to Rex v. Eters Udo Akpabio.
- Discuss the prosecution’s burden of proving an essential fact in a criminal case.
- Explain the relevance of fraudulent intent to an offence of fraudulent false accounting.
- “The failure of an accused person to provide a convincing explanation does not necessarily establish the prosecution’s case.” Discuss.
- Discuss the principle that the burden of proving criminal allegations rests upon the prosecution.
FREQUENTLY ASKED QUESTIONS
What is the main principle in Rex v. Eters Udo Akpabio?
One of the principal lessons is that the prosecution bears the burden of proving the essential facts necessary for conviction. The accused is not required to disprove an allegation that the prosecution has failed to establish.
Can an unpaid Honorary Treasurer be regarded as a clerk or servant?
Yes. In this case, the court held that although the appellant was unpaid, he was acting in the capacity of a clerk or servant because he had voluntarily undertaken and performed the relevant duties.
Why was the conviction on Count Two quashed?
The appellate court held that the necessary fraudulent intent had not been established. The prosecution could not sustain the finding of fraudulent intent in light of the appellant’s acquittal on the first count arising from the same transaction.
Why was the conviction on Count Three quashed?
The prosecution failed to prove that the appellant received the £7 before 16 April 1943. The trial judge had improperly treated the appellant’s failure to establish his own account as supporting the prosecution’s case.
What does the case teach about suspicion?
Suspicion is not proof. Even strong suspicion cannot replace evidence establishing the ingredients of a criminal offence.
KEY TAKEAWAYS
- The prosecution bears the burden of proving the accused’s guilt.
- The accused is not required to prove innocence merely because the prosecution’s allegation appears plausible.
- An unpaid person may still act in the capacity of a clerk or servant where the nature of the duties undertaken brings the person within that statutory category.
- Fraudulent false accounting requires proof of the statutory ingredients, including the necessary fraudulent intent.
- Suspicious conduct is not the same as proof of criminal guilt.
- Where the prosecution relies on a particular date or event as an essential fact, it must establish that fact by evidence.
- The court must not reverse the burden of proof by requiring the accused to disprove an allegation that the prosecution has failed to prove.
- An accused person’s explanation may be rejected, but that rejection does not automatically establish the prosecution’s alternative version.
- Criminal convictions must rest on evidence establishing the ingredients of the offence, not merely on suspicion.
- Rex v. Eters Udo Akpabio is therefore useful not only for stealing and fraudulent false accounting but also for understanding one of the foundational principles of criminal justice: the prosecution must prove its case.
In Summary
Rex v. Eters Udo Akpabio is a valuable authority for understanding the relationship between substantive criminal offences and the burden of proof.
The case began with apparently suspicious conduct involving money entrusted to an Honorary Treasurer. However, the appellate court demonstrated that suspicion could not substitute for proof.
On the second count, the prosecution failed to establish the necessary fraudulent intent. On the third count, the prosecution failed to prove the crucial fact that the appellant had received the £7 before 16 April 1943.
The court therefore refused to uphold the convictions.
Perhaps the most important lesson for every law student is this:
A criminal court does not convict because the accused appears suspicious.
It convicts only where the prosecution has proved the ingredients of the offence according to the required standard.
That principle is at the heart of criminal justice.
REX v. ETERS UDO AKPABIO THE CASE IN ONE SENTENCE
The prosecution must prove every essential element of a criminal offence; an accused person cannot be convicted merely because his explanation is unconvincing, suspicious circumstances exist, or he has failed to disprove an allegation that the prosecution itself has not established.
The Offence of Stealing/Theft in Nigerian Legal Jurisprudence
You can see more Lecture notes by Checking our criminal law categories Criminal Law
ABOUT THE PUBLISHER
LAW-MADE-SIMPLE is a growing African academic resource network and a centre for academic growth, dedicated to making complex academic and legal knowledge easier to understand, access and apply.
Founded and published by Kingsley Omenyi, popularly known as KING’S ADVOCATE, the platform provides simplified case analysis, legal principles, statutes, academic resources and student-focused learning materials for learners across Nigeria, Africa and the wider Common Law community.
Through LAW-MADE-SIMPLE, Kingsley Omenyi seeks to bridge the gap between complex legal materials and practical understanding by presenting Nigerian and African legal materials in a clear, accessible and academically useful manner, while connecting them with broader principles of the Common Law tradition.
As a finalist law student, legal educator and digital content creator, Kingsley Omenyi has a strong interest in legal education, legal research, advocacy and the use of technology to make academic knowledge more accessible.LAW-MADE-SIMPLE is being developed as a central digital resource for teachers ,students,learners and every legal person seeking reliable, simplified and practical academic materials, with Nigerian law legal education at its core and a growing focus on African legal education and the wider Common Law tradition.
Published by:
KINGSLEY OMENYI -KING’S ADVOCATE
Founder & Publisher, King’s Advocate network
Making Law Made Simple.
Contact the Publisher: Contact Kingsley Omenyi