In Agwuna V AG Federation (1995) 5 NWLR (Pt.396) 418, the Supreme Court per Iguh, JSC held as follows – “It is certainly not the law that it is only the person who manually writes or signs a forged document that may be convicted for forgery of the document. The position of the law is that all persons who are, participles criminis whether as principals in the first degree or as accessories before of after the fact to a crime are guilty of the offence and may be charged and convicted with [the] actual commission of the crime.”
PROVING THE OFFENCE OF UTTERING
Indeed, to establish the offence of uttering, the prosecution must prove that (a) the document/writing was false; and (b) the false document was knowingly and fraudulently uttered.
— J.H. Sankey, JCA. Brila Energy Ltd. v. FRN (2018) – CA/L/658CA/2017