“In the context of forgery, while the English law under the Forgery Act, 1913, necessitates an intent to defraud or deceive, the Nigerian Code simplifies the pleading process by embedding such intents within the allegation of forgery itself. Specifically, under section 465 of the Nigerian Criminal Code, a charge that simply states a person forged a document, detailing the falsehood, is legally sufficient without an intricate account of the intent. It remains the prosecution’s duty to prove the intent was present, but specifying the intent in detail, as seen in the counts of the indictment, may be superfluous and potentially imprudent.”
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