IN THE NATIONAL INDUSTRIAL COURT OF NIGERIA

IN THE PLATEAU STATE JUDICIAL DIVISION

HOLDEN IN JOS

BEFORE HIS LORDSHIP, HON. JUSTICE I.S. GALADIMA

 

DATE: 6 JULY 2O26                                                         CHARGE NO: NICN/JOS/CR/O4/2025

 

BETWEEN:

 

THE PEOPLE OF PLATEAU STATE ………………………………COMPLAINANT

 

AND

 

PROPHETESS GLORY NWACHUKWU…………………………… DEFENDANT

 

REPRESENTATION:

·        Joel Tahvan for the Prosecution

·        I.K. Randa with S.Y. Auta for the Defendant.

 

JUDGMENT:

SUMMARY OF PROCEEDINGS

The Defendant, Prophetess Glory Nwachukwu, was arraigned on a one-count charge of trafficking in persons, contrary to section 13(1) and (2)(a), (b), and (c) of the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015, filed before this Court on 23 January 2025.

The charge brought by the Office of the State Attorney-General is set out below:

Statement of offence:

Count one:

Human Trafficking contrary to section 13(1) and (2) (a), (b), and (c) of the Trafficking in Person (Prohibition) Enforcement and Administrative Act 2015:

Particulars of Offence:

That you, Glory Nwachukwu, sometime in September 2024, in Jos, Plateau State within the jurisdiction of this Honourable Court, deceived, recruited, and trafficked (1) a male child – real name unknown, (2) a female child (real name unknown) from Jos, Plateau State to Lagos State after paying the sum of N550,000.00 to one Pastor Dayo Bernard who gave out the children, upon which you were arrested in Jos North LGA of Plateau State and you thereby committed the above mentioned offence

The prosecution alleged that in September 2024, the Defendant procured and trafficked two children through one Pastor Dayo Bernard, ostensibly for adoption, after paying ?550,000.00 for each child. Proceedings began before this Court on 29 January 2025, when the Defendant was arraigned. The charge was read and explained to her in English, and she entered a plea of not guilty. After her plea, learned defence counsel made an oral application for bail on lenient terms, arguing that the Defendant was a woman of God and would attend trial. The Court granted bail in the sum of ?5,000,000.00, with one surety in the same sum, who must be a public servant not below Grade Level 14 and own landed property within the Court’s jurisdiction. The case was adjourned to 31 January 2025 for hearing.

On 31st January 2025, trial commenced.

The prosecution opened its case by calling its first witness, PW1, Inspector Dafoe Dashik, an officer attached to the Force Intelligence Department, Intelligence Response Team (IRT), Force Headquarters, Abuja. He testified that on 4 December 2024, a report of child trafficking was referred to his team for investigation. Acting on intelligence, the team arrested the Defendant and one Pastor Patrick Nnamdi at Busa Buji, Jos.

PW1 stated that investigations showed the Defendant and her accomplice had bought two children, Samuel and Sarah Usok Maren, for ?550,000 each from one Pastor Dayo Bernard. According to him, Pastor Dayo had fraudulently obtained the children from their parents in Bokkos under the pretext of enrolling them in school through an orphanage arrangement. He added that the children were between three and four years old.

PW1 further testified that, following the Defendant’s arrest, he recorded her cautionary statement. Although the Defendant could not write, she asked her associate, Pastor Patrick Nnamdi, to write the statement as she dictated it. After it was written and read back to her, she confirmed that it was accurate and signed it in his presence, after which he also countersigned it.

The prosecution sought to tender the Defendant’s statement in evidence. The defence raised no objection. The Court admitted the statement and marked it as Exhibit P1.

PW1 also said that in the statement, the Defendant confessed that after obtaining the first two children, she later paid another ?300,000 for a third child, but rejected the child on discovering that the child was a twin, and then requested another “suitable” child.

He further testified that the first two children were taken to Lagos and handed over to one Ifeoma Madueke, but when it became apparent that the police were closing in, they were returned to Jos and given to the Plateau State Commissioner for Women Affairs.

Under cross-examination, PW1 admitted that the Defendant’s lawyer was present when the statement was taken but did not sign it, that no receipt was available to show payment for the children, that he did not personally witness any exchange of money, and that his investigation report had been forwarded to the Ministry of Justice.

The defence then tendered the investigation summary through PW1, and it was admitted without objection as Exhibit P2.

At the end of PW1’s evidence, the prosecution requested an adjournment to present its remaining witnesses. The case was adjourned to 28 February 2025.

The matter later resumed on 1 July 2025, when the prosecution called its second witness, PW2, Inspector Abu Isah, another member of the investigation team.

PW2 testified that the Defendant was arrested based on confessional statements obtained from Pastor Dayo Bernard, which implicated her and Pastor Patrick Nnamdi. He stated that an examination of Pastor Dayo’s phone uncovered WhatsApp messages between him and the Defendant concerning requests for children aged one to two years.

PW2 said that when the Defendant was confronted with those messages, she admitted knowing about the transaction and confirmed that she had visited Pastor Dayo’s ministry.

He further testified that both written and video confessional statements were recorded. PW2 told the Court that he personally recorded the video statement using his Redmi Note 13 mobile phone, transferred it to his HP laptop, and then saved it onto a blue flash drive.

To prove compliance with section 84 of the Evidence Act, PW2 tendered the Certificate of Compliance and the flash drive containing the video statement.

The defence raised no objection. The Court admitted the items as Exhibit P3, the Certificate of Compliance, and Exhibit P4, the flash drive containing the video confessional statement.

PW2 further testified that his investigation showed the Defendant had been involved in arranging children for people who were looking to acquire them.

During cross-examination, PW2 conceded that he did not recover any written agreement between the Defendant and Pastor Dayo, nor did he find any receipt showing payment. He also admitted that the children were later returned voluntarily by persons in Lagos and that he did not personally recover any money from the Defendant.

After PW2’s evidence, the prosecution told the Court it had one more witness, but it later formally closed its case on 11 July 2025 without calling that witness. The matter was then adjourned to 7 November 2025 for the defence.

The defence eventually commenced its case on 29 January 2026, almost six months later. The Defendant testified as the sole defence witness, DW1.

She said she is a prophetess and pastor of Christ Ascension Church, Busa Buji, Jos. She admitted knowing Pastor Patrick Nnamdi, whom she described as her junior pastor, as well as Victoria Ugwu, a member of her church. However, she denied ever knowing Pastor Dayo before her arrest.

According to DW1, sometime in November 2024, a church member named Ifeoma told her she wanted to adopt a child. She said she connected Ifeoma with Victoria Ugwu, who had experience in adoption matters. DW1 added that Victoria later told her that ?50,000 was required for registration and ?550,000 for the adoption process.

She maintained that Ifeoma paid the money directly to Pastor Dayo and that she never handled any funds herself. She admitted, however, that she sent Pastor Patrick Nnamdi to collect the child from Pastor Dayo on Ifeoma’s behalf because Ifeoma’s phone was not reachable. She also said that after her arrest, she contacted Ifeoma and instructed her to return the child to the police.

Under cross-examination, DW1 made several important admissions: she did not know the children’s names, their biological parents, or their place of origin, and she was also unaware whether any lawful adoption approval had been obtained. She further admitted that two children, a male and a female, were eventually handed over through her church arrangement.

At the conclusion of her testimony, the defence closed its case. The parties thereafter filed and adopted their final written addresses on 18 June 2026, after which the matter was reserved for judgment.

SUMMARY OF EXHIBITS ADMITTED

During the course of trial, the following exhibits were admitted:

Exhibit P1 — Defendant’s Written Statement to the Police.

Exhibit P2 — Investigation Summary Report tendered during cross-examination of PW1.

Exhibit P3 — Certificate of Compliance under section 84 of the Evidence Act.

Exhibit P4 — Flash Drive containing the Defendant’s video confessional statement.

Thus, from commencement to close of evidence, the prosecution called two witnesses and tendered four exhibits, while the defence called one witness, the Defendant herself, and relied substantially on her oral testimony and contradictions allegedly arising from the prosecution’s evidence.

SUBMISSIONS OF LEARNED COUNSEL FOR THE DEFENDANT

Learned counsel for the Defendant, I.K. Randa Esq., in the Final Written Address settled on behalf of the Defendant and filed on 23 February 2026, formulated three issues for determination by the Court, namely:

1)    whether the prosecution proved its case beyond reasonable doubt to warrant the conviction of the Defendant;

2)    whether the Defendant committed the offence of human trafficking; and

3)    whether the Plateau State Ministry of Justice possesses the locus standi to prosecute the matter.  

On the first issue, learned counsel submitted that the prosecution woefully failed to discharge the burden imposed upon it by law. Counsel argued that by virtue of section 135(1) and (2) of the Evidence Act, 2011 and section 36(5) of the Constitution of the Federal Republic of Nigeria 1999 (as amended), the burden of proving the commission of a criminal offence rests entirely on the prosecution and must be discharged beyond reasonable doubt.

Counsel referred the Court to Mbang Efoli Mbang v State (2009) 12 SCNJ 232 and Ukatu v FRN (2021) 10 NWLR (Pt. 1785) 525 to emphasize that proof beyond reasonable doubt does not mean proof beyond all shadow of doubt, but it must be cogent, credible, and compelling enough to exclude every reasonable doubt.

It was submitted that the evidence presented by the prosecution, particularly the testimonies of PW1 and PW2, was speculative and opinionated rather than factual. Counsel argued that criminal liability cannot be founded on speculation and referred the Court to Sunday Ani & Anor v State (2009) 6 SCNJ 98, where the Supreme Court held that suspicion, no matter how strong, cannot substitute for proof.

Counsel further submitted that PW1’s conclusion that the Defendant trafficked the children was based solely on his opinion that “proper adoption procedure was not followed,” and not on any direct evidence of trafficking. It was argued that failure to comply with adoption procedure cannot automatically translate into trafficking.

Counsel contended that PW1 himself admitted under cross-examination that: he did not record the Defendant’s statement personally; the statement was written by Pastor Patrick Nnamdi; there was nowhere in the Defendant’s statement where she expressly stated that she “bought” the children; there was no receipt or documentary proof of payment for the children; he did not investigate whether the lawyer allegedly handling the adoption complied with legal requirements.  

Counsel submitted that these admissions severely weakened the prosecution’s case and exposed its speculative foundation.

Defence counsel further argued that there was no evidence from the biological parents of the children to establish that they did not consent to the transfer or adoption of the children. Counsel submitted that since the prosecution did not call any parent or guardian to deny consent, the Court ought to presume that consent may have existed. Reliance was placed on Omisore v Aregbesola (2015) 15 NWLR (Pt. 1482) 1, Buhari v Obasanjo (2005) 13 NWLR (Pt. 941) 1, and Ojo v Gbadamosi (2008) 6 NWLR (Pt. 1084) 1 for the principle that facts not denied are deemed admitted.

Counsel urged the Court to hold that the prosecution failed to establish any unlawful procurement or coercive transfer of the children.

On the second issue, learned counsel argued vigorously that the Defendant did not commit the offence of trafficking in persons as contemplated by section 13(2)(a), (b), and (c) of the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015.

Counsel reproduced the statutory provisions and submitted that for trafficking to be established, the prosecution must prove the essential ingredients, namely: recruitment, transfer, transportation, harbouring, or receipt of a person; the use of threat, force, coercion, fraud, deception, abuse of power, or payment; and most importantly, the purpose of exploitation. It was submitted that the prosecution failed to establish any of these ingredients. Counsel argued that there was no evidence whatsoever that the Defendant used force, threats, deception, or coercion against the children or their parents. It was also argued that there was no proof that the children were intended for sexual exploitation, forced labour, slavery, servitude, or any form of exploitation.

Counsel emphasized that trafficking under the Act is not complete merely because money changed hands or because a child was transferred. There must be evidence of exploitative intent. On this point, counsel submitted that the prosecution’s witnesses themselves admitted ignorance as to whether:

1)    the children were used for labour;

2)    the children were sexually abused;

3)    the children were subjected to servitude.  

Counsel argued that the absence of these crucial facts meant the prosecution failed to prove the exploitative element required under the statute.

Defence counsel maintained that what transpired was merely an adoption process gone wrong. Counsel submitted that the Defendant believed a lawful adoption process was ongoing and that a lawyer had been engaged for that purpose. According to counsel, the involvement of a legal practitioner was indicative of lawful intention, not criminal intent. Counsel pointed to the Defendant’s statement where reference was made to Barrister Ogbole Ogancha, who allegedly handled documentation, including consent letters and affidavits. It was argued that if indeed the Defendant intended to traffic children, she would not have involved a lawyer to regularize the process. Counsel submitted that this fact alone negates criminal intent.

Relying on Sanusi v State (1993) 4 NWLR (Pt. 288) 99, counsel submitted that no criminal conviction can stand without proof of both actus reus and mens rea, and that in this case, the prosecution failed to establish the guilty mind of the Defendant.

Counsel stressed that the Defendant’s intention was solely to facilitate adoption for childless women and not to traffic children. It was argued that the Defendant’s conduct, at worst, might amount to procedural irregularity in adoption, but not trafficking. Counsel further argued that the evidence of PW1 and PW2 revealed contradictions and inconsistencies, especially on the issue of how the children were procured and whether any payment was directly made by the Defendant. Counsel submitted that such contradictions created doubt which ought to be resolved in favour of the Defendant.

Counsel also attacked the credibility of PW1’s testimony, arguing that much of his evidence amounted to inadmissible opinion evidence. Reliance was placed on Esangbedo v State (1989) 4 NWLR (Pt. 113) 57, State v Ogbubunjo (2001) LPELR-3223(SC), and Afam Okeke v State (2016) LPELR-40024(CA). It was contended that the Court cannot act on speculation or conjecture and was urged to avoid descending into the arena of speculation. Counsel relied on Romrid Nig Ltd v FRN (2018) 15 NWLR (Pt. 1642) 284, Nworka v Ononeze-Madu (2019) 7 NWLR (Pt. 1672) 422, and Mohammed v Wammako (2018) 7 NWLR (Pt. 1619) 573.

On the third issue, counsel challenged the competence of the prosecution itself.

Counsel argued that by virtue of section 12(2) and section 6(c) of the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015, the National Agency for the Prohibition of Trafficking in Persons (NAPTIP) is the agency vested with powers to investigate and prosecute offences under the Act. Counsel submitted that since the law specifically established NAPTIP for prosecution of trafficking offences, the Plateau State Ministry of Justice lacked the statutory competence to prosecute the Defendant.

Counsel further referred to section 36(1) of the Act, which vests jurisdiction over trafficking offences in the High Court, and argued that the prosecution ought properly to have been initiated by NAPTIP before a competent High Court. It was therefore submitted that the proceedings were incompetent and liable to be struck out.

In conclusion, learned counsel urged the Court to hold that the prosecution failed to establish all the essential ingredients of the offence beyond reasonable doubt; that the evidence was speculative and inconclusive; that there was no proof of exploitative intent; and that the Defendant’s actions were merely part of an adoption process, albeit irregular.

Counsel finally urged the Court to discharge and acquit the Defendant of the charge.

PROSECUTION’S FINAL WRITTEN ADDRESS:

Learned prosecution counsel, led by the Attorney General of the State of Plateau, in the Complainant’s Final Written Address filed on 27/4/2026, distilled two issues for determination by the Court. The first issue was whether the prosecution had proved its case beyond reasonable doubt and established that the Defendant committed the offence charged to justify her conviction for trafficking in persons. The second issue was whether the Plateau State Ministry of Justice possessed the requisite locus standi to prosecute the Defendant.  

On the first issue, learned prosecution counsel began by reiterating the fundamental principle of criminal law that every person charged with a criminal offence is presumed innocent until proven guilty. Counsel anchored this submission on section 135 of the Evidence Act, 2023, which provides that where the commission of a crime is directly in issue, it must be proved beyond reasonable doubt. Counsel emphasized that the burden of proof in criminal proceedings lies squarely on the prosecution and remains there throughout the trial until discharged.

Counsel submitted that the prosecution in the instant case had successfully discharged this burden through credible oral testimony, documentary exhibits, and circumstantial evidence.

To support this position, counsel referred the Court to the decision of the Supreme Court in Okere v Inspector-General of Police [2021] 5 NWLR (Pt. 1770) 537, where the apex Court reaffirmed the three recognized methods by which the prosecution may establish criminal liability, namely by direct evidence of eyewitnesses, voluntary confessional statement of the accused person, or circumstantial evidence. Counsel argued that the present case was proved by a combination of direct evidence and the Defendant’s own confessional statements.

Counsel further relied on Ukatu v Federal Republic of Nigeria [2021] 10 NWLR (Pt. 1785) 519, where the Supreme Court interpreted the provisions of the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015, and outlined the ingredients required to establish trafficking involving children. Counsel argued that once it is shown that a person recruits, transports, harbours, transfers or receives a child through unlawful means, criminal liability attaches.

Learned counsel submitted that the evidence of PW1 and PW2, taken together, established that the Defendant orchestrated the unlawful procurement and movement of the children. Counsel argued that the Defendant deceived everyone around her by disguising the trafficking operation as adoption. It was submitted that the Defendant used her position as a prophetess and religious leader to manipulate vulnerable members of her congregation who trusted her, thereby abusing her authority.

Counsel contended that the Defendant lured unsuspecting church members under the pretense of helping them adopt children, whereas in reality she was operating an unlawful child procurement chain.

Counsel argued that the evidence showed clearly that no lawful adoption process was initiated or perfected. He submitted that no documents were produced to show that the Ministry of Women Affairs and Social Development, being the statutory authority responsible for adoption matters, was ever consulted.

Counsel drew the Court’s attention to the provisions of the Child Rights Law of Plateau State, 2005, particularly sections 127, 128, 130, 133, 145 and 146.

On section 133(1)(c) and (f), counsel argued that the law requires an applicant for adoption to have resided in Plateau State for at least five years and to notify a Social Welfare Officer at least twelve months before the making of an adoption order. It was submitted that the alleged adopter, Ifeoma, resided in Lagos and therefore could not lawfully adopt children from Plateau State under the circumstances presented.

Counsel further referred to section 130 of the Child Rights Law, which provides that no adoption order shall be made unless the biological parents or lawful guardians consent, or where the child is abandoned, neglected or abused and compelling reasons exist. Counsel submitted that in the instant case, there was absolutely no evidence of parental consent.

Counsel emphasized that throughout the entire trial, neither the Defendant nor any other person produced any consent document or adoption order.

Counsel also relied on section 145 of the Child Rights Law, which criminalizes the receipt or payment of money for the facilitation of adoption except with the sanction of the Court. He argued that the payment of ?550,000.00 per child was a direct violation of this statutory provision and was indicative of commercialization of children.

Further reliance was placed on section 146 of the same Law, which prohibits the transfer or movement of children outside the State for purposes of fostering or adoption without a valid licence. Counsel submitted that the Defendant’s act of transferring the children to Lagos was a clear contravention of this provision.

Prosecution counsel argued that the Defendant’s reliance on “adoption” was therefore not only defective but unlawful, and could not avail her as a defence.

Counsel submitted that Exhibit P1, the Defendant’s own statement to the police, was a confessional statement which directly implicated her. He referred to portions of the statement where the Defendant admitted that she arranged for ?550,000.00 to be paid through Pastor Dayo Bernard and admitted physically going to collect the children.

Counsel argued that this statement constituted direct evidence of her involvement in the transaction.

Counsel also relied heavily on the oral testimony of PW1, Inspector Dafoe Dashik, who testified that the Defendant admitted buying the children and that after the first two children were delivered, she later negotiated and paid ?300,000.00 for another child but rejected that child because it had a twin. Counsel argued that this fact alone demonstrated that the Defendant was not engaged in lawful adoption but was selecting children as commodities.

It was submitted that the evidence of PW2 corroborated PW1 materially. Counsel emphasized that PW2 testified that WhatsApp communications recovered from Pastor Dayo’s phone revealed that the Defendant had specifically requested children between the ages of one and two years. This, counsel argued, showed deliberate targeting and active recruitment.

Counsel argued that the Defendant’s testimony under oath was riddled with contradictions when compared with her statement to the police.

Particularly, counsel pointed out that in Court, the Defendant claimed she had never met Pastor Dayo before her arrest, yet in her statement to the police she clearly admitted visiting Pastor Dayo’s church and dealing with him directly.

Counsel submitted that this contradiction was material and fatal to her credibility.

In support of this proposition, counsel relied on FRN v Iweka (2011) 12 SCNJ, where the Supreme Court held that where a witness gives oral evidence which contradicts his previous written statement, such testimony ought to be treated as unreliable.

Counsel also referred to Mohammed v Attorney-General of the Federation [2023] 3 NWLR (Pt. 1764) 397 for the same principle.

It was the prosecution’s submission that the Court should reject the Defendant’s oral testimony and rely instead on her earlier confessional statement and the corroborative evidence of PW1 and PW2.

Counsel argued further that the Defendant’s acts squarely fell under section 13(2)(b) of the Trafficking in Persons Act, which criminalizes recruitment, transfer, harbouring or receipt of another person by means of fraud, deception, or abuse of vulnerability.

Counsel contended that the Defendant received the children, harboured them in her church premises, arranged their movement, and facilitated their transfer to Lagos.

He argued that these acts constituted the very mischief contemplated by the statute.

On the exploitative element, counsel submitted that exploitation need not necessarily mean forced labour or sexual abuse alone. Counsel argued that commercializing children, treating them as transferable property, and moving them for private arrangements outside lawful structures amounted to exploitation.

Counsel submitted that the children in this case were treated “like livestock,” procured and delivered based on demand and financial consideration.

Counsel stressed that the Defendant’s position as a church leader aggravated the offence because she abused the trust reposed in her by vulnerable congregants and the helpless children involved.

On the second issue concerning the competence of the prosecution, counsel submitted that the Defendant’s objection lacked legal foundation.

Counsel relied on section 211(1)(a), (b), and (c) of the Constitution of the Federal Republic of Nigeria, 1999 (as amended), which vests in the Attorney-General of a State the constitutional power to institute, undertake, take over, continue or discontinue criminal proceedings against any person before any court of law in Nigeria, except a court-martial.

Counsel argued that the powers of the Attorney-General are exercisable personally or through officers of his Ministry, and therefore the Plateau State Ministry of Justice was fully competent to prosecute the Defendant.

Counsel further submitted that the Attorney-General of the Federation had, by fiat dated 3rd January 2017, authorized the Attorney-General of Plateau State to prosecute federal offences created by Acts of the National Assembly, including offences under the Trafficking in Persons Act.

It was argued that this fiat further extinguished any doubt regarding prosecutorial competence.

In conclusion, learned prosecution counsel submitted that the prosecution had proved all the ingredients of the offence beyond reasonable doubt through the Defendant’s confessional statement, the testimony of PW1 and PW2, and the documentary exhibits admitted in evidence.

Counsel urged the Court to hold that the Defendant’s conduct was not a failed adoption process but a deliberate and unlawful trafficking enterprise masked as adoption, and consequently to convict the Defendant as charged.  

DEFENDANT’S COUNSEL’S REPLY ON POINTS OF LAW:

Learned counsel for the Defendant, in his Reply on Points of Law filed on 16/6/2026 in answer to the Prosecution’s Final Written Address, limited his response largely to the question of whether the Plateau State Ministry of Justice had the competence to prosecute the charge and to the alleged fiat purportedly granted by the Honourable Attorney-General of the Federation to the Honourable Attorney-General of Plateau State.

Counsel opened his reply by maintaining his earlier position that the Plateau State Ministry of Justice lacked the statutory authority to prosecute the Defendant under the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015. He argued that no law expressly empowered the Plateau State Ministry of Justice to undertake prosecution under the Act and urged the Court to reject the prosecution’s reliance on constitutional powers as an attempt to circumvent the specific statutory framework created under the Trafficking Act.

In direct response to paragraph 4.28 of the Prosecution’s Final Written Address, counsel challenged the prosecution’s assertion that the Honourable Attorney-General of Plateau State had obtained a fiat from the Honourable Attorney-General of the Federation authorizing prosecution of federal offences. Counsel argued that the purported fiat was never produced before the Court and remained a bare assertion from the bar without evidential foundation. It was his contention that the prosecution cannot rely on an unproved document or administrative instrument to clothe itself with competence.

Counsel further submitted that assuming, without conceding, that such fiat existed and was granted on 3rd January 2017 as claimed by the prosecution, there was still no evidence before the Court showing that the said fiat extended specifically to the present charge instituted in 2025. He argued that the prosecution had not demonstrated that the alleged fiat covered trafficking offences under the Act or was intended for this specific case. In essence, counsel’s position was that a general allegation of fiat, unsupported by production of the instrument itself, was insufficient in law.

Counsel also attacked what he described as the prosecution’s erroneous reliance on section 174 of the Constitution of the Federal Republic of Nigeria, 1999 (as amended). He argued that the prosecution misconceived the constitutional provision because section 174 deals exclusively with the powers of the Attorney-General of the Federation and not those of a State Attorney-General. Counsel reproduced the provisions of section 174(1)(a), (b) and (c), emphasizing that it is only the Attorney-General of the Federation who is vested with constitutional powers in relation to offences created by Acts of the National Assembly, except where such powers are properly delegated.

While conceding that section 268(4) and (5) of the Administration of Criminal Justice Act, 2015 empowers the Attorney-General of the Federation to grant a fiat to a State Attorney-General to prosecute classes of federal offences, counsel maintained that no such fiat had been shown to exist in relation to this case. He argued that the mere mention of a fiat in the prosecution’s address does not amount to proof and cannot be judicially noticed in the absence of production.

Counsel further argued that the prosecution’s suggestion that all offences committed within Plateau State automatically become offences against the State was legally flawed. He submitted that offences created under federal enactments, particularly the Trafficking in Persons Act, are governed by their own prosecutorial structure and that section 12(2) of the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015 specifically vests prosecutorial powers in the Legal and Prosecution Department of the Agency established under the Act, namely NAPTIP.

On that premise, counsel argued that the specific statutory provisions of the Trafficking Act override any broad constitutional interpretation canvassed by the prosecution, and that where the legislature has designated a particular agency for prosecution, that agency must be the proper authority to initiate such proceedings.

Counsel therefore urged the Court to hold that the prosecution lacked locus standi ab initio and that the entire proceedings were incompetent.

In conclusion, learned counsel urged the Court to discountenance all the arguments canvassed by the prosecution in its Final Written Address, uphold the objections raised in the Defendant’s submissions and reply, and discharge and acquit the Defendant.  

COURT’S DECISION:

I have carefully evaluated the totality of the evidence before this Court, both oral and documentary, and the final written addresses of learned counsel.

The primary issue for determination is whether the prosecution has proved the essential elements of the offence charged beyond reasonable doubt. By virtue of section 135(1) of the Evidence Act, 2011, the burden lies on the prosecution throughout the trial to establish its case beyond reasonable doubt, though not beyond every possible doubt. The well-known decision in Woolmington v DPP [1935] AC 462 remains the leading authority on this principle, and it has been consistently affirmed by the Supreme Court of Nigeria. See also Ibeziako v Commissioner of Police (1963) 1 All NLR 61; Isong v State (2016) 14 NWLR (Pt. 1530) 96; and Alabi v State (1993) 7 NWLR (Pt. 307) 511, where the courts reiterated that once the prosecution satisfies this burden with credible evidence, a conviction must follow.

The charge before this Court is founded on section 13(1) and (2)(a), (b) and (c) of the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015. The law is clear and deliberate. Human trafficking is not confined to chains, kidnapping in the dark, or dramatic force. The statute criminalises recruitment, transportation, transfer, harbouring, receipt, or procurement of a person, particularly a child, for the purpose of exploitation, whether or not the victim is physically restrained. The essence of the offence is the unlawful movement or handling of a human being as an object of trade, by whatever label the accused may seek to dress it up. The law does not permit a trafficker to escape liability by calling trafficking “adoption”, “assistance”, “settlement”, or “ministry work” when the facts betray a commercial transaction in children.

The prosecution called two witnesses, PW1 and PW2, and tendered documentary and electronic evidence, including the Defendant’s cautionary statement, the investigation report summary, and the video statement with its certificate of compliance. The Defendant herself testified as DW1.

I will first address the issue of whether the Plateau State Ministry of Justice had locus and competence to prosecute this matter. Learned defence counsel argued that only the National Agency for the Prohibition of Trafficking in Persons, NAPTIP, could prosecute offences under the Trafficking in Persons Act, and that the State Ministry lacked authority. That argument is attractive only if one reads the statute in isolation and ignores the Constitution and the settled law on prosecutorial powers.

Section 174(1) of the Constitution of the Federal Republic of Nigeria, 1999, vests in the Attorney-General of the Federation power to institute, take over, and discontinue criminal proceedings in respect of any offence created by or under any Act of the National Assembly. However, section 211 of the same Constitution confers a similar power on the Attorney-General of a State in relation to offences created by or under any law of the House of Assembly of that State, and also, by the settled practice of lawfully issued fiat, where authority is delegated for prosecution. Where a federal statute creates an offence, the AGF may prosecute; but it does not follow that only the AGF personally may do so in every case. The Attorney-General may act through law officers or other counsel properly authorised. See FRN v Osahon (2006) 5 NWLR (Pt. 973) 361, where the Supreme Court held that prosecution may be conducted by legal practitioners duly authorised by the Attorney-General and that the office may exercise its prosecutorial powers through delegates. See also State v Ilori (1983) 1 SCNLR 94 and Fawehinmi v Akilu (1987) 4 NWLR (Pt. 67) 797 on the breadth of prosecutorial powers.

In the present case, the prosecution submitted that a fiat had been issued by the Attorney-General of the Federation. I readily accept that such a fiat exists, and this conclusion is not undermined merely because the prosecution did not physically tender the fiat before the Court. More importantly, the Court is not satisfied that the Defendant suffered any prejudice simply because counsel from the Plateau State Ministry of Justice appeared in the matter. The Supreme Court has repeatedly held that a challenge to the competence of a prosecution is not a magic wand; the crucial issue is whether any constitutional or statutory breach has rendered the proceedings a nullity by occasioning a miscarriage of justice. See Onnoghen v FRN (2008) 7 NWLR (Pt. 1086) 48 and Tukur v Government of Gongola State (1989) 4 NWLR (Pt. 117) 517.

Now, section 268 (3) and (4) of ACJA 2015 read:

(3) Where a proceeding in respect of an offence is instituted on behalf of the AttorneyGeneral of the Federation, it shall be in the name of the Federal Republic of Nigeria.

(4) The Attorney-General of the Federation may delegate to the Attorney-General of a State the powers conferred on him by this section either generally or with respect to any offence or class of offences and such offence shall be prosecuted in the name of the Federal Republic of Nigeria.

In my view, the omission of “Federal Republic of Nigeria” from the case title does not, on its own, automatically make the proceedings incompetent or justify striking them out. The legal consequence depends on who instituted the prosecution, the authority relied upon, and whether the defect affects jurisdiction or is merely a matter of form.

Section 268(3) and (4) of the Administration of Criminal Justice Act 2015 must be read with the constitutional and statutory framework governing criminal prosecution. The section is designed to ensure that where a prosecution is instituted on behalf of the Attorney-General of the Federation, the proceedings are brought in the name of the Federal Republic of Nigeria, and where the Attorney-General of the Federation delegates his powers to a State Attorney-General, the same nomenclature is used. But the provision does not say that omission of that title is fatal in every case. Nigerian courts generally distinguish between a fundamental defect that deprives the court of competence and a curable irregularity in form.

The first and most important related question is whether the Attorney-General of the Federation is actually the proper prosecutor for the offence. In many federal offences, the AGF may prosecute personally or through law officers, or delegate to a State Attorney-General under section 174 of the Constitution of the Federal Republic of Nigeria 1999 (as amended). Once the prosecution is properly brought by or on behalf of the AGF, the case should ordinarily be in the name of the Federal Republic of Nigeria. However, if a State Ministry or State Attorney-General purports to prosecute a federal offence without lawful delegation or another valid legal basis, the more serious issue is not merely the missing title; it is the absence of prosecutorial competence. In that situation, the proceedings may indeed be vulnerable, but because of lack of authority, not simply because the caption omitted “FRN.”

The second related question is whether section 268 is mandatory in the sense that non-compliance automatically nullifies proceedings. The better view, supported by Nigerian appellate authority on analogous issues of criminal procedure, is that not every procedural non-compliance is fatal. Courts look at whether any miscarriage of justice has been caused. The Supreme Court has repeatedly held that criminal procedure statutes are to be interpreted to do substantial justice and that technical lapses which do not affect the merits or the jurisdiction of the court should not defeat proceedings. See, for example, Ariori v. Elemo (1983) 1 SCNLR 1; Ilori v. State (1983) 1 SCNLR 94; and Savannah Bank (Nig.) Ltd v. Pan Atlantic Shipping & Transport Agencies Ltd (1987) 1 NWLR (Pt. 49) 212, which, though civil in context, reflects the broader judicial approach that form should not be exalted over substance where no injustice is caused.

More directly relevant to criminal proceedings, the Supreme Court has held that where a statute prescribes a procedural step, the consequence of non-compliance depends on the wording of the statute and the purpose of the requirement. In Ojo v. Federal Republic of Nigeria (2006) 9 NWLR (Pt. 984) 103, the Court stressed that once the prosecution is competently brought, procedural complaints that do not go to the root of the case will not ordinarily vitiate the proceedings. Similarly, in FRN v. Osahon (2006) 5 NWLR (Pt. 973) 361, the Supreme Court affirmed the broad authority of the Attorney-General to prosecute and delegate prosecutorial powers, emphasizing substance over mere technical objections.

A closely related line of authority concerns who may institute criminal proceedings. In FRN v. Osahon, the Supreme Court held that officers in the office of the Attorney-General can prosecute, and that the AGF may properly authorize such prosecution. The case is important because it shows that the focus is on lawful authority, not merely the caption of the charge. Once the prosecution is being conducted under valid authority, the name in which the case is brought is ordinarily a formal matter, unless the law makes it a condition precedent to competence and the failure is shown to have caused prejudice or gone to jurisdiction.

The same approach can be seen in Attorney-General of the Federation v. Abubakar (2007) 10 NWLR (Pt. 1041) 1, where the Supreme Court recognized the constitutional powers of the AGF over federal criminal matters. The real inquiry is whether the prosecution was initiated by a person with the legal power to do so. If yes, a mistaken or omitted title may be amendable. If no, then the proceedings are defective for want of authority.

Under the ACJA itself, the general scheme also points away from automatic nullity for every defect. The Act is a remedial statute aimed at fair, efficient criminal justice, and its provisions are meant to be read purposively. The court is empowered to regulate procedure so that justice is not defeated by curable mistakes. A captioning defect, such as failure to write “Federal Republic of Nigeria” where the prosecution is clearly by a federal authority, is generally treated as an irregularity unless the accused shows that the omission caused real prejudice or that the prosecution lacked legal basis altogether.

It is therefore safer to state the rule this way: omission of “Federal Republic of Nigeria” in the heading of proceedings under section 268(3) or (4) does not automatically mean the case must be struck out. The court will examine whether the prosecutor had authority, whether the proceedings were in substance instituted on behalf of the AGF, whether any delegation under section 268(4) existed, and whether the defect has caused a miscarriage of justice. If the answer to lawful authority is yes, like in the instant case, the omission is usually an irregularity capable of amendment or being disregarded if no prejudice is shown. If the answer to lawful authority is no, the proceedings may be incompetent, but again the defect is not the mere absence of the words “Federal Republic of Nigeria”; the defect is lack of prosecutorial competence.

So, if the Plateau State Ministry of Justice prosecuted a TIPPEA charge, the more serious issue is not just whether “FRN” appeared in the suit title, but whether the prosecution was actually authorized by the Attorney-General of the Federation, because TIPPEA is a federal statute. If there was valid delegation under section 268(4), as this court had earlier found, the proceedings should still be in the name of the Federal Republic of Nigeria. If no valid delegation was shown, the defence could properly challenge prosecutorial competence. But even then, the defendant would not automatically win merely because the words “Federal Republic of Nigeria” were omitted; the court would determine whether the omission reflects a deeper absence of authority or a curable irregularity.

The key cases you can safely rely on include FRN v. Osahon (2006) 5 NWLR (Pt. 973) 361; Attorney-General of the Federation v. Abubakar (2007) 10 NWLR (Pt. 1041) 1; Ojo v. Federal Republic of Nigeria (2006) 9 NWLR (Pt. 984) 103; Ariori v. Elemo (1983) 1 SCNLR 1; and Ilori v. State (1983) 1 SCNLR 94.

The second objection raised by learned counsel for the Defendant is to the effect that this Court lacks jurisdiction and that only the High Court can entertain this matter.

Jurisdiction is the lifeblood of adjudication. It is fundamental and indispensable. Where a court lacks jurisdiction, all proceedings, however well conducted, amount to a nullity. See Madukolu v. Nkemdilim (1962) 2 SCNLR 341. But the law does not permit a party to oust jurisdiction by mere assertion or by citing the wrong forum. The question is always whether, on the Constitution and the enabling statute, this Court is seised of competence to determine the charge before it.

By section 254C(1) of the Constitution of the Federal Republic of Nigeria, 1999 (as altered), the National Industrial Court of Nigeria is vested with jurisdiction in civil causes and matters relating to, among other things, labour, employment, industrial relations, trade unions, workplace disputes, and matters incidental thereto.

It is true that section 254C is primarily framed in civil terms. However, the Constitution also makes room for this Court to exercise jurisdiction over certain offences where they are created to protect the subject matter of the Court’s substantive jurisdiction – see section 254C (5). The Constitution itself, particularly section 254C(1)(a), (k), (m), and the proviso thereto, recognises the authority of the NICN to deal with matters incidental to its statutory mandate.

What this means in plain terms is this: once a statute creates offences that are tied to employment, labour, trade union, industrial relations, or matters within the Court’s constitutional sphere, the National Industrial Court is not a helpless spectator. It may exercise the jurisdiction conferred upon it by that statute and by the Constitution.

The decisive answer lies in the wordings of the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015.

Under section 13(1) and (2) of the Act, trafficking in persons is an offence. More importantly, the Act provides a special enforcement framework and confers prosecutorial and adjudicatory competence on designated courts for offences under the Act. Where Parliament has lawfully vested jurisdiction in a court of coordinate constitutional standing to try a specific category of offence, that statutory command must be given effect.

In matters of trafficking connected with exploitation, recruitment, harbouring, transfer, and receipt of persons for unlawful purposes, the law recognises the need for a specialised adjudicatory route. The statute does not confine all such offences exclusively to the State High Court. The argument of learned defence counsel that only the High Court can try the case is therefore too rigid, too simplistic, and unsupported by the statutory text.

Let it be said clearly: the National Industrial Court is not a lower court begging for permission from the High Court before it may act. It is a superior court of record established by the Constitution. See section 254A(1), (2), 254C(5), and 254D(1) of the Constitution.

This Court stands on the same constitutional footing of superiority as other superior courts of record within its assigned field. Once a matter is brought before it under a law validly conferring jurisdiction, the Court is bound to exercise that jurisdiction. The mere fact that a criminal charge is involved does not automatically oust the jurisdiction of this Court where the enabling law validly places the matter before it.

The Defendant’s counsel’s submission rests on the mistaken assumption that all criminal matters belong exclusively to the High Court. That is not the law.

The Constitution does not say that only the High Court may try all offences. Rather, it permits the National Assembly to enact laws conferring criminal jurisdiction on competent courts where appropriate including the NICN. This is a settled principle of constitutional adjudication. Jurisdiction is a creature of statute and the Constitution, not of convenience or conjecture.

The Supreme Court has repeatedly held that jurisdiction is determined by the complainant’s or prosecutor’s originating process and the enabling law. See Tukur v. Government of Gongola State (1989) 4 NWLR (Pt. 117) 517. The court asks: what is the claim, what does the law provide, and which court is empowered to hear it? Once those questions are answered in favour of jurisdiction, the court proceeds.

A litigant cannot defeat criminal proceedings merely by shouting “jurisdiction” without demonstrating that the court before which the matter is brought is constitutionally or statutorily disabled from hearing it. That burden was not discharged.

What was placed before the Court was not an ordinary domestic adoption dispute. The evidence disclosed a commercial transfer of children, recruitment, receipt, movement, and harbouring for unlawful purposes. That is trafficking conduct. It is the substance of the charge, not the label attached to it by the defence, that determines jurisdiction. Courts look at the real nature of the complaint, not the camouflage used to disguise it. The Defendant cannot convert a trafficking charge into a mere adoption arrangement by verbal alchemy. The law is concerned with conduct, not costume.

Where the law creating the offence designates the court or class of court to try it, that designation must be respected. Courts have consistently upheld the principle that a special statute may validly assign jurisdiction to a specialised court where the Constitution permits it.

So, the National Industrial Court, being a superior court of record, is fully competent to exercise such jurisdiction as the Constitution and an Act of the National Assembly confer upon it. The law does not require that every offence under every federal statute must go to the Federal or State High Court. That proposition has no foundation in our jurisprudence.

Accordingly, I hold that this Court has jurisdiction to entertain and determine the charge against the Defendant. The objection of learned counsel that only the High Court can try the case is overruled.

Let me now turn to the evidence itself, because that is where this case was won and lost.

PW1, Inspector Dafoe Dashik, testified that the matter was referred to his team by the Force Intelligence Department, and that investigations led to the arrest of the Defendant and one Pastor Patrick Nnamdi. He stated that the Defendant and her accomplice purchased two children, Samuel and Sarah Usok Maren, for ?550,000 each from Pastor Dayo Bernard, who had allegedly obtained the children from their parents in Bokkos under false pretences. PW1 also testified that the children were about three to four years old, and that the Defendant’s statement was recorded, read over to her, and signed by her. The statement was admitted as Exhibit P1 without objection. Under cross-examination, PW1 admitted he did not personally witness the exchange of money and no receipt was recovered.

PW2, Inspector Abu Isah, testified that the Defendant was arrested based on confessional statements from Pastor Dayo Bernard. He said WhatsApp messages recovered from Pastor Dayo’s phone showed conversations with the Defendant concerning children aged one to two years. He further testified that both written and video confessional statements were recorded, and Exhibits P3 and P4, being the certificate of compliance and flash drive, were admitted. Under cross-examination, he admitted that no receipt or written agreement was recovered and no money was recovered from the Defendant.

The Defendant’s own testimony is the strongest corroboration of the prosecution case. She said she is a prophetess and pastor, that a church member, Ifeoma, wanted to adopt a child, and that she merely connected her with people experienced in adoption matters. But then came the admissions that matter most. She admitted that Ifeoma paid ?50,000 for registration and ?550,000 for the adoption process. She said she never personally handled the money, but she admitted sending Pastor Patrick Nnamdi to collect the child from Pastor Dayo on Ifeoma’s behalf. She also admitted she did not know the children’s names, parents, or origin, was unaware whether lawful adoption approval had been obtained, and admitted that two children were eventually handed over through her church arrangement.

The law is settled that an accused person may be convicted on his or her own confessional statement if it is positive, direct, and voluntarily made. See Kanu v King (1952) 14 WACA 30; Nwaturuocha v State (2011) 6 NWLR (Pt. 1242) 170. A confession need not be a complete narrative of guilt in every detail; it is enough if it admits the essential facts constituting the offence. In this case, Exhibit P1, coupled with the oral testimony and the video statement, is not only admissible but powerfully incriminating. The Defendant’s attempt to dress this up as an “adoption arrangement” is a transparent attempt to sanitise conduct that the law condemns.

The defence argument that there was no proof of force, deception, or exploitation is not supported by the statutory text. Under the Trafficking in Persons Act, exploitation is not limited to physical abuse. The Act criminalises recruitment, transportation, transfer, harbouring, receipt, and procurement for the purpose of exploitation. The exploitation may be commercial, abusive, or otherwise unlawful. A child is not a commodity to be sourced through intermediaries and exchanged for money. Where a person actively facilitates the movement of children from one location to another in return for money, without lawful adoption approval, parental consent proved in law, or statutory authorisation, the law presumes the sinister nature of the act from the surrounding circumstances. The Court is entitled to infer intent from conduct. See Sugh v State (2010) 12 NWLR (Pt. 1208) 192, where the apex court held that intent is often inferred from the totality of the circumstances and the conduct of the accused before, during, and after the offence. See also ALH. ABDULLAHI SHEHU v. FEDERAL REPUBLIC OF NIGERIA & ORS (2022) LPELR-58922(CA).

The defence’s “failed adoption” theory also collapses under legal scrutiny. Adoption of children in Plateau State is regulated by the Child Rights Law and the relevant family court process. Adoption is not a private commercial arrangement brokered by pastors, intermediaries, and informal payments. Under the Child Rights Act, 2003, which many states have domesticated in one form or another, adoption is a legal process requiring welfare investigation, court approval, and compliance with statutory safeguards. Even where a child is available for adoption, the law does not permit the clandestine procurement of children through monetary inducement and middlemen. The absence of any lawful adoption order, parental consent verified by the appropriate authority, welfare approval, or transfer licence is not a mere technical omission; it is the very heart of the criminality. An unlawful adoption is not a species of lawful excuse. It is evidence of trafficking in disguise.

The Court has considered the WhatsApp messages recovered from Pastor Dayo’s phone and the video statement tendered through a certificate of compliance. Electronic evidence is admissible where the conditions in section 84 of the Evidence Act, 2011 are satisfied. The Supreme Court in Kubor v Dickson (2013) 4 NWLR (Pt. 1345) 534 made it clear that computer-generated evidence must comply with section 84. The prosecution here laid the proper foundation through the certificate of compliance, and the defence did not successfully dislodge that evidence. The messages corroborate the narrative that the Defendant was not a passive bystander but an active participant in the procurement and movement of the children. Corroboration may be direct or circumstantial. See Adisa v State (1991) 2 NWLR (Pt. 175) 259.

I also reject the suggestion that because no money was recovered, no offence was proved. A criminal transaction is not rendered lawful because the police failed to seize the proceeds. In numerous cases, courts have held that where direct evidence is unavailable, a conviction may rest on strong circumstantial evidence so long as the circumstances point irresistibly to the guilt of the accused and are incompatible with innocence. See Lori v State (1980) 8-11 SC 81; and Ukorah v State (1977) 4 SC 167. Here, the Defendant’s admissions, the written statement, the transfer of two children, the admitted involvement of her church and pastor, and the absence of any lawful adoption documentation all point in one direction only.

The conduct of the Defendant is especially troubling because she occupied a position of spiritual trust. The law does not punish a person because she is a pastor or prophetess. But where a person uses that office to create credibility, to recruit trust, and to facilitate the movement of children as if they were goods in a market, that position aggravates the moral culpability of the act. Religious garb is not a shield against criminal liability. The Court must say so plainly: the robe does not purify the conduct.

As to the standard of proof, once the prosecution establishes the essential elements of the offence, the burden shifts in a practical sense to the accused to raise a reasonable doubt. The Defendant did not do so. Her evidence was riddled with self-contradiction. She claimed mere connection, yet admitted sending someone to collect the children. She claimed adoption, yet knew nothing of lawful approval. She claimed innocence, yet accepted the existence of payments tied to the process and the ultimate transfer of the children. That is not a credible defence; it is a confession in fragments.

The Court also notes that the prosecution’s case was not weakened by the fact that the remaining witness was not called. The law is settled that the prosecution is not bound to call a host of witnesses once the evidence available is sufficient to prove its case. See Alonge v I.G.P. (1959) 4 FSC 203; Osetola v State (2012) 17 NWLR (Pt. 1329) 251. A court is concerned not with the quantity but the quality of evidence. Here, the quality was enough. The prosecution may have called only two witnesses, but their evidence was fortified by the Defendant’s own admissions and documentary exhibits.

I also bear in mind that where there is a conflict between a bare denial and credible, consistent, corroborated prosecution evidence, the court is entitled to prefer the latter. See State v Danjuma (1997) 5 NWLR (Pt. 506) 512 and Nwobodo v Onoh (1984) 1 SCNLR 1 on evaluation of evidence and the duty of the trial court to believe or disbelieve on the basis of credibility and consistency. I do not believe the Defendant’s account that this was merely a benign adoption arrangement. The facts do not support it, and the law does not permit it.

For all the reasons already given, I hold that the prosecution has proved beyond reasonable doubt that the Defendant recruited, received, facilitated the transfer of, and trafficked two children by deceitful means and for unlawful purposes, contrary to section 13(1) and (2)(a), (b), and (c) of the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015.

Accordingly, the Defendant, Prophetess Glory Nwachukwu, is hereby found guilty and is accordingly convicted for the offence of trafficking in persons contrary to section 13(1) and (2)(a), (b) and (c) of the Trafficking in Persons (Prohibition) Enforcement and Administration Act 2015.

ALLOCUTUS:

The convict is asked to say why sentence should not be passed upon her.

The defendant is a first offender.

This shall be the judgment of the Court.

SENTENCE:

Having considered the allocutus and the submissions of learned counsel for the Defendant in mitigation, as well as the fact that the Defendant is a first offender, this Court hereby sentences the Defendant to two (2) years’ imprisonment and a fine of ?250,000.00, punishable under sections 13(1) and 13(2) (c) of TIPPEA 2015. The sentence shall be less one month she spent in custody pending her admission to bail by this court.

The Defendant’s name and photo shall also be entered into the national trafficking offenders register and be placed under correctional monitoring upon release in accordance with the law.

Delivered in Jos this 6th Day of July 2026

 

Hon. Justice I. S. Galadima,

Judge.