basis of coincidence. The case stated that in admitting such evidence the judge should exercise his discretion to admit the evidence only on the satisfaction of the following: That its probative force in relation to an issue in the trial outweighs the prejudicial effect, and That there was no possibility of collaboration between the witnesses Common Law Rule of Similar Fact Evidence in Nigeria Prior to the advent of the Evidence Act in Nigeria, the common law rule of similar evidence as upheld in the case of Makin were made applicable in some Nigerian cases, prominent among which is the case of R v Adeniji [1937] 3 WACA 185. In this case the appellant was charged with the offence of being in possession of moulds for minting coins under the Criminal Code. The Court held that the evidence of previous uttering of counterfeit coins by him was admissible in order to establish guilty knowledge. Also in the case of Akerele v R [1943] A.C. 255, a similar position as in the above case was maintained. In this case the appellant a Medical Practitioner gave injections of mixtures to a number of children among who is the deceased who died as a result of the injection given by the appellant. At the trial the court held that the evidence of the fact that other children died as a result of the injection given to them by the accused at the same time and from the same mixture was held admissible. It is noteworthy that such decisions as above would have been reached even after the advent of the Evidence Act because, it tends to look like the position in the case of Makin as examined above, has become adopted in our Evidence Act, particularly in Section 17 of the Evidence Act 1990 which is now Section 12 of the Evidence Act 2011 and it provides as follows: When there is a question