understood from il lustrations as follows: Koyo, a brewer supplies beer. He supplied beer to Haruna and there was no complaint. It was good beer. He supplied beer to Dogo who complained that the beer which Kodgo supplied was bad. Kodjo denies and seek to put in evidence that the beer he supplied are good beer and had supplied good beer to Haruna. Ado obtained N50,000.00 by false pretence (4-1-9-) from Folashade in 2009. Ado also obtained N20,000.00 by false pretence from Chukwu in 2010. Again he has been arrested for obtaining N150,000.00 from Fatima by false pretence. He is charged to court. Ado denies the The prosecution seeks to calFolashade and Chukwu to testify to previous fraud or to tender evidence of previous conviction for obtaining by false pretence. What the brewer and Ado seek to do is to give evidence of facts similar to a fact in issue. Had both of them adduced evidence as regards the same line of transaction as with the case at hand, the evidences would have been admissible. The general rule of Similar Facts evidence is established in the expression of Lord Herschell. He stated the general rule when he said as follows: “it is undoubtedly not competent for the prosecution to adduce evidence tending to show that the accused had been guilty of criminal acts other than those covered by the indictment; for the purpose of leading to the conclusion that the accused is a person likely form his criminal conduct or character to have committed the offence for which he is being tried.” See the case of Makins v Attorney General for New South Wales [1894] AC 59 But it must be noted that a contrary view to the above was maintained by Lord Goddard when he argued as follows: “if one starts with the assumption that all evidence tending