who testifies on his own behalf in a joint trial, and who incriminates a co- accused: Ukut and others v the state (1968). A Bribe giver who meets the monetary demand of bribe taker: R v Usman Pategi (1957), Okeke v the Police (1948); Osidola v COP. (1968). A person, who takes no part in a crime but is merely an eye witness: Queen v Ukut (1960). See ENAHORO v THE QUEEN (1965) 1 NLR 125 was charged with conspiracy with others to commit treason. O was assigned a responsibility. He subscribed to the oath, but declined his role. He did not report to the police. O was a prosecution witness and it was contended that he was an accomplice. The Supreme Court held that O might have been guilty of an offence under a different section of the code for failure to reveal the plot, but this offence is a separate and distinct offence from the conspiracy charged. Accordingly O is not an accomplice. The Evidence Act Provision. The Evidence Act, Section 198 provides that an accomplice shall be a competent witness against an accused person and a conviction is not illegal merely because it proceeds upon the uncorroborated testimony of an accomplice. Provided that in cases tried by a jury when the only proof against a person charged with a criminal offence is the evidence of an accomplice uncorroborated in any material particular implicating the accused, the judge shall warn the jury that it is unsafe to convict any person upon such evidence though they have a legal right to do so and in all other cases, the court shall direct itself. The judge must warn himself of the danger of convicting on the uncorroborated evidence of an accomplice who testifies for the prosecution. Having warned himself the judge may convict upon uncorroborated testimony if he believes the evidence