“Instigating a crime is no more than to goad or incite another to do an act that is a crime. It is a specie of the offence generally referred to as criminal conspiracy. Even at common law it is an indictable offence for one person to incite or instigate another to commit an offence: R. v. Rams Ford 13 Cox 9.”

PER E. EKO, J.S.C. IN THE CASE OF ADIELE NDUBUISI V THE STATE : LER [2018] SC.488/2015