Summary Trial

By the provisions of Sections 156 and 157 of the Criminal Procedure Code there could only be a valid conviction under the use of summary trial procedure, if the under listed conditions are complied with by the Magistrate Court, namely:-
(1) The particulars of the offence are stated to the accused
(2) The accused is asked, if he has any cause to show why he should not be convicted
(3) The accused admits that he has committed the offence
(4) He shows no cause why he should not be convicted.
See Halilu (Alhaji Maisalibu) vs. Commissioner of Police (1970) 2 All NLR 178.
It must be emphasised here, that failure to state particulars of the offence as required by Section 156 of the CPC, amounts to breach of the provisions of Section 156 of CPC and if the accused is convicted, the trial or conviction is a nullity. See Wambai & Anor vs. N. A. (1965) NMLR 17.
Similarly, if the Court omits to ask the accused/appellant to show cause and the absence of clear admission by the accused that he had committed the offence, such constitutes a failure to comply with the above conditions and such amounts to failure of justice. See Halilu (Alh) Maisalibu v COP (supra).

A summary trial is therefore a short, not long proceeding that does away with the rigours of a full trial, hearing of witnesses or tendering of the evidence. Summary trial allows for the conviction of an accused person based on his or her admission of guilt to an indictable offence other than capital offence or an offence punishable with life imprisonment. See COP v. Okoye (2012) 14 NWLR (pt. 1320) 396; Alamieyesigha v. FRN (2006) 16 NWLR (pt. 1004) 1.

The advantage and importance of summary trials have been commended in several decisions of this Court. See: Baalo Vs FRN (2016) LPELR-40500 (SC) @ 16-18 D-C, where Sanusi, JSC held as follows:
"The antecedents of this case brings to the fore the propriety of a summary trial in criminal proceedings. Where an accused person is arraigned before a criminal Court and he pleads guilty of (sic) the offence or charge he is facing... after the charge was read and explained to him, the trial Court is free to adopt summary trial and convict and sentence him provided the Court is satisfied that he really understood the charge read and explained to him before he admitted his guilt... The summary trial procedure is adopted to avoid a prolong(ed), full blown trial and the rigours associated with same.
To my mind summary trial is not only beneficial to the Court but is also of great benefit to the accused. The advantage of summary trial is that it speeds up the trial thereby saving a lot of cost and time.
... Another advantage of summary trial is that if an accused person pleads guilty as in the present case, there is the possibility for him to enjoy some degree of indulgence with regard to leniency and may also earn less stringent penalty, since by his early plea of guilt, he had relieved the Court of rigorous and lengthy time consuming trial..."