In response to the first issue as to whether E-mail evidence could be admissible before the court of law,

Your honor an accused person is guilty of an offence of moeny laundering and unlawfully deal in
goverment trophy due to the fact that the provision of section 12(a,b,c and d) and section 13(2) of the
Anti-money laundering Act 2006 RE 2019 and section 68 of Wild Life Consevation Act Cap 283 RE 2002
read togather with section 13(b) of the first schedule and section 57(1) of the Economic and Organized
Crime Control Act Cap 200 RE 2002.

In order to prove the offence against him the prosecution intend to produce e-mail evidence so as to
prove the evidence against him which show his conversation. You honor e-mail evidence is discussed in
the case of Lazarious Mrisho Mafie and another V Odilo Gasper Kilenga cormecial case no 10 2008 HCT
Arusha (Unreported) where's in this case the dispute was whether an e-mail should be admissible as
evidence in the court of law this cas ewas before Makaramba J who admit the admissibility of E-mail and
give out five criteria

· Whether an e-mail was relavant to

· Whether it was authentic

· Whether e-mail is original or duplicate

· What is the probative value of the e-mail

· Whether it was covered under exception to the hearsay rule

In such regard section 3 and 18(2) of the Electronic Transaction Act of 2015 provide for the weight to be
measured so as to admit the admissibility of data message

Your honor i pray before this honorable court to admit the e-mail evidence as evidence and the accused
to be found guilty of the offence and be convicted according to the law due to the fact that the criteria
stipulated in the case and the condition provided under the Electronic Transaction Act is similar to the
case at hand.

In responce of the second issue whether tape record could be admissible before the court of law: Due to
the conversation recorded on the accused discussions with his donors and identified the accused person
to be engaged in illegal issues with those donors and due to the law those recorded conversation
tenderd as evidence to prove on what was going on upon an accused person behind his work and
property managed. Your honor tape recording is the kind of evidence based on electronic evidence as
defined under section 3 of the Electronic Transaction Act of 2015 to mean a record stored in electric
form. Electronic evidence is admissible in court and prodused as an evidence since the provision of
section 40A of the law of evidence (RE 2002) Amended in written laws of 2007 which allows the
admissibility of electronic evidence in criminal matters.

Section 7-8 of the law of Evidence Act RE 2002 provide for the evidence to be admissible must be
relavant to the issue in the litigation and these issue the evidence of tape recording could be admissible
because it's relavant tot he matter involved. The evidence being electronic evidence it must be authentic
to mean that a part relies upon has not changed from the moment were created in the case of Salum
Said Salum v DPP criminal Appeal no 3 of 2013 HCZ Vuga (unreported). The court admit electronic
evidence based on VCD including several guidelines such as proper identification of the voice and the
relavance of the evidence to the issue, though these guidelines related to the matter uppon an accused
person due to the recorded conversation which identified the voice found was accused voice and it
related to the issue upon him. Also in the case of Salau Dean v Republic 1966 EA272 the court held that
the tape record is admissible before the court of law whereby the court provide various reasons for the
tape record to be admitted before the court as (a) the voice of the person against whom such recording
is being produced as evidence, must fully identified by the person who is produced such recording. (b)
the accuracy of the tape recorded statement has to be provided by the marker of the record by
satisfactory evidence (c) the statment must be relavant according to the evidence Act (d) the recorded
cassette must be carefully sealed and kept in the safe or official custidy and (e) the voice of the oerson
should be clearly audible and not lost or distroyed by other sounds or disturbances.

Your honor the criteria provided in the Salum Dean's case by the court is relating to our case at hand
where's the criteria's provided is provided by the evidence adduced by the prosecutor to prove that the
accused person is liable for the offence which he is committed.

In response to the third issue as to whether banking record could be admissible before the court of law.
Your honor an accused person is guilty of an offence of money laundering and unlawful deal in
goverment trophy due to the fact that the provision of section 12(a)(b)(c)and(d) and section 13(2) of the
Anti-money laundering Act 2006(RE2019) and section 68 of Wildlife Consevation Act(Cap 283 RE2002)
read togather with section 13(b) of the first schedule and section 57(1) of the Economic and Organized
Crime control Act (Cap 200-RE) (2002). Your honor the electric evidence brought before this honarable
court which is banking record of the accused person account is adduced here in an evidence which were
severally reported the central bank following the accused person suspicious transaction.

These evidence prove the accused person is conduncting illegal activities.

This evidence could be admitted before honarable court as provided under section 40A of the law of
Evidence Act RE (2002) which allow the applicability of the criminal proceeding, also section 78A (1) of
the same Act allow the applicability of bank on micro-film computer as evidence in the court of law. Also
section 18(2) of the Electronic Transaction Act of 2015 which allow the admissibility of the electronic
evidence. Your honor this evidence is stipulated in the case of Trust Bank Tanzania Ltd v Le Marsh
Enterprises Ltd cormecial case no 4-2002 TLR 144. The issue was whether or not a computer print-out is
a bank's book under evidence Act. The court rule that they consider admissibility of computer evidence.
Also this was stipulated in the case of Exim Bank (T) Ltd V Kilimanjaro coffee Company Ltd case no 29 of
2011 where the decission of the court is similar to Le Marsh case.

In response to the fourth issue as to whether CCTV footage could be admissible before the court of law,
the accused person is guilty of an offence of money laundering and several economic crime including
drug traficking and goverment trophies contrsry to sectiom 12 and 13 of the Anti-money laundering Act
2006. Togather with section 15 (1and2) of the Drug control and Enforcement Act 2015 and paragraph 13
(b) of the first schedule and section 57 (1) of the Economic and Organized Crime Act 2002. The electric
evidence of CCTV footage tendered before this honarable court law by the police officer who ambushed
Omar residence premises where police seized his electric and physical on his trading it realized that
there is unusual movement within the center associated with goverment trophies evidenced that
accused person is guilty concerning that office.

Due to the provision provided under section 3 of Electronic Transaction Act of 2015 togather with
section 18(2) (a) (d) of the same Act and section 40A of the Tanzania Evidence Act cap 6 RE 2010, provide
the admissibility of electric evidence where it allow the application of data message as evidence in the
court of law because all the matter discussed in the case at hand is relavsnt to the issue iligation due to
the evidence captured by the CCTV(closed -circuit television) footage may be tendered to the court of
law and admitted basing as evidence of electric evidence which prove of Tanzania Cotton marketing
board v Cogecot cotton company 1997 TLR 165 CA. The court held that the electric communication
mode of sending arbitration award to the high court contrary to rule 4 of arbitration ordnance.

Criteria for VCD(Video Compact Disk) to be admitted as evidence which are: (1) the accuracy of VCD, (2)
proper identification of voice and picture, and (3) the relavant to the issue in the litigation. The court
rightly observed that the hallmark of the condition for admissibility of an electric evidence is provided
under section 18 (1)(2) of the Electric Transaction Act 2015. Where by criteria provided under that
section is relating to this matter at hand. this also is stipulated in the case of Emmanuel Godfrey
Masanga v Edward Franz Mwalongo miscelenious civil cause no 6 of 2015 HCT (Iringa District Registry)
Njombe Ureported, where the court observing criteria provided under section 18(2) of the Electronic
Transaction Act of 2015. The court held that VCD could be admitted in both criminal and civil proceeding
by virtual of Electronic Transaction Act 2015. Due to that condition it realized that Omar is liable and is
nothing but professional conman who trading in goverment trophy.

In response to the fifth issue as to whether expert evidence could be admissible before the court of law.
Your honor the accused person is guilty of an offence due to the provision provided under section 13(a)
of the Anti-money laundering Act No12 (RE 2019) and section 18 of the Wildlife Conservation Act (Cap
283 RE 2002) as read togather with section 13 (5) of the first schedule and section 57(1) of the Economic
and organized Crime Control Act (Cap 200 RE 2002) the accused is proved guilty by the evidence
adduced by the two inspector since they save as expert. This could be admitted due to the provision
provided under section 47 of the Tanzania evidence Act (Cap 6 of 2010) therefore it is proper to ask for
an opinion from expert as provided in the case of Gutheru Njangwaru v Republic (1954) East African
Court of Appeal 384, The court observed that within such specific skills is not confined to knowladge
acquired academically but would also include skills acquired by practical experience. It may will be that
in the presence circumstances Kenya police officer employed in operation or investigation work acquired
a sufficient practical knowladge as to qualify him to speak as an expert.

The two inspectors who were pretending to be Omar his right hand man for three years proved that they
have a strong knowladge and widely experience concern the aspect of investigation. Due to that regard
the court could admit the evidence adduced by the two inspectors as a witness because the expert
evidence admissible before the court of law as provided under section 47 of the Tanzania Evidence Act
and the accused person to be found guilty of the offence and to be convicted in accordance with a law.

We pray before this honorable court to admit the evidence adduced by the prosecution side and
accused to be found guilty of the offence and to be convicted in accordance to the law.