He further argued that the burden of proof in criminal proceedings lies solely on the prosecution, citing Sections 11 and 15 of the Evidence Act, 1975 (NRCD 323). He maintained that although the practice direction attempts to cushion the disclosure requirement with the phrase “without prejudice to the constitutional presumption of innocence,” the Constitution itself does not provide for any such qualification, rendering the practice direction inconsistent with the Constitution. Reference was made to Republic v Baffoe-Bonnie and Others (2017–2020) SCGLR 342, as well as Republic v High Court (General Jurisdiction), Accra; Ex parte Zenator Rawlings (Ashirtey & NDC, Interested Parties). She submitted that Part 2(3)(a) of the practice direction is not inconsistent with Articles 19(2)(c), 19(2)(e), or 19(10) of the Constitution. She further relied on authorities including Aduamoah II v Twum II (1999) 2 GLR 409, Republic v Court of Appeal, Cape Coast; Ex parte James G. Quayson (SC, July 27, 2022), and Republic v Regional Tribunal; Ex parte Akorsah (1980) GLR 592, to submit that no real or genuine issue of con