In my view, it is not necessary, in order to meet the requirements of section 215 of the Criminal Procedure Law of Lagos State that the presiding judge must put down in writing words to the effect that he is satisfied the accused understand the charge to his satisfaction. It is sufficient if the arraignment is as recorded in this case where there is substantial compliance with procedural provision.
— Wali JSC. Onuoha v State (1998) – SC. 24/1996