This was an appeal on the decision of the Chief Magistrate that found the appellant guilty of possession of four pieces of raw ivory and two hippo teeth without a permit or licence. The appellant argued for an acquittal as per s 188 (b) of the Criminal Procedure and Evidence Code; on grounds that the state failed to prove beyond reasonable doubt. He relied on the definition of “possession” “be in possession of” or have in possession” in s 4 of the Penal Code, that requires proof of knowledge and control of anything in one’s actual possession. The appellant also pointed to the inconsistencies by state witnesses on where his arrest took place and the failure of the state to prove how the bag of ivory and hippo teeth found its way onto the undercover vehicle. The state supported the conviction, on the same grounds given by the Chief Magistrate: the appellant was found in possession since he squeezed himself to the bag in the car signifying a sense of security.