TOPIC: EXPEDITING THE COURT PROCESS THROUGH THE APPROPRIATE USE OF CASE LAW*
BY: LAYI BABATUNDE, SAN.
It has been said, not without justification, that ‘ justice delayed is justice denied ‘. It is against this background that I have taken some time to reflect on above topic, which to me represents a possibility. Indeed I have solemnly asked myself: Why not, given the body of tested decided judgments, particularly of the apex court readily available? My short address therefore is a sketch of my reflection on the use to which I believe, we, as lawyers, can put to better use, previously decided cases to achieve quicker and qualitative justice delivery. Judging from my experience as a practitioner and Editor -in – Chief of Judgments of the Supreme Court of Nigeria, it appears to me, that we can do more to expedite the process through proper use of case Law, than we are presently doing. I wish to preface my brief address with few helpful Quotes;
- ”The essence of the administration of Justice, it must be emphasized, is to make access to Justice as quickly and cheap as possible” – Per Onu JSC ( as he then was ) in ELABANJO & ANOR V. DAWODU (2006) 6-7 SC 24 @ 48 page 35.
- Cases must be heard with dispatch and resolved quickly”. Per Rhodes – Vivour JSC, in SOCIETY BIC. S.A & 2ORS V. CHARZIN IND LTD (2014) 2 S.C (Pt II) 57 @ 97 Para –
- “True, we build no bridges. We raise no towers. We construct no engines. We paint no pictures- unless as amateurs for our own amusement. There is little that we do that eye of man can see. But we smooth out difficulties, we relieve stress, we correct mistakes, we take up other men’s burdens and by our efforts we make possible the peaceful lives of men in a peaceful state.”- John W. Davis – (Former President, New York City Bar Association) (underlining supplied)
However If we are to achieve the above, to begin with, we must appreciate the appropriate ways of using case law as reported by credible Law Reports. I say credible Law Reports, because we are now living witnesses to all sorts of materials, labeled as Law Reports! Some of them have no regard for chronological order of case Law, such that judgments delivered in the 70s are being published as if they were judgments just delivered! This is highly misleading and constitutes a great problem, if not danger to quality justice delivery. Having said this, here are a few examples of things we must get right, even while using credible Law Reports, if case law is to be of envisaged assistance in quicker justice delivery:
- CITATION OF CASES:
Over reliance on the use of numbered ratios by counsel has engendered laziness with improper case citation practice. The proper way and manner to cite a judgment, as we have learnt, is to refer first to the title of such case, the law Report in which it is reported, then the page in which it is reported and if there is any point of emphasis in any particular page, then that particular page or paragraph should be referred to as the case may be. I state with humility that it is not good practice to cite a judgment by reference to numbered ratios which more often than not, is nothing more than a written opinion of what the Editor perceives the Honourable Court to have said. The better way, I believe is to cite a judgment by reference to the direct pronouncement of the court, and not the Editor’s summary of same. The practice therefore, of citing cases by reference to numbered ratios should have no place in legal practice and should be seriously discouraged by the Bar and the Bench. The Supreme Court in the case of FRANCHAL v. NIGERIA ARAB BANK LTD. (2000) 6 S.C. (PT. I) 1 at 12 Per Uwais CJN; (as he then was) held thus; “It is hazy for counsel to rely on headnotes in Law Reports instead of reading the whole of the facts of the case he is relying on to see how relevant the decision in the case is to his own case”.
- Great care must be taken by the party relying on decided cases to distinguish between what constitutes the ratio of a case, as distinct from pronouncements rendered The Supreme Court restated the limit of obiter dicta in BUHARI v. OBASANJO (2003) 11 S.C. 74 at 85, per Belgore, JSC. (As he then was) thus:
“Those who are familiar with the doctrine of obiter dicta will know their limit in jurisprudence. They are not conclusive authority; they are to be regarded as statements by the way. They arise when a Judge thinks it is desirable to express opinion on some points, though not in issue or necessary to the case before him; this makes obiter dicta not to have binding effect or weight on the case.”
It is to be noted, that the doctrine of Judicial precedent is rendered prostrate where no such distinction has been done. This is because, it is the ratio of a Case as rendered by a Superior Court on similar facts that remains binding on Lower Courts. Where this is properly done, then the Utility of Case Law in the expeditions determination of cases is enhanced See; ADO V. STATE (2017) 4 SC (Pt II) 96 @ III page 20 -25 and also 112 Para 5
”My lords, the utility of precedents or the application of the doctrine of stare-decisis in the administration of justice cannot be over-emphasized. Muhammed, JSC; in ADO V. STATE (2017) 4 SC (Pt II) 96 @ III page 20 -25. Under the doctrine, decisions of superior courts are binding on inferior courts. Thus, in the hierarchical system of courts we operate in this country, the decision of the Supreme Court is binding on all other courts. See Suleiman v. C.O. P (2008) 2-3 S.C. (Pt. 1) 185 and Abacha v. Fawehinmi (2000) 4 S.C (Pt. II) 1.
Cases cannot be authorities for what they did not decide. A decided case furnishes a basis for the determination of a later case only if the facts or issues in the subsequent case are similar to those in the earlier case. Thus a lower court would not be bound to follow decisions of superior courts cited before it which decision were not informed by similar facts or issues the lower court subsequently confronts. See Tejumade A. Clement & anor v. Bridget J. Iwuanyawu & anor (1989) 4 S.C. (Pt II) 89 Babatunde and Anor v. Olatunji and Anor. (200) 2. S.C. 9” – Per – Muhammad, JSC;
Counsel should spare no effort in ensuring that he does not elevate an opinion rendered obiter to the status of a ratio. This is because the consequence can be grave and devastating to both Litigants and Counsel. See the case of COLLINS OBIH v. SAM MBAKWE (1984) 1 S.C 246, heavily relied upon by the appellant in BUHARI & ORS. v. OBASANJO & ORS. (2003) 11 S.C. 74 @ 82 – 84 Para 40 –50 in pressing for orders of injunction to restrain the swearing-in of the President-Elect whose election was being challenged. It turned out that the passage at pages 254-255 Para 15 – 35 of COLLINS OBI V. MBAKWE (supra) Per OBASEKI, JSC; (as he then was) was a mere obiter.
It is important to bear it in mind, that a case is only authority for what it actually decided;
“Thus, it is very important for counsel to bear in mind always, that a case is only authority for what is actually decided. In other words, it is only the “ratio decidendi” of Supreme Court judgment that binds the court and the lower courts, and not “obiter dicta” in concurring judgments. (See for example Odiase & Anor v. Agho & Ors. (1972) 3 S. C. (Reprint) 69. – Per Kutigi, JSC. (As he then was), in OBASANJO v. YUSUF (2004) 5 S.C. (Pt. 1) 27 at 47 -48 Paras. 35 see also SULEIMAN ANOR. V. C. O. P PLATEAU STATE (2008) 2- 3 S.C (Pt 1) 185 at 214 – 216 Para. 35 -20”
See also: ADEGOKE MOTORS LTD V. ADESANYA (1989) 5 S.C. 113 @ 130 – 131 5-15
- USE OF HEADNOTES:
Head notes in Law Reports are only helpful if the Editor has done a good job in crafting it, otherwise Counsel may be mislead. It therefore, behoves Counsel and the Court to be on the lookout for misleading or incorrect Head notes.
No wonder, the Supreme Court in ENGINEERING ENT. v. A.G. KADUNA (1987) 5 S.C 20 @ Page 79 Para. 30, Per Belgore, JSC (As he then was), Sounded a note of warning thus:
“The editorial heading in Law Reports could be misleading as to the context of the judgment reported and courts must be extra careful in relying on such headings before verifying the context”.
- LEADING JUDGMENTS AND CONCURRING JUDGMENTS:
Counsel and the Court, must appreciate the place of leading judgments vis-a-vis concurring and dissenting judgments in appellate decisions. It is the leading Judgment that is in Legal circles, regarded as the Judgment of the Court, being representative of consensus of opinion of the entire panel that read the Judgment, where the decision is unanimous or at least majority thereof as the Case may be – see BUHARI & ORS V. OBASANJO & ORS (2003) 11 SC 74 @ 82 – 84 Page 40 – 50. This is not to say that contributory Judgments have no value, given that it is a constitutional requirement that each Justice renders his opinion in every case he hears.
- IN APPROPRIATE OR MISLEADING CITATIONS – e.g CITING COURT OF APPEAL JUDGMENTS AS SUPREME COURT JUDGMENTS:
There is now an emerging trend especially with the increasing use of electronic law reporting whereby counsel cite Judgments of lower Courts, pretending them to be Judgments of the Supreme Court. Nothing can be more confusing and damaging to the doctrine of Judicial precedent. See: – ARAKA V. EJEUGU (1999) 2 NWLR (PT 589) 107 @ 118 -119 pages H – A (C A) Per SALAMI, J.C.A (as he then was) at pages 118 -119, paras. H – A:
“In the respondent’s brief, the case of Adedoyin v. Adedoyin (supra) cited was described as a decision of the Supreme Court. I am unable to lay my hands on a Supreme Court decision going by that description. The judgment answering to that description was delivered by Akinkugbe, J. (as he then was) in the High Court, Western Nigeria on June 15, 1965. Learned counsel are implored to exercise patience in their citation of authorities in this court.”
See: NNEJI & 3 ORS V CHUKWU & 7ORS (1988) 6 SC 224 @ 247 – 248 para 20-10
I make bold to say, that where counsel assist the Court through the correct application of case law, not only do we help to expedite the early determination of cases, we also help our practice because as decided in the case of HIRAT ADERINSOLA BALOGUN v. THE NATIONAL BANK OF NIGERIA LTD. (1978) 3 SC. (reprint) 111 a solicitor in practice is not in the same category as a “trader”, even though he is one “in business” and for that matter “commercial business”. In other words, while we as Legal Practitioners are in “Commercial business” we are not in the category of “traders “and should not practice as if we are. Afterall to whom much is given, much is expected.
One perhaps, would be correct to assume, that virtually every lawyer gathered in this hall is “a solicitor in practice” engaged in a way in “commercial business” for reward. But how much of understanding have we shown in managing ourselves, our business and expected Leadership role in the society?
Looked at from whatever perspective, delay in the disposal of cases, cannot be business like; nor in the interest of Justice. Except perhaps for lawyers who allow themselves to be maintained by clients/ litigants based on the number of appearances in Court. Avoidable repeated Court appearances in a given case, makes no business sense. Filing and pursuing cases that obviously by Law, particularly Case law, stand no chance, does the profession no good and belittles our calling and learning. To continue to seek the postponement of the hearing of cases and therefore prevent their early determination, for no genuine reason, than lack of knowledge does no good to our profession, nor the cause of justice.
If we, as Lawyers over time remind ourselves, of the pronouncement of the Supreme Court in BALOGUN’S case (supra) and become business like in the handling of our briefs, perhaps this trend of avoidable delays that has bedeviled the administration of Justice in Nigeria would be alleviated.
The challenge for us therefore, is that we should begin to seriously explore more practical ways by which we can safely deploy case law to expedite the early determination of cases.
One of the class of cases that get really prolonged in court, are Land matters. Yet the highest form of any claim a party may make on a piece of Land is claim to OWNERSHIP/ TITLE. The Land Use Act which came into effect on 29th march, 1978 has even whittled down such claims to being entitled to a Statutory or Customary Right of Occupancy – See: KASALI V LAWAL (1986) 3 NWLR (Pt 28) 305 @ 307 C.A. Mean while as far back as Friday 8th October, 1976; (i.e. forty one (41) years ago) the Supreme Court of Nigeria in the case of IDUNDUN & 6 ORS. v. OKUMAGBA (1976) 9-10 S.C. (Reprint) 140 at 154-155. para. 5-40, put it beyond doubt, that there are only five established ways for proving ownership of land. No other ground has been added since then, so basically the law in that regard has remained stable. These established grounds are:
“Firstly, ownership of land may be proved by traditional…
Secondly, ownership of land may be proved by production of documents of title which must, of course be duly authenticated in the sense that their due execution must be proved, unless they are produced from proper custody in circumstances giving rise to the presumption in favour of due execution in the case of documents twenty years old or more at the date of the contract (see section 129 of the Evidence Act and Johnson v. Lawanson (1971) 1 All NLR p.56). .
Thirdly, acts of the person (or persons) claiming the land such as selling, leasing or renting out all or part of the land, or farming on it or on a portion of it, are also evidence of ownership, provided the acts extend over a sufficient length of time and are numerous and positive enough as to warrant the inference that the person is the true owner (see Ekpo v. Ita NLR p.68).
Fourthly, acts of long possession and enjoyment of the land may also be prima facie evidence of ownership of the particular piece or quantity of land with reference to which such acts are done (see Section 45 of the Evidence Act, Cap. 62). Such acts of long possession, in a claim of declaration of title (as distinct from a claim for trespass? are really a weapon more of defence than of offence; moreover under Section 145 of the Evidence Act, while possession may raise a presumption of ownership, it does not do more and cannot stand when another proves a good title (see DaCosta v. Ikomi (1968) 1 All NLR 394 at page 398).
Finally, proof of possession of connected or adjacent land, in circumstances rendering it probable that the owner of such connected or adjacent land would, in addition, be the owner of the land in dispute, may also rank as a means of proving ownership of the land in dispute (see Section 45 of the Evidence Act, Cap. 62).” (Underlining supplied)
The above, no doubt are clear statements of the law and guidelines that can be honestly and professionally applied by business like practitioners in advising their clients, over such claims. Indeed every serious Lawyer and the court with due respect, ought to identify on the pleadings whether a Claimant relies on one or more of such grounds or not. Once done, evidence can then be limited to only such ground or grounds as the case may be and where the averments in the pleading does not evince any of the grounds, I believe such a claim for title, should not be on the cause list, beyond the pre-trial conference period.
This brings one to the importance of pleadings and the valuable insight that Case Law offers – See: SOGUNRO & 5 ORS V. YEKU & 2 ORS (2017) 2 S.C. (Pt. II) 1 @ 14 – 15 Para. 5 – 30
“Once pleadings are ordered, filed and exchanged, the parties, and indeed the courts, are bound by them. The implication, therefore, is that evidence must be led in accordance with the averments therein. That explains the impregnable prescription that evidence which is not in conformity with the pleadings go to no issue, Okoko v. Dakolo (2006) 7 S.C. (Pt. Ill) 84.
This ubiquitous principle in the vocabulary of Pleadings applies with equal force whether the pleadings and evidence are those of the Plaintiff or the Defendants, Akinloye v. Eyiyola (1968) NMLR 92, 95; Alii v. Alesinloye (2000) 4 S.C. (Pt. I) 111; Obulor v. Oboro (2001) 4 S.C. (Pt. 1) 77. As this court had, once, explained, the rationale behind this principle of law is that by our adversary system of civil procedure in the high court, facts are first erected on the pleadings before the trial of the case. This is to foreclose the likelihood of springing surprises at the trial and to circumscribe the compass or breadth of divergences. This inviolable or sacrosanct rule is only subject to the fairly liberal rules appertaining to the amendment of pleadings.
Thus, if and when parties join issues in the settled pleadings; amend and join issues on their amended pleadings, thenceforth, they are bound by them and so they cannot orbit outside the compass of the issues so joined in search of more luxuriant facts, Okoko v. Dakolo (supra); Eze and Ors. v. Atasie and Ors. (2000) 6 S.C. (Pt. I) 214; Emegokwe v. Okadigbo (1973)’ 4 S.C. 113;”
It is equally trite that evidence is not to be pleaded but material facts – See: PURIFICATION TECHNIQUE & 3 ORS V. JUBRIL & 9 ORS (2012) 6 S.C. (Pt. II) 1 @ 47.
Case Law, of which the above is a recent example, seems to raise an ever present banner of caution to counsel and the Court regarding the importance and place of pleadings in proceedings. Where due attention is not paid to this warning, before the Originating processes are filed in court, delays will almost always attend the proceedings. Of course due to human nature issues do arise in the course of proceedings that may necessitate amendments of pleadings. Again, in this regard Case Law is not silent – see; EZE V. ENE & ANOR (2017) 2 – 3 S C (Pt. III) 154 @ 176 – 178 Page 30 – 50 Per Ogunbiyi, JSC;
“The duty of a court as an arbiter is to act for the benefit of all parties. It follows therefore that an amendment which will serve the interest of the justice of the case is beneficial to all parties and should be allowed and granted. The caveat however is also true that if an amendment is sought either in bad faith, for purpose of undermining the case of the opponent or is simply done with the intention of giving the party seeking same to have a second bite at the cherry, then such should not be allowed.
The general principle of law is well settled that an amendment of pleadings can be made at any time, before judgment. However, and notwithstanding the wide latitude, the intention not to leave the consideration open -ended and without proper control so as to create a flood gate of an abuse of discretion. The case of lmonikhe v. A.G. Bendel State (1992) 7 S.C. (Pt. V) 34 at 52-53 per Nnaemeka-Agu, JSC.,(as he then was) is relevant wherein this court said:-
“Although, by the rules, an amendment to the pleadings can be made at any stage of the proceedings, different considerations apply depending on whether the amendment is being sought before or after the close of the evidence by the parties. Before the close of evidence, such amendments are allowed to make such evidence as may be called admissible, as evidence on an issue which
was not pleaded or a claim not on the record is strictly inadmissible. But once the calling of evidence has been concluded, any amendment of the pleading or claim can be justified or allowed only on the premise that evidence in support of it is already on record, so that it is necessary and in the interest of justice to allow the amendment in order to make the pleadings or the claim accord with evidence already on record. The rationale of it is that such amendment should be allowed to enable the court to use the evidence already on record to settle the real issue in controversy between the parties.”
Parties are enjoined and must beware that instituting an action must first require great consideration and caution. This should give a cause for careful and proper planning. (Underlining Supplied)
See also: ADETUTU V. ADEROHUNMU (1984) 6 S.C. 92 @ 99
Now with such clear guidelines, one cannot but wonder why we spend so much valuable time, in some cases years contending over Applications to amend pleadings? It is unfortunate, that the Court Rules which in some states permitted counsel to consent to amendments of pleadings without the necessity of formal Applications in Court were jettisoned. It was only where counsel withheld consent that such Applications were taken in open Court. I believe it is time, to restore such provisions, which apparently recognized that counsel, should be able to determine such matters based on Case Law and the Rules of Court.
It should be pointed out as well, that sometimes the problem of delay arises from the courts, because of failure to be guided by case law. Where counsel and the Court ignore the input of Case Law, the effect can be devastating to the cause of Justice and Justice Administration generally.-See DALHATU V. TURAKI & 5 ORS (2003) 7 S.C. 1
A good example having regards to Judgment writing, is the Case of ENIGWE & 7 ORS V. AKAIGWE & 5 ORS (1992) 2 S.C. (Pt. I) 196 wherein the Supreme Court based
on the non-discernable Judgment of the Trial Court ordered a non-suit on the grounds that “it was impossible for this court to determine on which side the scale of Justice should tilt”.
This was unfortunately after Twenty Two (22) years of the parties being in court! What a waste of time, energy and resources. See: ODOFIN V. MOGAJI & ORS (1978) 4 S.C. (Reprint) 53 (decided 28th April, 1978) where the Supreme Court gave clear guiding principles on Judgment writing. Given the volume of binding judicial authorities on Judgment writing today, I venture to suggest with due respect , that the kind of blunder that occasioned the Supreme Court ordering rehearing de novo in OJOGBUE V. NNUBIA (1972) 6 S.C. (Reprint ) 127 @ 132 Page 15 – 35 should be rare in our Judicial Administration.See: ALIBO&2Ors v. OKUSIN & Ors (2010) 3-5 SC ( pt 1) 41 @ 64-66 paras 25-35 and USIOBAIFO v. USIOBAIFO (2005) 1 SC (pt 11) 60 @77 paras 20-40 on qualities of a good judgment .
A Lawyer in criminal law practice for instance, should know that it is idle to continue to argue, that on no account should an accused be convicted based on circumstantial evidence -See Adie v. The State (1980) 1-2 (Reprint) at 83, para. 5-15. Neither is it helpful to continue to press the point that a Confessional Statement, even when free and voluntary cannot ground conviction – See EDHIGHERE V. THE STATE (1996) & NWLR (Pt 464) 1 @ 10 S.C.; OKANLAWON V. STATE (2015) 6-7 S.C (Pt.1) 115 @ 157
In the same manner, it serves no useful purpose applying for the conduct of trial- within-a-trial where an accused denies making a statement. See; NWANGBOMU V. THE STATE (1994) 2 NWLR (Pt 327) 380 at 392 S.C; STATE V. GWANGWAN (2015) 2-3 S.C 111 @131 -133 as opposed to contending that he made it under duress. See; IGAGO V. THE STATE (1999) 10 – 12 S.C 84 @ 104 PARA 5 – 15 The two circumstances differ. There is no harm too in knowing when certain defences will just not wash e.g. insanity or intoxication- see Ekanu v. The State (1980) 3-4 S.C. (Reprint) 1 at 10 para. 15-30. These are without prejudice to other issues that may be legitimately urged on the court on behalf of the accused.
Of recent, the Supreme Court expressed its apparent disgust by what I may call stubborn refusal and/or neglect to be guided by decided cases when in APC & 2 ORS V. KARFI & 2 ORS (2017) 3-4 S.C. 153 @ 176- 177, 182 – 183 Per Nweze, JSC held thus;
“Counsel for the Appellants and the 1st Respondent praying in aid Section 246 (3) of the 1999 Constitution (as amended) contended, and rightly too, that decisions of the lower court on appeals from the National and State House of Assembly Tribunal are final. This has long been settled.
Indeed, on March 10, 2017, this courtexpressed its disgust at the incessant attempts bycounsel to irritate it with the question whetherappeals could lie against decisions of the Courtof Appeal on election matters from the Nationaland State Assembly Election Tribunal. That was in Abubakar & Anor. v. Usman & Ors. (2017) 3-4 S.C. 1. First, this court; (per Nweze, JSC) pointed out that it has:
… dealt with the meaning and breadth this Section (246 (3) of the 1999 Constitution) on numerous occasions. Only a handful of these decisions would be cited in this judgment, Qpara & Anor v. Amadi (2013) 6-7 SC (Pt. II) 49; Madumere v. Okwara (2013) 6-7 SC (Pt. II) 95; Okadigbo v.Emeka & Ors. (2012) 1 S.C. (Pt. IV) Emordi v. lgeke (2011) 4 SC (Pt. II)107, 145; Salik v. ldris (2014) 5 S.C.(Pt. II/) 45; Dangana v. Usman (2012) 2S.C. (Pt. Ill) 103; Onuaguluchi v. Ndu & Ors. (2001) 3 S.C. 48; Salik v. ldris(2014) 5 S.C. (Pt. II) 45; Jegede v.Akande (2014) 16 NWLR (Pt 1432) 43,72.
Instructively, in Dangana & Anor. v. Usman & Ors. (2012) 2 S.C. (Pt. Ill) 103 this court dealt with this question…
The Court then concluded;
“In all, there is no merit in this application. I, therefore, enter an order dismissing it with costs assessed and fixed at N500, 000 to be paid personally by counsel for the Applicant for this ill -advised forensic trip to this rare altitude even in the face of the avalanche of decisions of this court that the decision of the Court of Appeal in such matters is final”( underlining supplied )
In conclusion, what I have tried to do by the above brief Address, which is not exhaustive, is to provoke our thoughts, on the subject of overcoming delays that often bedevil court proceedings, through appropriate use of case law. The subject of delay in proceedings is not new with it’s debilitating effect on the litigant, counsel and the society. Some have said and perhaps rightly so, that delay is one major contributory factor to poverty in the profession and lack of experience by juniors! Yet without well grounded juniors in the art of Litigation, the future of the profession and indeed quality of the bench in the future, becomes suspect. I believe that by appropriate use of case law, we may make some progress in ameliorating the situation. Human nature can be complex and tricky. Indeed litigation in particular, can be tricky and sometimes ‘justice rushed can be justice crushed’. Besides, there is hardly a’ one size fit all’ solution to legal issues, because after all ‘cases are like faces that sometimes look alike but are hardly the same.’ Notwithstanding, as learned gentlemen, it serves no useful purpose taking coal to Newcastle over and over again, on principles that are settled ( as it happened in APC & 2 Ors v. KARFI & 2 Ors -(Supra) when we can use our best professional endeavors to help resolve matters more quickly, by offering appropriate advise to our clients and assisting the court with helpful submissions. With appropriate use of Case Law, we can help free the Court’s Docket of causes that ought not linger. I believe this can be done, without compromising the essence of justice. The time to bring to bear our learning and respected status as gentlemen, with a deep understanding of the law is now , so that we can fare better and the law can better work , for the good of our society .
* ADDRESS DELIVERED BY LAYI BABATUNDE, SAN; FCTI; EDITOR IN CHIEF, JUDGMENTS OF THE SUPREME COURT OF NIGERIA (S.C. REPORTS) AT THE 2017 ANNUAL LAW WEEK OF THE NIGERIA BAR ASSOCIATION, LAGOS BRANCH HELD MAY 24-27 2017.