Daily Law Tips (Tip 712) by Onyekachi Umah, Esq., LL.M,
ACIArb(UK)
![image](/2020/12/legacy1.jpg")
![image](/2020/10/lawreport.jpg")
Introduction:
People are often encouraged to make a “WILL” before death to ensure
their property are well disposed and that their loved ones are
adequately protected. This is built on the assumption that a “WILL”
is a sacred wish of a dead person that must be respected by all
persons. Ironically, there are limitations that make this
assumption wrong. Imagine a limitation that does not stop a living
person from disposing his property but limits that same person from
disposing the same property through a “WILL”. Somehow, the
limitations can even invalidate a well written and video recorded
“WILL”. The limitations allow courts in Nigeria to reject a “WILL”
and to dispose a property contrary to the contents of the
“WILL”.
![image](/2020/10/NWLRland.jpg")
This work focuses on the customary limitation placed by several
laws on “Will”, that limits disposal of property that are under
native law and custom (customary ownership). It highlights the
states in Nigeria that are affected as well as states that are free
from such limitations.
History Of Laws On “WILL” According to the Supreme
Court:
There is no better place to obtain genuine facts about Nigerian
laws and history, than from the judgments of the Supreme Court of
Nigeria. On the history of laws on “WILL”, hear the Justice
MOHAMMED BELLO of the Supreme Court of Nigeria in the case of
IDEHEN & ORS v. IDEHEN & ORS (1991) LPELR-1416(SC);
”During the colonial era, the Wills Act 1837 of England which
empowered a testator to dispose of his properties – real and
personal – as he pleased, applied as an Act of general application
throughout Nigeria. At that time, any native law and custom which
was incompatible with the Wills Act was unenforceable and the
provisions of the Act prevailed. A testator had the right to
dispose of his properties, real and personal irrespective of any
encumbrance of native law and custom on the property: Adesubokan v.
Yunusa (1971) 1 All N.L.R. 225.” Afterwards, each region (Western,
Mid-Western, Eastern and Northern regions) made their own laws on
“WILL”. Later when states were created in the regions, the states
also made their own laws on “WILL” which are often replicas of the
laws on “WILL” in their regions.
Present Status of Laws on “WILL”:
Presently, Nigeria does not have a national (federal) law on
“Will”. Rather regions and states in Nigeria have separate laws on
“WILL” and as expected, this has unequal effects across Nigeria.
For example, in the Northern part of Nigeria, the law on “WILL” is
the English Wills Act of 1937. As as such, many states in that
region have enacted their state laws on “WILL”, which are mere
copies of the English Wills Act of 1937 but with unique law titles
and citations. By the English Wills Act of 1937, in all the states
in the Northern part of Nigeria, where it operates, people are free
to make a “WILL” over any property. So, there is really no
limitation on what can be shared through a “WILL” in the states in
Northern Nigeria.
Unlike in criminal law, the English Wills Act of 1937 is a law
that both Northern part of Nigeria and the Eastern part of Nigeria
have in common. Yes, the states in the eastern region of Nigeria
have replicated the English Wills Act of 1937 as their state laws
on “WILL”, with unique law titles and citations. As expected,
persons in eastern Nigeria have no limitation on what can be
disposed or shared through a “WILL”.
This one-dimensional law, changes the moment one lands into any
of the states in the Western part of Nigeria. This part of Nigeria
is predominately habited by the Yoruba people of Nigeria, as the
Igbo people of Nigeria live majorly in the eastern part of Nigeria
and the Hausa/Fulani people of Nigeria dominate the Northern part
of Nigeria. Always note that, Nigeria has about 371 tribes.
In the Western part of Nigeria (including the Mid-Western part
of Nigeria), the operational law of “WILL” is the Wills Law of
1959. So, many states in the Western part of Nigeria replicated the
Wills Law of 1959 as their state laws on “WILL” but with unique law
titles and citations. Unlike in the Northern part of Nigeria and
the Eastern part of Nigeria, the laws on “WILL” in the Western part
of Nigeria, placed a limitation on the origin of property that any
person can dispose via “WILL”. The limitation is that in Western
Nigeria and Mid-Western Nigeria, a person can give out his property
through a “WILL” but cannot give out any of his property that is
bound by native law and customs (Customary Law).
Customary Limitation on “WILL” (“You Cannot Give What
You Don’t Have Principle”)
Customary law, customarily owned property and customary ownership
cannot be affected by a “WILL” in the states in the Western part of
Nigeria and the Mid-Western part of Nigeria. The Supreme Court of
Nigeria has through a plethora of judgments validated this position
of the laws of states in those regions of Nigeria. The popular
Benin tradition that mandates the first son of a man to inherit his
father’s main residential property (igi-ogbe), irrespective of his
father’s “WILL”, has given several opportunities to the Supreme
Court of Nigeria, for the Supreme Court to emphasis that a “WILL”
cannot change, or alter any native law and custom in any community
in the Western or Mid-Western part of Nigeria. Benin Kingdom is in
Edo State, in the Mid-Western region of Nigeria.
It must be mentioned that, few states in the Western part of
Nigeria, have moved on to enact their own unique laws on “Will”,
this includes, Lagos State and Oyo State. In the new unique law on
“WILL” of Lagos State, there is still Customary Law Limitation over
“WILL”. In the law on “WILL” of Oyo State, there is still also a
Customary Law Limitation, plus even an Islamic Law Limitation. So
that, in Oyo State, a property held under customary law are above a
“WILL” and persons that are Muslims are exempted from the law on
“WILL”.
Across Nigeria, there are about 371 tribes with their unique
cultures, native law and customs. One common thing with customs
across Nigeria, is communal life, communal ownership and extended
families. So, by native law and custom, landed property and any
other property owned or bound under native law and custom must be
shared in accordance with the relevant native law and custom. By
this, certain property owned under native law and customs are
arguably not exclusive property of their owners at death and as
such, their owners may not be able to share them via a “WILL”.
After all, one cannot give what one does not have, to avoid being
prosecuted for a criminal case of misrepresentation, stealing,
cheating and conversion.
The above paragraph sums up the logic behind laws on “WILL” in
the states in Western and Mid-Western regions of Nigeria, that
clearly stated that property owned or bound under native law and
custom cannot be affected by a “WILL”. Imagine, the customary
relevance of the ancestral land of a family, which is often
inherited by only the children of the family, now being shared by a
father through a “WILL” to a total stranger.
This logic has received judicial blessings from “… several
judgments from the Supreme Court of Nigeria, upholding the place of
customary laws over certain property and how such property cannot
be under a “WILL”. This is seen in “several superior Courts of
record including this Court and the apex Court in the cases of
Ogiamien v. Ogiamien (1967) NMLR 382; Idehen v. Idehen (1991) 6
NWLR (Pt. 198) 382 (S.C.); Agidigbi v. Agidigbi (1992) 2 NWLR (Pt.
221) 98; Lawal-Osula v. Lawal-Osula (1993) 2 NWLR (PT 274) 158
(S.C.) amongst a host of others. …. What makes the house of a
deceased Bini man Igiogbe under Bini native law and custom, which
he cannot even give out by Will to anyone but his eldest surviving
son ….”, quoting Justice BOLOUKUROMO MOSES UGO of the Court of
Appeal in the case of ISU v. ABASA & ORS (2017) LPELR-42014(CA)
Conclusion:
“WILL” is regulated by law and where the law that regulates “WILL”
makes customary law to be above “WILL”, then so be it. In the
states in the Western and Mid-Western States in Nigeria, their laws
on “WILL” clearly prohibits any person from making a “WILL” over
any property that is bound under customary law. This clearly
protects their rich cultural heritages and customs, however,
unfortunately higher and above the clear intentions of a maker of a
“WILL”.
It has been argued that Customary Limitation which is created by
laws on “WILL” is contrary to natural justice and that it
contradicts the essence of “WILL” and rather promotes the sharing
of property of dead persons contrary to their wishes. This is
clearly seen in the case of Osula Vs Osula, where the maker of a
“WILL” clearly stated that he does not want his will to be changed
by any person and that he does not want the customs of Benin
Kingdom to apply to his “WILL”, however, the Supreme Court of
Nigeria forcefully applied the native law and customs of Benin
Kingdom on the “WILL” and modified the “WILL” over property that
where bound by native law and custom.
Many are clamoring for Customary Law Limitation on “WILL” in
states of the Western and Mid-Western region of Nigeria to be
expunged, in order to promote respect for “WILL” and wishes of the
dead. It is not a crime or a fault of any person to be off any
particular custom and culture, so people should be allowed to
denounce their customs, even at death. I support this call and do
condemn the cowardly acts of the laws of “WILL” in the concerned
states, that clearly robes and steals from dead persons, just to
satisfy often lazy and ill-mannered beneficiaries contrary to their
true intentions of their dead benefactors.
My authorities, are:
1. Sections 1, 2, 3, 4, 5 and 6 of the Constitution of the Federal
Republic of Nigeria, 1999.
2. Sections 1, 2, 26 and 27 of the Wills Law of Lagos State, 1990
Cap W2 Laws of Lagos State 2004
3. Sections 1, 2, 3, and 4 of the Wills Edict of Oyo State 1990
4. The Judgment of the Supreme Court (on the history of Wills Act
in Nigeria) in the case of IDEHEN & ORS v. IDEHEN & ORS. (1991)
LPELR-1416(SC).
5. The judgment of the Supreme Court of Nigeria (on the superiority
of customary law over “WILL” in Western and Mid-Western regions of
Nigeria) in the case of Osula V Osula (1995) 9 NWLR pt 419 page
259.
6. The judgment of the Court of Appeal (on the superiority of
customary law over “WILL” in Western and Mid-Western regions of
Nigeria) in the case of Court of Appeal in the case of ISU v. ABASA
& ORS (2017) LPELR-42014(CA)
7. Onyekachi Umah, “A “WILL” Without Good Financial Provision For
Family Can Be Cancelled” (LearnNigerianLaws.com, 7 December 2020)
accessed 8 December 2020
8. Onyekachi Umah, “How To Recover Property Of The Dead In Nigeria.
(A Legal Guide On Probate Matters In Nigeria)”
(LearnNigerianLaws.com, 10 March 2016) accessed 5 December 2020
9. Obiora Atuegwu Egwuatu, “Limits Of A Testator On Freedom Of Will
Testament” (nigerianlawguru,) accessed 5 December 2020.
10. Onyekachi Umah, “Requirements Of A Valid/Genuine Will”
(LearnNigerianLaws.com, 13 July 2020) accessed 5 December 2020.
11. Vanguard, “Full List Of All 371 Tribes In Nigeria, States Where
They Originate” (Vanguard Newspaper, 10 May 2017)<
https://www.vanguardngr.com/2017/05/full-list-of-all-371-tribes-in-nigeria-states-where-they-originate/>
accessed 3 December 2020
12. Onyekachi Umah, “Can An Inheritance Under A “Will” Be
Rejected?” (LearnNigerianLaws.com, 6 May 2020) accessed 5 December
2020
13. Onyekachi Umah, “He 4 Facts Courts Must Consider In Evaluating
Expert Opinions On Handwriting And Signatures On Wills”
(LearnNigerianLaws.com, 2 November 2019) accessed 5 December
2020
14. Onyekachi Umah, “Acceptable Age For Making Of Wills In Nigeria”
(LearnNigerianLaws.com, 25 April 2019) accessed 5 December 2020
#SabiLaw
#DailyLawTips
#SabiBusinessLaw
#SabiElectionLaws
#SabiHumanRights
#SabiLawOnBeatFm
#SabiLawLectureSeries
#CriminalJusticeMonday
#SabiLawVideoChallenge
Speak with the writer, ask questions or make inquiries on this
topic or any other via onyekachi.umah@gmail.com,
info@LearnNigerianLaws.com or +2348037665878 (whatsapp).
To receive our free Daily Law Tips, join our free WhatsApp group
via the below link:
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Or our free Telegram group, via the below link:
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To keep up to date on all our free legal awareness projects,
follow us via:
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@LearnNigeriaLaw
Please share this publication for free till it gets to those
that need it most. Save a Nigerian today! NOTE: Sharing, modifying
or publishing this publication without giving credit to Onyekachi
Umah, Esq. and “LearnNigerianLaws.com” is a criminal breach of
copyright and will be prosecuted.
This publication is the writer’s view not a legal advice and
does not create any form of relationship. You may reach the writer
for more information.
Powered by www.LearnNigerianLaws.com {A Free Law Awareness
Program of Sabi Law Foundation, supported by the law firm of
Bezaleel Chambers International (BCI).}
Daily Law Tips (Tip 712) by Onyekachi Umah, Esq., LL.M,
ACIArb(UK)
Introduction:
People are often encouraged to make a “WILL” before death to ensure
their property are well disposed and that their loved ones are
adequately protected. This is built on the assumption that a “WILL”
is a sacred wish of a dead person that must be respected by all
persons. Ironically, there are limitations that make this
assumption wrong. Imagine a limitation that does not stop a living
person from disposing his property but limits that same person from
disposing the same property through a “WILL”. Somehow, the
limitations can even invalidate a well written and video recorded
“WILL”. The limitations allow courts in Nigeria to reject a “WILL”
and to dispose a property contrary to the contents of the
“WILL”.
This work focuses on the customary limitation placed by several
laws on “Will”, that limits disposal of property that are under
native law and custom (customary ownership). It highlights the
states in Nigeria that are affected as well as states that are free
from such limitations.
History Of Laws On “WILL” According to the Supreme
Court:
There is no better place to obtain genuine facts about Nigerian
laws and history, than from the judgments of the Supreme Court of
Nigeria. On the history of laws on “WILL”, hear the Justice
MOHAMMED BELLO of the Supreme Court of Nigeria in the case of
IDEHEN & ORS v. IDEHEN & ORS (1991) LPELR-1416(SC);
”During the colonial era, the Wills Act 1837 of England which
empowered a testator to dispose of his properties – real and
personal – as he pleased, applied as an Act of general application
throughout Nigeria. At that time, any native law and custom which
was incompatible with the Wills Act was unenforceable and the
provisions of the Act prevailed. A testator had the right to
dispose of his properties, real and personal irrespective of any
encumbrance of native law and custom on the property: Adesubokan v.
Yunusa (1971) 1 All N.L.R. 225.” Afterwards, each region (Western,
Mid-Western, Eastern and Northern regions) made their own laws on
“WILL”. Later when states were created in the regions, the states
also made their own laws on “WILL” which are often replicas of the
laws on “WILL” in their regions.
Present Status of Laws on “WILL”:
Presently, Nigeria does not have a national (federal) law on
“Will”. Rather regions and states in Nigeria have separate laws on
“WILL” and as expected, this has unequal effects across Nigeria.
For example, in the Northern part of Nigeria, the law on “WILL” is
the English Wills Act of 1937. As as such, many states in that
region have enacted their state laws on “WILL”, which are mere
copies of the English Wills Act of 1937 but with unique law titles
and citations. By the English Wills Act of 1937, in all the states
in the Northern part of Nigeria, where it operates, people are free
to make a “WILL” over any property. So, there is really no
limitation on what can be shared through a “WILL” in the states in
Northern Nigeria.
Unlike in criminal law, the English Wills Act of 1937 is a law
that both Northern part of Nigeria and the Eastern part of Nigeria
have in common. Yes, the states in the eastern region of Nigeria
have replicated the English Wills Act of 1937 as their state laws
on “WILL”, with unique law titles and citations. As expected,
persons in eastern Nigeria have no limitation on what can be
disposed or shared through a “WILL”.
This one-dimensional law, changes the moment one lands into any
of the states in the Western part of Nigeria. This part of Nigeria
is predominately habited by the Yoruba people of Nigeria, as the
Igbo people of Nigeria live majorly in the eastern part of Nigeria
and the Hausa/Fulani people of Nigeria dominate the Northern part
of Nigeria. Always note that, Nigeria has about 371 tribes.
In the Western part of Nigeria (including the Mid-Western part
of Nigeria), the operational law of “WILL” is the Wills Law of
1959. So, many states in the Western part of Nigeria replicated the
Wills Law of 1959 as their state laws on “WILL” but with unique law
titles and citations. Unlike in the Northern part of Nigeria and
the Eastern part of Nigeria, the laws on “WILL” in the Western part
of Nigeria, placed a limitation on the origin of property that any
person can dispose via “WILL”. The limitation is that in Western
Nigeria and Mid-Western Nigeria, a person can give out his property
through a “WILL” but cannot give out any of his property that is
bound by native law and customs (Customary Law).
Customary Limitation on “WILL” (“You Cannot Give What
You Don’t Have Principle”)
Customary law, customarily owned property and customary ownership
cannot be affected by a “WILL” in the states in the Western part of
Nigeria and the Mid-Western part of Nigeria. The Supreme Court of
Nigeria has through a plethora of judgments validated this position
of the laws of states in those regions of Nigeria. The popular
Benin tradition that mandates the first son of a man to inherit his
father’s main residential property (igi-ogbe), irrespective of his
father’s “WILL”, has given several opportunities to the Supreme
Court of Nigeria, for the Supreme Court to emphasis that a “WILL”
cannot change, or alter any native law and custom in any community
in the Western or Mid-Western part of Nigeria. Benin Kingdom is in
Edo State, in the Mid-Western region of Nigeria.
It must be mentioned that, few states in the Western part of
Nigeria, have moved on to enact their own unique laws on “Will”,
this includes, Lagos State and Oyo State. In the new unique law on
“WILL” of Lagos State, there is still Customary Law Limitation over
“WILL”. In the law on “WILL” of Oyo State, there is still also a
Customary Law Limitation, plus even an Islamic Law Limitation. So
that, in Oyo State, a property held under customary law are above a
“WILL” and persons that are Muslims are exempted from the law on
“WILL”.
Across Nigeria, there are about 371 tribes with their unique
cultures, native law and customs. One common thing with customs
across Nigeria, is communal life, communal ownership and extended
families. So, by native law and custom, landed property and any
other property owned or bound under native law and custom must be
shared in accordance with the relevant native law and custom. By
this, certain property owned under native law and customs are
arguably not exclusive property of their owners at death and as
such, their owners may not be able to share them via a “WILL”.
After all, one cannot give what one does not have, to avoid being
prosecuted for a criminal case of misrepresentation, stealing,
cheating and conversion.
The above paragraph sums up the logic behind laws on “WILL” in
the states in Western and Mid-Western regions of Nigeria, that
clearly stated that property owned or bound under native law and
custom cannot be affected by a “WILL”. Imagine, the customary
relevance of the ancestral land of a family, which is often
inherited by only the children of the family, now being shared by a
father through a “WILL” to a total stranger.
This logic has received judicial blessings from “… several
judgments from the Supreme Court of Nigeria, upholding the place of
customary laws over certain property and how such property cannot
be under a “WILL”. This is seen in “several superior Courts of
record including this Court and the apex Court in the cases of
Ogiamien v. Ogiamien (1967) NMLR 382; Idehen v. Idehen (1991) 6
NWLR (Pt. 198) 382 (S.C.); Agidigbi v. Agidigbi (1992) 2 NWLR (Pt.
221) 98; Lawal-Osula v. Lawal-Osula (1993) 2 NWLR (PT 274) 158
(S.C.) amongst a host of others. …. What makes the house of a
deceased Bini man Igiogbe under Bini native law and custom, which
he cannot even give out by Will to anyone but his eldest surviving
son ….”, quoting Justice BOLOUKUROMO MOSES UGO of the Court of
Appeal in the case of ISU v. ABASA & ORS (2017) LPELR-42014(CA)
Conclusion:
“WILL” is regulated by law and where the law that regulates “WILL”
makes customary law to be above “WILL”, then so be it. In the
states in the Western and Mid-Western States in Nigeria, their laws
on “WILL” clearly prohibits any person from making a “WILL” over
any property that is bound under customary law. This clearly
protects their rich cultural heritages and customs, however,
unfortunately higher and above the clear intentions of a maker of a
“WILL”.
It has been argued that Customary Limitation which is created by
laws on “WILL” is contrary to natural justice and that it
contradicts the essence of “WILL” and rather promotes the sharing
of property of dead persons contrary to their wishes. This is
clearly seen in the case of Osula Vs Osula, where the maker of a
“WILL” clearly stated that he does not want his will to be changed
by any person and that he does not want the customs of Benin
Kingdom to apply to his “WILL”, however, the Supreme Court of
Nigeria forcefully applied the native law and customs of Benin
Kingdom on the “WILL” and modified the “WILL” over property that
where bound by native law and custom.
Many are clamoring for Customary Law Limitation on “WILL” in
states of the Western and Mid-Western region of Nigeria to be
expunged, in order to promote respect for “WILL” and wishes of the
dead. It is not a crime or a fault of any person to be off any
particular custom and culture, so people should be allowed to
denounce their customs, even at death. I support this call and do
condemn the cowardly acts of the laws of “WILL” in the concerned
states, that clearly robes and steals from dead persons, just to
satisfy often lazy and ill-mannered beneficiaries contrary to their
true intentions of their dead benefactors.
My authorities, are:
1. Sections 1, 2, 3, 4, 5 and 6 of the Constitution of the Federal
Republic of Nigeria, 1999.
2. Sections 1, 2, 26 and 27 of the Wills Law of Lagos State, 1990
Cap W2 Laws of Lagos State 2004
3. Sections 1, 2, 3, and 4 of the Wills Edict of Oyo State 1990
4. The Judgment of the Supreme Court (on the history of Wills Act
in Nigeria) in the case of IDEHEN & ORS v. IDEHEN & ORS. (1991)
LPELR-1416(SC).
5. The judgment of the Supreme Court of Nigeria (on the superiority
of customary law over “WILL” in Western and Mid-Western regions of
Nigeria) in the case of Osula V Osula (1995) 9 NWLR pt 419 page
259.
6. The judgment of the Court of Appeal (on the superiority of
customary law over “WILL” in Western and Mid-Western regions of
Nigeria) in the case of Court of Appeal in the case of ISU v. ABASA
& ORS (2017) LPELR-42014(CA)
7. Onyekachi Umah, “A “WILL” Without Good Financial Provision For
Family Can Be Cancelled” (LearnNigerianLaws.com, 7 December 2020)
accessed 8 December 2020
8. Onyekachi Umah, “How To Recover Property Of The Dead In Nigeria.
(A Legal Guide On Probate Matters In Nigeria)”
(LearnNigerianLaws.com, 10 March 2016) accessed 5 December 2020
9. Obiora Atuegwu Egwuatu, “Limits Of A Testator On Freedom Of Will
Testament” (nigerianlawguru,) accessed 5 December 2020.
10. Onyekachi Umah, “Requirements Of A Valid/Genuine Will”
(LearnNigerianLaws.com, 13 July 2020) accessed 5 December 2020.
11. Vanguard, “Full List Of All 371 Tribes In Nigeria, States Where
They Originate” (Vanguard Newspaper, 10 May 2017)<
https://www.vanguardngr.com/2017/05/full-list-of-all-371-tribes-in-nigeria-states-where-they-originate/>
accessed 3 December 2020
12. Onyekachi Umah, “Can An Inheritance Under A “Will” Be
Rejected?” (LearnNigerianLaws.com, 6 May 2020) accessed 5 December
2020
13. Onyekachi Umah, “He 4 Facts Courts Must Consider In Evaluating
Expert Opinions On Handwriting And Signatures On Wills”
(LearnNigerianLaws.com, 2 November 2019) accessed 5 December
2020
14. Onyekachi Umah, “Acceptable Age For Making Of Wills In Nigeria”
(LearnNigerianLaws.com, 25 April 2019) accessed 5 December 2020
#SabiLaw
#DailyLawTips
#SabiBusinessLaw
#SabiElectionLaws
#SabiHumanRights
#SabiLawOnBeatFm
#SabiLawLectureSeries
#CriminalJusticeMonday
#SabiLawVideoChallenge
Speak with the writer, ask questions or make inquiries on this
topic or any other via onyekachi.umah@gmail.com,
info@LearnNigerianLaws.com or +2348037665878 (whatsapp).
To receive our free Daily Law Tips, join our free WhatsApp group
via the below link:
https://chat.whatsapp.com/Drc0UK3ba10KnuR8zuPMwl
Or our free Telegram group, via the below link:
https://t.me/LearnNigerianLaws
To keep up to date on all our free legal awareness projects,
follow us via:
Facebook Page:@LearnNigerianLaws,
Instagram: @LearnNigerianLaws and Twitter:
@LearnNigeriaLaw
Please share this publication for free till it gets to those
that need it most. Save a Nigerian today! NOTE: Sharing, modifying
or publishing this publication without giving credit to Onyekachi
Umah, Esq. and “LearnNigerianLaws.com” is a criminal breach of
copyright and will be prosecuted.
This publication is the writer’s view not a legal advice and
does not create any form of relationship. You may reach the writer
for more information.
Powered by www.LearnNigerianLaws.com {A Free Law Awareness
Program of Sabi Law Foundation, supported by the law firm of
Bezaleel Chambers International (BCI).}