Daily Law Tips (Tip 776) by Onyekachi Umah, Esq., LL.M,
ACIArb(UK)
![image](/2020/10/lawreport.jpg")
Introduction:
Justice is not free, as litigants must pay court filing fee to
courts, for their cases to be attended to, by magistrates and
judges. Over the years the costs of filing cases in courts have
increased with every new rules of courts. In a judicial system that
plans to generate funds from filing fees paid into courts, failure
to pay filing fees and inadequate filing fees have varying effects
and may jeopardize justice. Hence, understating the distinction
between non-payment and inadequate payment of filing fees is
important.
![image](/2021/01/payne-alex.jpg")
Filling fees and access to justice:
The courts in Nigeria are expected to establish and charge filing
fees from disputants before accepting their cases. Government and
government agencies do not pay filing fees. The fees are often
expensive, as such they discourage disputants from claiming high
damages, since high damages translate to high filing fees. The fees
at times discourage disputants from accessing the courts, coupled
with the complexity of procedures of the courts and delays in
courts.
Often, stakeholders argue that the court filing fees (court
cost) are set to discourage frivolous cases. However, the costs are
not justifiable, since truly government provides budget. By the
way, frivolous cases can easily be discouraged by having judges
order punitive fees against concerned disputants and their lawyers.
Also, for the lawyers, courts should report them to their
professional body (the Nigerian Bar Association and others). Court
filing fees (court cost) are increasing and they are obviously
decreasing access to justice among indigent Nigerians and thereby
encouraging self-help.
Non-Payment Vs. Inadequate Payment of Filing Fees and
their Effects:
This section focuses on clarifying the distinction between
non-payment of filing fees from inadequate payment of filing fees.
It will reveal their nature and impact to access to justice. No one
understands the courts in Nigeria more than the judges, especially
the judges that have been promoted from the lower courts to the
Supreme Court.
The Supreme Court of Nigeria is the apex court in Nigeria, its
judgments are final and its judges are more experienced than any
other. Below are the words of the justices of the Supreme Court of
Nigeria, on the “Distinction between Non-Payment and Inadequate
Payment of Filing Fees”, through the judgments of the Supreme Court
of Nigeria:
1. First of all, “Filing fees in civil appeals (cases) are
generally set out by the Rules of Court and paid to the registrar
of the appropriate court from which the appeal emanates.” Per
MUHAMMAD, J.S.C (P. 38, paras. A-B) in the case of SPDC & ORS v.
AGBARA & ORS (2015) LPELR-25987(SC).
2. On the purpose of filing fees; “…In our system of Court
administration it is not possible for a litigant to walk into our
Courts to institute a suit without paying fees. Such fees are being
charged for the purpose of raising funds for public revenue. They
are not being charged to punish the litigants for deciding to take
advantage of the provisions of Section 6 subsection (6) of the 1979
Constitution. The fact that the fees payable are increased in
certain categories of cases does not render the charging of the
increased fees unconstitutional. It is not within the province of
the Courts to conjecture as to the reasons why the higher fees are
being charged for as long as the 1988 Edict does not state the
purpose for which the higher fees are being charged. The function
of the Courts is to interpret the law but not to bring to bear
extrinsic reasons as to why the law is made. For the same reason it
will be wrong, in my opinion, for the Courts to consider whether
prospective litigants are in a position to pay the fee prescribed
or not in determining whether the charging of the fee is
constitutional. See: Nwosu’s case (supra).” Per MUHAMMADU LAWAL
UWAIS ,J.S.CÂ ( P. 23, paras. A-E ) in the case of ATOLAGBE & ANOR
v. AWUNI & ORS (1997) LPELR-593(SC)
3. “In SC. 693/2013 an appeal on an identical issue decided by the
Court on 11/12/15 in my concurring judgment to the leading judgment
delivered by my learned brother I.T Muhammed, JSC I said that:”……..
non-payment of filing fees is different from inadequate payment,
the latter being the fault of the Registry……..” I must say that non
payment of filing fees is a serious omission by the Appellant which
in effect deprives the Court of jurisdiction to hear the appeal.
see Okolo v. UBN Ltd (2004) 3 NWLR (Pt.859) p. 87. On the other
hand in adequate payment of filing fees is usually the fault of the
Registry who made a mistake when it told the Appellant the amount
to be paid. In cases where the fees paid by the Appellant are
inadequate it is the singular duty of the presiding Judge to order
the erring Appellant to pay the correct filing fees instead of
striking out the appeal.” Per RHODES-VIVOUR ,J.S.C ( Pp. 35-36,
paras. F-D) in the case of NIGERIA AGIP OIL CO. LTD v. NKWEKE &
ANOR (2016) LPELR-26060(SC)
4. “I begin with the issue of filing fees. Payment of filing fees
is a precondition to Court’s assumption of jurisdiction in a case.
The rules of Court make this mandatory. See ONWUGBUFOR VS OKOYE
(1996) 1 NWLR (Pt. 424) 252 at 292 per Iguh, JSC. However, the
Appellants’ contention is not that fees were not paid, but that the
appropriate fees have not been paid by the Respondent. This is an
assertion on the part of the Appellants. Proof is required as to
what ought to be paid and what was actually paid. The Appellants
have not proved that the assessment of the Court’s Registrar was
wrong neither did they state the amount that the Respondent ought
to pay.” Per BAGE ,J.S.C ( P. 8, paras. C-F ) in the case of SULE &
ORS v. ORISAJIMI (2019) LPELR-47039(SC)
5. “Payment of filing fees is a precondition to or condition
precedent to the court’s assumption of jurisdiction. Where filing
fees are not paid, a court of law will have no jurisdiction to
entertain the matter before it. This is because the rules of court
make it mandatory for a party to pay filing fees. This is because
the rules of Court make it mandatory for a party to pay filing
fees.” Per TOBI ,J.S.C ( P. 14, paras. A-B ) in the case of OKOLO &
ANOR v. UBN LTD (2004) LPELR-2465(SC)
6. “…the failure to remedy or pay the deficiency does not and
should not raise an issue of jurisdiction but the consequential
effect is a mere irregularity and which is not capable in affecting
the validity of the proceedings. See the cases of Akpaji v. Udemba
(2009) 2 NMLR 183; ACB Ltd v. Henshaw (1990) 1 NWLR (Pt 129) 646 at
650; Noibi v. Fikolati & Anor (1987) 1 NMLR (Pt.52) 619 at 632.”
Per OGUNBIYI ,J.S.C ( P. 76, paras. A-B ) SPDC & ORS v. AGBARA &
ORS (2015) LPELR-25987(SC)
7. “…the law has for long been settled by authorities that payment
of inadequate filing fees can only make a process irregular and not
capable of affecting the jurisdiction of the court. See: Onwugbufor
& 2 Ors v. Okoye & 3 Ors; Akpaji v. Udemba (2009) 6 NWLR (Pt.1138)
545.” Per MUHAMMAD ,J.S.C ( Pp. 56-57, paras. E-A ) SPDC & ORS v.
AGBARA & ORS (2015) LPELR-25987(SC)
8. “…where inadequate fees are paid, I agree with learned
appellants’ counsel, the usual remedy is an order of court for the
short fall to be paid. Non-payment of adequate fees, it has been
held, does not ordinarily rob the court its jurisdiction. In ACB
Ltd v. Henshaw (1990) 1 NWLR (pt 129) 646, a decision this court
cited with approval in reiterating the principle, Oguntade JCA (as
he then was) at page 651 of the report puts the position succinctly
thus: “Even if the Defendant/Respondent had not paid the requisite
court fees, this was a matter to be settled before the Lower Court
the usual remedy being on order by the Lower Court that the
appropriate fees or any short fall be paid. It certainly has
nothing to do with the jurisdiction of the Lower Court to entertain
the suit.” This Court in Onwugbufor & 2 Ors v. Okoye & 3 Ors (1996)
1 NWLR (Pt 424) 252 at 291-292 also states per Iguh JSC thus:- “If
the default in payment is that of the plaintiff, the claim in
respect of which such prescribed fees have not been paid cannot be
said to be properly before the court and should be struck out in
the absence of an appropriate remedial action or application to
regularise such anomaly.” Per MUHAMMAD ,J.S.C ( Pp. 18-19, paras.
G-E ). OGWE & ANOR v. IGP & ORS (2015) LPELR-24322(SC)
9. “It is basic to say it without any form of hesitation that based
on the position of this court in the case of Akpaji v. Udemba
(supra), payment of inadequate filing fees is a mere irregularity.
The usual remedy should be an order that the appropriate filing
fees or its short fall be paid. Such a short fall has nothing to do
with the jurisdiction to hear the appeal as in the instant appeal
and ought not to be a basis for the court to strike out the
appeal.” Per FABIYI ,J.S.C ( P. 24, paras. D-F ) OGWE & ANOR v. IGP
& ORS (2015) LPELR-24322(SC)
10. “I wish to say that generally, payment of a prescribed filing
fee, by all litigants except the government, is a pre-condition to
the validity of any process filed in the Court. Unless the
pre-condition is satisfied, the Court will lack the jurisdiction to
entertain a process the prescribed filing fee of which has not been
paid. … If the default in payment is that of the plaintiff, the
claim in respect of which such prescribed fees have not been paid
cannot be said to be properly before the Court and should be struck
out in the absence of an appropriate remedial action or application
to regularize such anomaly.” Per ADEREMI ,J.S.C ( Pp. 31-33, paras.
C-A ) in the case of ABIA STATE TRANSPORT CORPORATION & ORS v.
QUORUM CONSORTIUM LTD (2009) LPELR-33(SC)
11. “It is worthwhile to note that Section 30 of the Court of
Appeal Act defines an appeal to include an application for leave to
appeal and an appellant to include the person who makes such
application. In any event once it is shown that the appellant has
paid the filing fees as assessed by the officer whose
responsibility it is to do so, whether at the trial court or the
Court of Appeal as the case may be, the appeal is, on the
authorities, duly filed and same cannot be legally struck out.
Otherwise the appellants would be made to suffer for the fault,
negligence or inadvertence of another. Where the fault of the
payment of inadequate filing fees in respect of the appeal is
traceable to the officer who assessed the fees it would be unfair
not to place the blame where it truly is. See Iyalabani Co Ltd V.
Bank of Baroda (1995) 44 NWLR (Pt.387) 20, Bowaje V. Adediwura
(1976) 6 SC 143, Doherty V. Doherty (1964) 1 NLR 299 and Ahmadu V.
Salawu (197411 NLR (Pt.11) 318.” Per MUHAMMAD ,J.S.C ( Pp. 20-21,
paras. D-B ) OGWE & ANOR v. IGP & ORS (2015) LPELR-24322(SC)
Conclusion:
Filling fees are assessed and collected by courts for cases. They
are paid before disputants and their lawyers are allowed to file
documents in courts, except government and govern agencies.. The
filing fees having been going up even as the courts keep receiving
allocations from government to run the affairs of courts.
Generally, payment of filling fees is one of the facts that
discourage disputants in courts. Failure to pay filing fees have
been differentiated from failure to pay adequate filling fees.
Payment of court filing fees is a statutory condition and where it
is lacking the court has no jurisdiction over a case. However,
where there is an inadequate payment of court filing fees (often
due to wrong assessment and mistake of the court registry), it is a
mere irregularity that does not affect the jurisdiction of the
court. Rather, the court would rather make an order for the balance
of the fees to be paid.
My authorities, are:
1. The judgment of the Supreme Court of Nigeria in the case of
SPDC & ORS v. AGBARA & ORS (2015) LPELR-25987(SC)
2. The judgment of the Supreme Court of Nigeria in the case of
NIGERIA AGIP OIL CO. LTD v. NKWEKE & ANOR (2016)
LPELR-26060(SC)
3. The judgment of the Supreme Court of Nigeria in the case of SULE
& ORS v. ORISAJIMI (2019) LPELR-47039(SC)
4. The judgment of the Supreme Court of Nigeria in the case of
OKOLO & ANOR v. UBN LTD (2004) LPELR-2465(SC)
5. The judgment of the Supreme Court of Nigeria in the case of OGWE
& ANOR v. IGP & ORS (2015) LPELR-24322(SC)
6. Onyekachi Umah, “How to Certify Documents & Make Affidavits
Without Courts” (LearnNigerianLaws.com, 14 April 2021)
<https://learnnigerianlaws.com/how-to-certify-documents-make-affidavits-without-courts/[1]> accessed 16
April 2021
7. Onyekachi Umah, “Why Courts Must Hear Stupid
Applications/Motions?” (LearnNigerianLaws.com, 17 September 2020)
<https://learnnigerianlaws.com/why-courts-must-hear-stupid-applications-motions/[2]> accessed 16
April 2021
8. Onyekachi Umah, “When Courts Must Refuse To Consider
Issues/Applications Before It” (LearnNigerianLaws.com, 10 September
2020) <https://learnnigerianlaws.com/when-courts-must-refuse-to-consider-issues-applications-before-it/[3]> accessed 16
April 2021
9. Onyekachi Umah, “Oral Application for Bail is Allowed in High
Courts” (LearnNigerianLaws.com, 31 August 2020)<https://learnnigerianlaws.com/oral-application-for-bail-is-allowed-in-high-courts/[4]> accessed 16
April 2021
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Daily Law Tips (Tip 776) by Onyekachi Umah, Esq., LL.M,
ACIArb(UK)
Introduction:
Justice is not free, as litigants must pay court filing fee to
courts, for their cases to be attended to, by magistrates and
judges. Over the years the costs of filing cases in courts have
increased with every new rules of courts. In a judicial system that
plans to generate funds from filing fees paid into courts, failure
to pay filing fees and inadequate filing fees have varying effects
and may jeopardize justice. Hence, understating the distinction
between non-payment and inadequate payment of filing fees is
important.
Filling fees and access to justice:
The courts in Nigeria are expected to establish and charge filing
fees from disputants before accepting their cases. Government and
government agencies do not pay filing fees. The fees are often
expensive, as such they discourage disputants from claiming high
damages, since high damages translate to high filing fees. The fees
at times discourage disputants from accessing the courts, coupled
with the complexity of procedures of the courts and delays in
courts.
Often, stakeholders argue that the court filing fees (court
cost) are set to discourage frivolous cases. However, the costs are
not justifiable, since truly government provides budget. By the
way, frivolous cases can easily be discouraged by having judges
order punitive fees against concerned disputants and their lawyers.
Also, for the lawyers, courts should report them to their
professional body (the Nigerian Bar Association and others). Court
filing fees (court cost) are increasing and they are obviously
decreasing access to justice among indigent Nigerians and thereby
encouraging self-help.
Non-Payment Vs. Inadequate Payment of Filing Fees and
their Effects:
This section focuses on clarifying the distinction between
non-payment of filing fees from inadequate payment of filing fees.
It will reveal their nature and impact to access to justice. No one
understands the courts in Nigeria more than the judges, especially
the judges that have been promoted from the lower courts to the
Supreme Court.
The Supreme Court of Nigeria is the apex court in Nigeria, its
judgments are final and its judges are more experienced than any
other. Below are the words of the justices of the Supreme Court of
Nigeria, on the “Distinction between Non-Payment and Inadequate
Payment of Filing Fees”, through the judgments of the Supreme Court
of Nigeria:
1. First of all, “Filing fees in civil appeals (cases) are
generally set out by the Rules of Court and paid to the registrar
of the appropriate court from which the appeal emanates.” Per
MUHAMMAD, J.S.C (P. 38, paras. A-B) in the case of SPDC & ORS v.
AGBARA & ORS (2015) LPELR-25987(SC).
2. On the purpose of filing fees; “…In our system of Court
administration it is not possible for a litigant to walk into our
Courts to institute a suit without paying fees. Such fees are being
charged for the purpose of raising funds for public revenue. They
are not being charged to punish the litigants for deciding to take
advantage of the provisions of Section 6 subsection (6) of the 1979
Constitution. The fact that the fees payable are increased in
certain categories of cases does not render the charging of the
increased fees unconstitutional. It is not within the province of
the Courts to conjecture as to the reasons why the higher fees are
being charged for as long as the 1988 Edict does not state the
purpose for which the higher fees are being charged. The function
of the Courts is to interpret the law but not to bring to bear
extrinsic reasons as to why the law is made. For the same reason it
will be wrong, in my opinion, for the Courts to consider whether
prospective litigants are in a position to pay the fee prescribed
or not in determining whether the charging of the fee is
constitutional. See: Nwosu’s case (supra).” Per MUHAMMADU LAWAL
UWAIS ,J.S.CÂ ( P. 23, paras. A-E ) in the case of ATOLAGBE & ANOR
v. AWUNI & ORS (1997) LPELR-593(SC)
3. “In SC. 693/2013 an appeal on an identical issue decided by the
Court on 11/12/15 in my concurring judgment to the leading judgment
delivered by my learned brother I.T Muhammed, JSC I said that:”……..
non-payment of filing fees is different from inadequate payment,
the latter being the fault of the Registry……..” I must say that non
payment of filing fees is a serious omission by the Appellant which
in effect deprives the Court of jurisdiction to hear the appeal.
see Okolo v. UBN Ltd (2004) 3 NWLR (Pt.859) p. 87. On the other
hand in adequate payment of filing fees is usually the fault of the
Registry who made a mistake when it told the Appellant the amount
to be paid. In cases where the fees paid by the Appellant are
inadequate it is the singular duty of the presiding Judge to order
the erring Appellant to pay the correct filing fees instead of
striking out the appeal.” Per RHODES-VIVOUR ,J.S.C ( Pp. 35-36,
paras. F-D) in the case of NIGERIA AGIP OIL CO. LTD v. NKWEKE &
ANOR (2016) LPELR-26060(SC)
4. “I begin with the issue of filing fees. Payment of filing fees
is a precondition to Court’s assumption of jurisdiction in a case.
The rules of Court make this mandatory. See ONWUGBUFOR VS OKOYE
(1996) 1 NWLR (Pt. 424) 252 at 292 per Iguh, JSC. However, the
Appellants’ contention is not that fees were not paid, but that the
appropriate fees have not been paid by the Respondent. This is an
assertion on the part of the Appellants. Proof is required as to
what ought to be paid and what was actually paid. The Appellants
have not proved that the assessment of the Court’s Registrar was
wrong neither did they state the amount that the Respondent ought
to pay.” Per BAGE ,J.S.C ( P. 8, paras. C-F ) in the case of SULE &
ORS v. ORISAJIMI (2019) LPELR-47039(SC)
5. “Payment of filing fees is a precondition to or condition
precedent to the court’s assumption of jurisdiction. Where filing
fees are not paid, a court of law will have no jurisdiction to
entertain the matter before it. This is because the rules of court
make it mandatory for a party to pay filing fees. This is because
the rules of Court make it mandatory for a party to pay filing
fees.” Per TOBI ,J.S.C ( P. 14, paras. A-B ) in the case of OKOLO &
ANOR v. UBN LTD (2004) LPELR-2465(SC)
6. “…the failure to remedy or pay the deficiency does not and
should not raise an issue of jurisdiction but the consequential
effect is a mere irregularity and which is not capable in affecting
the validity of the proceedings. See the cases of Akpaji v. Udemba
(2009) 2 NMLR 183; ACB Ltd v. Henshaw (1990) 1 NWLR (Pt 129) 646 at
650; Noibi v. Fikolati & Anor (1987) 1 NMLR (Pt.52) 619 at 632.”
Per OGUNBIYI ,J.S.C ( P. 76, paras. A-B ) SPDC & ORS v. AGBARA &
ORS (2015) LPELR-25987(SC)
7. “…the law has for long been settled by authorities that payment
of inadequate filing fees can only make a process irregular and not
capable of affecting the jurisdiction of the court. See: Onwugbufor
& 2 Ors v. Okoye & 3 Ors; Akpaji v. Udemba (2009) 6 NWLR (Pt.1138)
545.” Per MUHAMMAD ,J.S.C ( Pp. 56-57, paras. E-A ) SPDC & ORS v.
AGBARA & ORS (2015) LPELR-25987(SC)
8. “…where inadequate fees are paid, I agree with learned
appellants’ counsel, the usual remedy is an order of court for the
short fall to be paid. Non-payment of adequate fees, it has been
held, does not ordinarily rob the court its jurisdiction. In ACB
Ltd v. Henshaw (1990) 1 NWLR (pt 129) 646, a decision this court
cited with approval in reiterating the principle, Oguntade JCA (as
he then was) at page 651 of the report puts the position succinctly
thus: “Even if the Defendant/Respondent had not paid the requisite
court fees, this was a matter to be settled before the Lower Court
the usual remedy being on order by the Lower Court that the
appropriate fees or any short fall be paid. It certainly has
nothing to do with the jurisdiction of the Lower Court to entertain
the suit.” This Court in Onwugbufor & 2 Ors v. Okoye & 3 Ors (1996)
1 NWLR (Pt 424) 252 at 291-292 also states per Iguh JSC thus:- “If
the default in payment is that of the plaintiff, the claim in
respect of which such prescribed fees have not been paid cannot be
said to be properly before the court and should be struck out in
the absence of an appropriate remedial action or application to
regularise such anomaly.” Per MUHAMMAD ,J.S.C ( Pp. 18-19, paras.
G-E ). OGWE & ANOR v. IGP & ORS (2015) LPELR-24322(SC)
9. “It is basic to say it without any form of hesitation that based
on the position of this court in the case of Akpaji v. Udemba
(supra), payment of inadequate filing fees is a mere irregularity.
The usual remedy should be an order that the appropriate filing
fees or its short fall be paid. Such a short fall has nothing to do
with the jurisdiction to hear the appeal as in the instant appeal
and ought not to be a basis for the court to strike out the
appeal.” Per FABIYI ,J.S.C ( P. 24, paras. D-F ) OGWE & ANOR v. IGP
& ORS (2015) LPELR-24322(SC)
10. “I wish to say that generally, payment of a prescribed filing
fee, by all litigants except the government, is a pre-condition to
the validity of any process filed in the Court. Unless the
pre-condition is satisfied, the Court will lack the jurisdiction to
entertain a process the prescribed filing fee of which has not been
paid. … If the default in payment is that of the plaintiff, the
claim in respect of which such prescribed fees have not been paid
cannot be said to be properly before the Court and should be struck
out in the absence of an appropriate remedial action or application
to regularize such anomaly.” Per ADEREMI ,J.S.C ( Pp. 31-33, paras.
C-A ) in the case of ABIA STATE TRANSPORT CORPORATION & ORS v.
QUORUM CONSORTIUM LTD (2009) LPELR-33(SC)
11. “It is worthwhile to note that Section 30 of the Court of
Appeal Act defines an appeal to include an application for leave to
appeal and an appellant to include the person who makes such
application. In any event once it is shown that the appellant has
paid the filing fees as assessed by the officer whose
responsibility it is to do so, whether at the trial court or the
Court of Appeal as the case may be, the appeal is, on the
authorities, duly filed and same cannot be legally struck out.
Otherwise the appellants would be made to suffer for the fault,
negligence or inadvertence of another. Where the fault of the
payment of inadequate filing fees in respect of the appeal is
traceable to the officer who assessed the fees it would be unfair
not to place the blame where it truly is. See Iyalabani Co Ltd V.
Bank of Baroda (1995) 44 NWLR (Pt.387) 20, Bowaje V. Adediwura
(1976) 6 SC 143, Doherty V. Doherty (1964) 1 NLR 299 and Ahmadu V.
Salawu (197411 NLR (Pt.11) 318.” Per MUHAMMAD ,J.S.C ( Pp. 20-21,
paras. D-B ) OGWE & ANOR v. IGP & ORS (2015) LPELR-24322(SC)
Conclusion:
Filling fees are assessed and collected by courts for cases. They
are paid before disputants and their lawyers are allowed to file
documents in courts, except government and govern agencies.. The
filing fees having been going up even as the courts keep receiving
allocations from government to run the affairs of courts.
Generally, payment of filling fees is one of the facts that
discourage disputants in courts. Failure to pay filing fees have
been differentiated from failure to pay adequate filling fees.
Payment of court filing fees is a statutory condition and where it
is lacking the court has no jurisdiction over a case. However,
where there is an inadequate payment of court filing fees (often
due to wrong assessment and mistake of the court registry), it is a
mere irregularity that does not affect the jurisdiction of the
court. Rather, the court would rather make an order for the balance
of the fees to be paid.
My authorities, are:
1. The judgment of the Supreme Court of Nigeria in the case of
SPDC & ORS v. AGBARA & ORS (2015) LPELR-25987(SC)
2. The judgment of the Supreme Court of Nigeria in the case of
NIGERIA AGIP OIL CO. LTD v. NKWEKE & ANOR (2016)
LPELR-26060(SC)
3. The judgment of the Supreme Court of Nigeria in the case of SULE
& ORS v. ORISAJIMI (2019) LPELR-47039(SC)
4. The judgment of the Supreme Court of Nigeria in the case of
OKOLO & ANOR v. UBN LTD (2004) LPELR-2465(SC)
5. The judgment of the Supreme Court of Nigeria in the case of OGWE
& ANOR v. IGP & ORS (2015) LPELR-24322(SC)
6. Onyekachi Umah, “How to Certify Documents & Make Affidavits
Without Courts” (LearnNigerianLaws.com, 14 April 2021)
<https://learnnigerianlaws.com/how-to-certify-documents-make-affidavits-without-courts/[1]> accessed 16
April 2021
7. Onyekachi Umah, “Why Courts Must Hear Stupid
Applications/Motions?” (LearnNigerianLaws.com, 17 September 2020)
<https://learnnigerianlaws.com/why-courts-must-hear-stupid-applications-motions/[2]> accessed 16
April 2021
8. Onyekachi Umah, “When Courts Must Refuse To Consider
Issues/Applications Before It” (LearnNigerianLaws.com, 10 September
2020) <https://learnnigerianlaws.com/when-courts-must-refuse-to-consider-issues-applications-before-it/[3]> accessed 16
April 2021
9. Onyekachi Umah, “Oral Application for Bail is Allowed in High
Courts” (LearnNigerianLaws.com, 31 August 2020)<https://learnnigerianlaws.com/oral-application-for-bail-is-allowed-in-high-courts/[4]> accessed 16
April 2021
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