CHERRYPICKING OF CONSTITUTIONAL PROVISIONS AND ITS DEBACLE OF THE NIGERIAN ECONOMY
Activities in the political arena directly and indirectly affect economic policies and outcomes. The foundation of political, economic and social structures is often anchored on a constitutional order. In a democratic society like Nigeria with a written constitution, the supremacy of the 1999 Constitution of the Federal Republic of Nigeria as amended is sacrosanct!
The bane of the Nigerian society is that often times in governance, there is no alignment between the provisions of the Constitution and the politics of power in Nigeria. Thus uncritical critics of the Constitution are denigrating it and presenting it as seemingly ineffective to tackle legal-economic-socio challenges that the country faces.
This article examines the recent events that involved the third arm of the Federal Government of Nigeria, particularly as it relates to the attempt to arraign the Chief Justice of Nigeria ('CJN') Walter Samuel Onnoghen before the Code of Conduct Tribunal ('CCT'), his subsequent suspension by President Muhammadu Buhari and the President's appointment of an Acting-Chief Justice of Nigeria ("Acting-CJN') Tanko Muhammed. Emphasis is placed on the constitutionality of these events and the potential effect they may have on the Nigerian Economy considering that we are in the eve of general elections.
On 9 January 2019, major news and social media outlets reported that a petition has been filed at the Code of Conduct Bureau ('CCB') against the CJN. It was alleged that there were undeclared assets and unexplained funds found in his bank accounts contrary to the code of conduct for public officers. Charges were filed at the CCT and the arraignment of the CJN at the CCT was scheduled for 14 January 2019. While arguments over the appropriateness or otherwise, as well as litigations over the planned arraignment of the CJN continued unabated, the President of the Federal Republic of Nigeria on 25 January 2019 unilaterally suspended the CJN relying on an ex parte order issued by the CCT and in his place hurriedly swore-in Justice Tanko Muhammed as the new Acting-CJN without any recourse to National Judicial Council ('NJC').
APPLICABLE CONSTITUTIONAL AND STATUTORY PROVISIONS
Supremacy of the Constitution
Section 1 of the 1999 Constitution provides as follows (1) This constitution is supreme and its provisions shall have binding forces on all authorities and person throughout the Federal Republic of Nigeria. (2) The Federal Republic of Nigeria shall not be governed, nor any person or group of persons take control of the Government of Nigeria or any part thereof, except in accordance with the provisions of this Constitution.'
Nigeria adopted a presidential system of government way back in 1979. The 1999 Constitution like its predecessor of 1979 embodies the supremacy of the Constitution. The foregoing section has been interpreted in constitutional cases handled by the courts to mean that all the actions of the government of Nigeria are governed by the Constitution and it is the Constitution as the organic law of the country that declares in a formal, corporate and binding principles the rights, liberties, powers and responsibilities of the people, both the government and the governed: Attorney General of the Federation v. Atiku Abubakar  8 NWLR (Part 1035) p.124.
All actions and activities of any of the arms of governments in Nigeria must be governed by the provisions of the Constitution. The three arms of government are creations of the Constitution and the powers they exercise must be exercised in line with constitutional provision. In Attorney-General of Abia State v. Attorney-General of the Federation  6 NWLR (Part 763) p.479-480, para. G-A) the Supreme Court held that the Constitution is the gundnorm and the fundamental law of the land. All other legislations take their hierarchy from the provisions of the Constitution. The provisions of the Constitution take precedence over any law enacted by the National Assembly even though the National Assembly has the power to amend the Constitution itself. By the provisions of the Constitution, the law made by the National Assembly comes next to the Constitution, followed by those made by the House of Assembly of a State.
Any executive action or legislative activity that does not find support from the Constitution or a statute is void and unconstitutional. When an executive action is premised on a statute, that statute must not be in conflict with the Constitution, in the event that the statute is in conflict with the Constitution, the Constitution is supreme. Section 1(3) of the Constitution provides that, if any other law is inconsistent with the provisions of this Constitution, this Constitution shall prevail, and that other law shall to the extent of the inconsistency be void.
Appointment of the CJN and Justices of the Supreme Court
Section 231 provides as follows (1) The appointment of a person to the office of the Chief Justice of Nigeria shall be made by the President on the recommendation of the National Judicial Council subject to confirmation of such appointment by the Senate. (2) The appointment of a person to the office of a Justice of the Supreme Court shall be made by the President on the recommendation of the National Judicial Council, subject to confirmation of such appointment by the Senate. (3) A person shall not be qualified to hold office of the Chief Justice of Nigeria or of a Justice of the Supreme Court, unless he is qualified to practice as a legal practitioner in Nigeria and has been so qualified to practise as a legal practitioner in Nigeria and has been so qualified for a period of not less than fifteen years. (4) if the office of Chief Justice of Nigeria is vacant or if the person holding the office is for any reason unable to perform the functions of the office, then until a person has been appointed to and has assumed those functions, the President shall appoint the most senior Justice of the Supreme Court to perform those functions. (5) Except on the recommendation of the National Judicial Council, an appointment pursuant to the provisions of section (4) of this section shall cease to have effect after the expiration of three months from the date of such appointment and the President shall not reappoint a person whose appointment has lapsed.
Removal of Judicial Officer
On the removal of a judicial officer from office, section 292 of the Constitution provides as follows:
"(1) A judicial officer shall not be removed from his office or appointment before his age of retirement except in the following circumstances -
(a) in the case of -
(i) Chief Justice of Nigeria, President of the Court of Appeal, Chief Judge of the Federal High Court, Chief Judge of the High Court of the Federal Capital Territory, Abuja, Grand kadi of the Sharia Court of Appeal of the Federal Capital Territory, Abuja by the President acting on an address supported by two-thirds majority of the Senate;
(ii) Chief Judge of a State, Grand Kadi of a Sharia Court of Appeal or President of a Customary Court of Appeal of a State, by the Governor acting on an address supported by two-third majority of the House of Assembly of that State;
Praying that he be so removed for his inability to discharge the functions of his office or appointment (whether arising from infirmity of mind or body) or for misconduct or contravention of the Code of Conduct;
(b) in any case, other than those to which paragraph (a) of this subsection applies, by the president or, as the case may be, the Governor acting on the recommendation of the National Judicial Council that the judicial officer be so removed for his inability to discharge the functions of his office or appointment (whether arising from infirmity of mind of body) or for misconduct or contravention of the Code of Conduct.
(2)Any person who has held office as a judicial officer shall not on ceasing to be judicial officer for any reason whatsoever thereafter appear or act as a legal practitioner before any court of law or tribunal in Nigeria."
The above provides the foundation for further discussion on this subject. The highlighted provisions will be considered and analysed - Chapter VII of the 1999 Constitution deals with the judicature. It makes elaborate provision for the establishment of the superior courts listed in Section 6(5)(a)-(i) of the Constitution, appointment of judges to these courts and their removal, the court's jurisdiction; as well as its practice and procedure.
The Supreme Court has in several cases considered the guiding principles governing interpretation of the Constitution and statute. In Attorney General of Lagos State v. Attorney General of the Federation  12 NWLR (Pt 833) p.117 paras.G-H; 159, para C-E. the Supreme Court held that in interpreting the Constitution a narrow meaning should not given to it unless it becomes necessary to do so. Rather a wide and liberal interpretation must be applied unless there is express provision to the contrary and this must be done in order to carry out or give effect to the intention of the makers of the Constitution.
A court of record should be minded to make broad interpretation or what is sometimes referred to as adopting a liberal approach. A court should give a holistic interpretation to a statute as required by law. A court should aim at giving a statute purposeful interpretation. The underlying philosophy is that a legislator does not act in vain: N.U.R.T.W v. R.T.E.A.N  10 NWLR (Pt.1307) p. 196. The Supreme Court in the earlier case of Muhammadu Buhari v. Olusegun Obasanjo  13 NWLR (Pt. 941) p.281 held that where the words of a statute are ambiguous, it is the duty of the court to give words a meaning that will reasonate with sense, order and system so as to make it workable and real. The Court further held that in construing the provisions of a section of a statute, the whole of the statute must be read in order to determine the meaning and effect of the word being interpreted.
In A.T.Limited v. A.D.H Limited  15 NWLR (Pt.1056) p.166, the Supreme Court held that in the interpretation of constitutional provisions, the entire provisions must be read together as a whole so as to determine the object of the provisions. Secondly, where a court is faced with alternatives in the course of interpreting the Constitution or a statute, the alternative construction that is consistent with smooth running of the system shall prevail. This principle of construction is often expressed in the maxim ut res magis valeat quam pereat. This means that even if alternative constructions are equally open, the court will opt for that alternative which is to be consistent with the smooth working of the system, which the Constitution read as a whole, has set out to regulate. And the alternative, which will disrupt the smooth development of the system, is to be rejected.
Section 292 of the Constitution is clear and straightforward on how a serving CJN can be removed from office. It recognises only two means. First, by the President acting on an address supported by two-third majority of the Senate, praying that the CJN be removed for his inability to discharge the functions of his office or appointment (whether arising from infirmity of mind or of the body) or for misconduct or contravention of the Code of Conduct. Second, by the President acting on the recommendation of the NJC that the judicial officer be so removed for his inability to discharge the functions of his office or appointment (whether arising from infirmity of mind or body) or for misconduct or contravention of the Code of Conduct.
None of the above two means of removal of a Judicial officer was satisfied in the case of the suspended CJN and the Acting CJN. The President relied on an ex parte order issued by the CCT to remove the CJN and he then subsequently appointed the Acting CJN. It doesn't require rocket science to decipher the unconstitutionality of the President's action by his removal of the CJN. The thresholds stated in section 292(1)(a) and (b) of the Constitution were not satisfied. The CJN prior to his suspension was not suffering from any infirmity of the mind or body, neither was he found culpable of any misconduct by the NJC, the body constitutionally charged with the discipline of judicial officers nor was he found to have contravened the code of conduct by the CCT or any court in Nigeria. The CCB only planned to arraign him before the CCT on allegations of non-declaration of assets.How the President came about the powers he exercised on 25 January 2019 is perplexing for the most discerning legal mind. Legally and constitutionally speaking, the office of the CJN was not vacant, when the President purported to swear-in the Acting-CJN relying on Section 231(4) of the Constitution.
Impenitent supporters of the President's illegal action will rush to find justification in Section 231(4) of the Constitution for the swearing-in of the Acting-CJN. Some have vigorously sought to justify the President's action on the need to fight corruption. But such argument falls flat in the face of a superior legal principle, which states that you cannot build on unconstitutionality and expect the structure to stand. I dare say such an action is null and void and of no legal effect. More so, a holistic interpretation of the Constitution and not an isolated reading of a single provision is required by law. The unconstitutional action of the President has foisted upon the country a de jure CJN who is illegally suspended and a de facto Acting-CJN who enjoys the backing of the President and members of his executives arm of government, political party and paraphernalia of the Nigerian state. The President or his advisors read the Constitutional provisions and simply cherry-picked provisions they believed will support their desecration of the very document Mr. President swore to uphold and defend. A scenario like this could never have been the intentions of the draftsman. In fact, if unchecked, Mr. President's unconstitutional action is the very recipe for a constitutional crisis and a breakdown in governance.
The Code of Conduct Bureau and the Code of Conduct Tribunal Proceedings
The Code of Conduct Bureau ('CCB') is one of the federal executive bodies created by Section 153 of the Constitution and its independence guaranteed by Section 158 of the Constitution.
Section 3 of the Code of Conduct Bureau and Tribunal Act ('CCB&T') confers the body with the following functions - '(a) receive assets declarations by public officers in accordance with the provisions of the Act; (b) examine the assets declarations and ensure that they comply with the requirement of the Act and of any law for the time being in force; (c) take and retain custody of such assets declarations; and (d) receive complaints about non-compliance with or breach of the Act and where the Bureau considers it necessary to do so, refer such complaints to the Code of Conduct Tribunal established by section 20 of this Act in accordance with the provisions of sections 20 to 25 of the Act. Provided that where the person concerned makes a written admission of such breach or non-compliance, no reference to the tribunal shall be necessary.'
The CCT is a creation of the fifth Schedule, paragraph 15 of the 1999 Constitution and Section 20 of the CCB&T Act. Section 23 of the CCB&T Act confers the CCT with powers to impose punishment. The section provides thus -
· where the Tribunal finds a public officer guilty of contravening any of the provisions of this Act, it shall impose upon that officer any of the punishments specified under subsection (2) of this section.
· The punishment which the Tribunal may impose shall include any of the following -
· Vacation of office or any elective or nominated office, as the case may be;
· Disqualification from holding any public office (whether elective or not) for a period not exceeding ten years; and
· Seizure and forfeiture to the State of any property acquired in abuse or corruption of office.
Part II of the Fifth Schedule of the Constitution provides the list of public officers that the Code of the Conduct is applicable to. Paragraph 5 mentions the Chief Justice of Nigeria, Justice of the Supreme Court, President and Justices of the Court of Appeal, all other judicial officers and all staff of court of law. It follows that upon a commission of any of the offences stated in the paragraphs 1 to 11 of Part 1 of the fifth Schedule of the Constitution, the judicial officer can be subjected to trial before the CCT. The power to try an alleged offender is however subject to the proviso in Section 3(d) of the CCB&T Act, which states that where the person concerned makes a written admission of such breach or non-compliance, no reference to the tribunal shall be necessary. In the absence of a written admission in a particular case the proviso of Section 3(d) of the CCB&T Act will not apply.
The rule of procedure to be adopted in any prosecution for the offences under the CCB&T Act before the CCT and the forms to be used in such prosecution shall be as set out in the Third schedule to the CCB&T Act. A comprehensive reading of the rule of procedure would show that it is a criminal proceeding or in the least a quasi-criminal proceeding. Paragraph 17 of the Third Schedule of the CCB&T Rules of Procedure states that where these Rules contain no provision in respect of any matter relating to or connected with the trial of offences under this Act, the provision of the Criminal Procedure Act or, depending on the venue, the Criminal Procedure Code shall with such modification as the circumstance may require apply in respect of such matter to the same extent as they apply to the trial of offences generally. It follows that punitive measures or sanctions can only be meted out at sentencing after the completion of trial proceedings. They cannot be granted in absentia by way of ex parte order as was the case in the suspension of CJN Walter Samuel Onnoghen from office. The simple reason for this is that the principle of audi alteram partem as enshrined in Section 36 of the Constitution grants any person charged with an offence the right to fair hearing in public within a reasonable time by a court or tribunal. Importantly, the penalty to vacate office or any other punishment stipulated in the Constitution or the CCB&T Act can only be imposed after trial proceedings have been completed and the CCT finds a public officer guilty of contravening any of the provisions of the Code of Conduct. Stated differently, there is no provision in the CCB&T Act conferring the CCT with powers to grant interim or interlocutory punitive measures in a proceeding before it.
The NJC or the CCT
The NJC is a Constitutional body just as the CCT. It was established by Section 153 of the Constitution with its powers specified in Paragraph 21 of Part One of the Third Schedule. Section 158 of the 1999 Constitution unequivocally provided for the independence of the NJC vis-à-vis directing or controlling it by any authority or person while exercising its powers.
Paragraph 20 of the Part 1 of the Third Schedule of the Constitution provides for the composition of the NJC and the members are (a) the Chief Justice of Nigeria, (b) the next most senior Justice of the Supreme Court, (c) the President of the Court of Appeal; (d) five retired Justices selected by the Chief Justice of Nigeria from the Supreme Court or Court of Appeal (e) the Chief Judge of the Federal High Court; (f) five Chief Judges of States to be appointed by the Chief Justice of Nigeria from among the Chief Judges of the States and of the High Court of the FCT, Abuja in rotation to serve for two years; (g) one Grand Kadi to be appointed by the Chief Justice of Nigeria from among Grand Kadis of the Sharia Courts of Appeal to serve in rotation for two years; (h) one president of the Customary Court of Appeal to be appointed by the Chief Justice of Nigeria from among the Presidents of the Customary Court of Appeal to serve in rotation for two years; (i) five members of the Nigerian Bar Association who have been qualified to practice for a period of not less than fifteen years, at least one of whom shall be Senior Advocate of Nigeria, appointed by the Chief Justice of Nigeria on the recommendation of the National Executive Committee of the Nigerian Bar Association to serve for two years and subject to re-appointment; (j) two person not being legal practitioners, who in the opinion of the Chief Justice of Nigeria are of unquestionable integrity.
The NJC has by virtue of Section 160 of the Constitution fashioned out several judicial regulations to inter alia regulate its own procedure while exercising its constitutional powers and these include the (i) Judicial Discipline Regulations, (ii) Revised NJC Guidelines and Procedural Rules for the Appointment of Judicial Officers of all Superior Court of Record;(iii) Code of Conduct for Judicial officers of the Federal Republic of Nigeria and (iv) National Judicial Policy.
For all intents and purposes, the NJC is a specialised and well equipped body to handle the discipline of any judicial officer that is alleged to have been involved in financial or professional misconduct. This position finds support in the composition of the NJC as not just a council of the bench but that which comprises retired judges, serving judges and representatives of the Nigerian Bar Association. The draftsman must have desired or envisaged a system where a specialised and well experienced council will disciple a judicial officer by suspending or removing him from office before any other body can charge such a person who is no longer an embodiment of Justice, to court or before a tribunal as any ordinary citizen.
It is admitted that judicial officer are public officers and are also subject to the jurisdiction of the CCB and CCT. But arraignment of a serving judicial officer before another brother or sister judge works hardship on the justice administration system as the institution of the Court is not necessarily in a given courtroom or edifice, but in the person that exercises judicial power at any given time. The fundamental question that the Attorney-General of the Federation or the various prosecutorial authorities that he supervises needs to answer is - whether criminal trial can be time barred? If the answer to the question is in the negative. Why not wait for the NJC to exercise its constitutional powers before instituting an action at a court of law or the CCT.
The above position, I have canvassed finds support in a subsisting decision of the Court of Appeal, where the issue considered was - whether in view of the constitutionally guaranteed doctrine of independence of the Judiciary, the lower Court is right in reaching the conclusion that the executive arm of government (acting through the EFCC or any other authority) can directly prosecute a sitting judicial officer without first following due process as provided for in the Constitution by first referring the matter by way of petition to the NJC. The Court of Appeal answered in the negative. It held that the intention of the framers of the Constitution is to give the National Judicial Council a vital role to play in the appointment and removal of Judicial Officers by the Governors and Houses of Assembly of the State. The Court of Appeal held that the Respondent in the matter (i.e. the EFCC) must first report any infractions to the NJC to carry out its constitutional and disciplinary control over the Appellant, to establish a case before criminal proceedings. The powers of NJC are a condition precedent to the exercise of any other power over judicial officers who breach the code of conduct. These law enforcement agencies are not above the law and therefore must also comply with specific provisions of the law (Constitution). The aim is not to shield any judicial officer but to ensure that there is a ground to proceed against such person before their prosecution. This is also to ensure that there is no abuse by these agencies: Honourable Justice Hyeladzira Ajiya Nganjiwa v. Federal Republic of Nigeria (20017) LPELR - 43391 (CA).
In the wake of the 2016 invasion of the residences and arrest of judicial officers by the Department of State Services ('DSS'), the NJC rose to vehemently denounce a situation whereby the psyche of Judicial officer in the Federation is subjected to a level where they would be afraid to discharge their constitutional judicial function, without fear or favour, intimidation, victimisation or suppression. The NJC also restated its commitment to the preservation of the integrity and impartiality of the judiciary. There is nothing that the Executive arm of government has presented to show that the NJC as constituted is not independently or impartially discharging its constitutional functions. The steps taken by the NJC after the removal of the CJN would controvert such an assertion. The Chairman (CJN Walter Samuel Onnoghen) and the Vice Chairman (Acting-CJN Tanko Mohammed) were both excused from the NJC meeting of 29 January 2019 in compliance with the principle of nemo judex in causa sua(not being a judge in their own case). They were both queried; the nation and the world await the next step the NJC will take.
To settle this needless NJC v. CCT debate, a reading of the relevant constitutional and statutory provisions would show that appeals lie from the decision of the CCT to the Court of Appeal and even to the Supreme Court. One can see that this process is resources and time intensive. But in the case of the NJC, its decisions and recommendations are final from which no appeal lies. Economically, and even on the basis of saving tax payers money, the executive arm of government should refer matters on the discipline of any judicial officer to the NJC on a first line charge. Severity of the crime or misconduct may then necessitate criminal proceedings before the court of law or CCT after the Judicial Officer has been removed from office.
IMPLICATIONS FOR THE ECONOMY
It has been said that a seldom-stated fact of life is that without political stability, it is impossible to have economic progress. Until a nation has stable political system in place, it is impossible for people to plan their lives, conduct business peacefully and go about their daily routines with any hope for the future: Justiciability and Constitutionalism: An Economic Analysis of Law edited by Professor E. Azinge SAN and Professor B. Owasanoye, NIALS, 2010 p.140. The President's action did not only shake the foundation of governance in Nigeria and the principle of separation of powers enshrined in the Constitution, it created a crisis of confidence in the polity and economy.
The Nigerian economy is already weighed down by fluctuating oil or commodity price, resurgence of Boko Haram attacks in the North East, consistent absence of the President from the country on account of ill-health, heightened capital outflows on the back of rising yield in other emerging markets etc. As a Capital Market lawyer, recent reports I studied showed that the All Share Index ('ASI') of the Nigeria Stock Exchange ('NSE') which was the third best performing stock market in 2017, contracted by 17.81 percent as investors exited the market and repatriated capital. This is also bearing in mind that the International Monetary Fund had few days to the removal of the CJN from office announced a downward review of its growth forecast for Nigeria's economy to 2.0 percent for 2019 citing decline in crude oil prices.
In the World Bank Ease of Doing Business Report released in late 2018, Nigeria dropped to 146th position lower than the 145th it occurred the previous year. The World Bank noted that Nigeria carried out four reforms which included making starting a business easier, getting electricity and trading across borders. The World Bank also noted that some states made enforcement of contracts easier by issuing new rules of civil procedure and by making the ease of registering an interest in land easier through making available online the fee schedule and list of documents required.
But nothing threatens investors' confidence than a signal that the justice system can be bent or is subject to the rule of thumb or the whims and caprices of the executive arm of government. One of the major indicators for ease of doing business for any country is the access to its court system as already pointed out in the above mentioned World Bank report, where commercial or investment disputes can be settled before an independent or impartial court. Investors whether local or foreign need certainty in laws and policies. People don't put their money where they will most likely lose it on account of inconsistent policies or political turbulence.
At a time when Nigeria has relied on debt securities (treasury bills, domestic sovereign bonds, Eurobonds etc) to finance it short and mid-term budgetary needs, economic handlers at the Federal Executive level know that the market thrives not only on economic fundamentals, but also on perception. Political instability, governance and constitutional crisis impact on the credit ratings that a country and corporates from that country get from international credit rating agencies. It suffice to say that low ratings means low pricing of the country's debt securities and more interest to be paid by the government or Nigerian corporates that access the international capital market.
There are also security implication for the country and sub-Sahara Africa. Election or politically motivated crisis has wretched the economy of some countries in the region and these occurrences left long lasting economic and development consequences. The international community's intervention on the removal of the CJN is motivated by the above regional security and economic imperatives, considering that investors and multinational corporations from these countries have investments in Nigeria. This is evident by the reactions of the governments of the United States of America, the United Kingdom and the EU through its Election Observation Mission. In the various press statement released by these governments, they called for a resolution of the issues in accordance with rule of law, due process and the Constitution. As bad public and foreign relations personnel that some federal government officials are, they hurriedly jumped to criticise and shun the well intended interventions from our international partners.
Executive rascality or lawlessness should be rejected by the courts and the judicial institutions. The relevant institutions implicated in this removal saga need to follow due process, the rule of law and constitutionalism and stay above partisan, sectional or parochial interests.
This is not necessarily about the dramatis personae, it is about the institution of governance and the preservation of the very foundation on which our democracy is built. The cherry-picking of constitutional provisions to obey or disregard has not only destabilized the political arena, it has further tarnished our image and reputation in the comity of nations especially amongst our economic and development partners.
I belong to the school of thought that advocates that Nigeria as a secular state must develop a sense of commitment to the Constitution as an inviolable law and the basis for societal order. More important is the sanction of a national attitude that regards the Constitution as something inviolable, something so fundamental in the life of a nation that respect for it should be regarded as almost a kind of religion, and any violation of its provisions a sacrilege. Respect for the Constitution means that it should be treated as above the game of politics, and not tampered with, to buttress the political fortunes of politicians. As a nation we must institution a tradition against abuse of office or power. A democratic spirit should be complemented by a willingness on the part of the leader to observe the limits upon government powers, a habit of restraint and moderation. A statesman-like acceptance that the integrity of the whole governmental framework and the regularity of its process and procedure should rise above personal aggrandizement: Professor B.O Nwabueze, The Presidential Constitution of Nigeria (London: C. Hurst & Company) p.539.
*Author - Mr. Ikemefuna Stephen Nwoye
Principal Chief Counsel - NWOYE (Barrister and Solicitor)
Disclaimer: This article should not in any way serve as a substitute for legal advice or opinion. The views expressed are personal to the author and do not necessarily reflect the views of any organization or person that the author is or might have been affiliated to.