Monday, 20 August 2018

The election committee released the election result for the 2018 NBA National officers election in Abuja on Monday morning.
The election which began on Saturday ended on Monday at exactly 6am on Monday and Paul Usoro emerged winner of the presidential election.
The chairman of the election committee, Professor Auwalu Yadudu who presented the result said Usoro polled 4,509 votes to defeat Ernest Ojukwu who polled a total 3,313 votes and Okafor Obi who scored 4,423 votes
The outgoing president of the association, Abubakar Mahmoud who commended the election process said the 2018 election was the fairest so far
Mahmoud will bow out of office at the next NBA conference.

Tuesday, 12 June 2018

The High Court of the Federal Capital Territory, Gudu, Abuja , on Tuesday sentenced a former Governor of Plateau State and serving senator, Joshua Dariye , to 14 years ’ imprisonment on charges of criminal breach of trust and misappropriation of overN 1 . 16 bn belonging to the state .
Justice Adebukola Banjoko in a judgment which took her six and a half hours to read convicted the ex - governor on 15 out the 23 counts preferred against him .
The judge barely a fortnight ago , imposed 14 years ’ jail term on ex - Governor of Taraba State , Jolly Nyame , on similar charges .
On Tuesday she sentenced Dariye to two years imprisonment on each of the five counts bordering on criminal misappropriation and 14 years ’ jail term on each of the 11 counts of criminal breach of trust .
The judge , however , ruled that all the sentences would run concurrently , implying that the convict would have to spend 14 years in jail.
The punishments imposed on the ex -governor for the two categories of offences of criminal breach of trust and criminal misappropriation are the maximum as provided under sections 315 and 309 of the Penal Code Act , respectively .
The judge threw out eight of the 23 charges on the grounds of either duplicity or lack of sufficient evidence.
Economic and Financial Crimes Commission ’ s lawyer , Mr . Rotimi Jacobs ( SAN ) , had in opposing the defence lawyer ’ s plea for mercy, urged the court to impose the maximum sentence to serve as deterrence to others.

Tuesday, 29 May 2018

Corporate governance is the system of rules, practices and processes by which a firm is directed and controlled . Corporate governance essentially involves balancing the interests of a company’ s many stakeholders , such as shareholders , management, customers , suppliers , financiers , government and the community . But there is this general belief that there are serious corporate governance issues that need to be addressed in Nigeria so as to attract foreign direct investment and improve the country’ s ease of doing business index. Business lawyer and managing partner of Alliance Law Firm ( ALF ) , Uche Val Obi ( SAN ) in this interview with JOSEPH ONYEKWERE said the maiden edition of the ALF annual lecture would provide the platform for experts to examine contemporary issues around corporate governance . At the event , he will also unveil a novel book on class action in Nigeria .
Talking on the concept of corporate governance and its attendant challenges , the senior advocate said : “Corporate Governance is a set of rules and corporate behavioral patterns that regulate and guide corporate entities in their organization , proceedings , control , management and operation in a lawful, transparent , efficient and integrity driven manner so as to protect the interest of all stakeholders. These stakeholders are not limited to interest or shareholders , but include employees, creditors , service providers , host communities , governmental authorities and the general public . At this lecture the experts will be examining the contemporary issues around it , which would cover the present state ,
expected new codes , the practice and the way forward. ”
The event will be a convergence of law , regulators , leaders of the bar , captains of industries , operators and academics. When asked about legislators , Obi responded thus : “Those categories of people are the real stakeholders on matters of corporate governance , as they help to formulate and influence the policies, codes , behavioral patterns of corporates and implement them. The legislators are more involved in law making through sponsorship and passage of bills into Acts of the Parliament with presidential assent except when it is overridden . So by the end of the day , the National Assembly makes statutes . However , the codes of Corporate Governance are either regulatory or driven rules and practices, which may operate broadly or sectorally . So legislators are not directly involved in formulating the codes of corporate governance primarily . However , the body of laws already passed by the National Assembly is useful materials in promoting corporate governance rules to ensure that the later does not conflict with the former . ”
As earlier stated , the event would also witness the launch of the much awaited book titled : “Class Action in Nigeria ”. Giving snippets of this groundbreaking publication, the first of its kind in Nigeria , Obi said : “Class Action is a legal procedure or a form of suit in which a large group of people collectively bring a claim to Court or in which a class of defendants are being sued . The outcome of the suit will bind them and others falling into the same class whether or not they were named as parties . So there is finality of the outcome of the suit over the subject matter of class suit . ”
According to him , the importance of Class Action includes its ability to enhance access to justice. “ It is arguably one of the greatest most effective legal mechanism to remedy mass wrongs in a fast and evolving globalized world order , where the effect of a single wrong in a particular territory could affect millions of consumers in the country or across the world .
“ Aggregation of claims increases efficiency of the legal process , and lowers the costs of litigation especially ( in cases sharing common questions of law and facts ) as those claims are heard under a single suit . It also helps to avoid multiple suits arising from the same subject matter , which can result into conflicting decisions of Courts or different outcomes. In limited fund cases, a class action ensures that all plaintiffs receive reliefs and that early filing plaintiffs do not raid the fund or rid the defendant of all its assets before other plaintiffs are compensated . It can be used to change the behavior of a class of which the
defendant is a member .
“ The book is a pioneer work basically dealing with an understanding of the concepts , the state of affairs with our various Rules of Court , and the pros and cons . About a decade ago I was engaged to defend a Bank in a certified class action at the Federal High Court in which the claim was quite substantial . I then set out to gather local authorities to use but was quite shocked at the paucity of local materials both in reported cases and published works . So , I largely depended on foreign sources. I thought there was a gap to be filled and this book was therefore my attempt to respond to this yearning gap . In the course of writing the book, I tried to examine the state of the Rules of Court at the date of publication and expressed my views on their adequacy or otherwise . I also introduced the concept of Class arbitration as an emerging trend , which is gaining faster grounds
in some foreign jurisdictions like USA .
“ I have the feeling that an efficient deployment of Class Action mechanism would assist in promoting access to justice as more people can have their grievances resolved under a class suit without having to afford independent suits . It will also assist in decongesting the courts as hundreds or thousands of actions on the same subject matter can be litigated under one suit . I think that the practice should be consciously promoted by the leaders of the bar and bench , the academia and the public at large , as part of the demoralization of legal process . ”
On why ALF has decided to embark on lecture series , he said : “It has always been our model to give back to the society . So it is part of our corporate social responsibility programmes to embark on such a project. After this maiden edition , the aim is to hold it annually and the theme is not restricted to legal topics or issues . Similarly, the faculties and facilitators will cut across board . It will be an avenue to get top experts share their experiences on impactful topical issues . It will be a platform to promote national and global dialogues , which may sometimes assist in policy formulation and nation building . It is also an opportunity to host our high profile clients, colleagues and others to a luncheon . ”
Responding to what informed his choice of the theme, for the public lecture series and luncheon , which holds on Thursday , May 31 , 2018 , at Radisson Blu, Ozumba Mbadiwe, Victoria Island , the learned silk declared : “ The choice of theme for this maiden edition was influenced by its topicality and relevance across the broad spectrum of the business community and regulatory authorities and its overall impact to the economy , especially now that the Federal Government is making efforts to improve the country’ s Doing Business Index. A sound corporate governance culture is a measure of transparency , integrity and better management of resources and this helps to project a country as a conducive investment destination . Our nation is in dire need of economic growth through massive influx of Foreign Direct and Portfolio investments . ”
The faculty for the lecture is also very rich . They include Professor Pat Utomi , Mr . Dotun Sulaiman of Financial Reporting Council of Nigeria ( FRCN) as lead speaker , Ben Akabueze , DG, Budget Office of the Federation , Ms . Mary Uduk Acting DG of Security and Exchange Commission ( SEC ), Mr . Oscar Onyema CEO Nigerian Stock Exchange ( NSE) , Mr . Austin Avuru, MD /CEO SEPLAT Petroleum , Mr . Toyin Sani , CEO, United Capital Plc and Prof . Fabian Ajogwu SAN .
According to him , the theme of the lecture is quite topical and the personalities involved being passionate stakeholders are naturally interested in a discussion on contemporary issues and trends of Corporate Governance in Nigeria . His words : “ They appreciate its importance of our quest to grow the economy and improve our competitiveness at the global level . They must have seen it as a call to national duty , not just our effort as a Firm, and that is the only way to explain the convergence of such high powered panel of experts . ”

Sunday, 13 May 2018

A High Court sitting in Port Harcourt , Rivers State , has stopped the All Progressives Congress Local Government Congress earlier scheduled for Saturday, May 12 .
Justice Chiwendu Nwaogu gave the ruling in Port Harcourt on Friday after the Police quelled a riot by unknown persons within the court premises.
The riot led to a temporary closure of the State ’ s Judiciary Complex and the brutalisation of some journalists , litigants and lawyers by thugs around the court premises.
Senator Magnus Abbe ( APC) , representing Rivers South East Senatorial District in the Senate, had filed a motion on notice to stop the congress .
The motion followed a controversial ward congress on May 5 in the state .
The News Agency of Nigeria reports that the riot in the court complex was an attempt to stop the court session .
However , the Police responded by shooting into the air to disperse the rioters alleged to be supporters of a faction of APC in Rivers.
Many glass doors , windows and cars ’ windscreens were smashed in the court premises by the rioters who were alleged to have earlier locked all entrances to the court to stop the court from sitting .
Eyewitnesses told NAN that the padlocks were later destroyed to allow judicial workers into the premises.
Justice Chiwendu Nwaogu later sat to grant an order restraining the APC in the state from holding its local government congress scheduled for Saturday .
He also adjourned until June 26 for hearing.
Meanwhile , about 50 armed policemen have been deployed to maintain peace in the complex .
A Deputy Superintendent of Police and spokesman for the command , Mr . Nnamdi Omoni, confirmed the incident .
He also told NAN that Police personnel were on the field collecting detailed information on the incident .
“ Our men are still on the field collecting information about the incident , ” he said .

Monday, 7 May 2018

The Minister of Justice and Attorney-General of the Federation (AGF), Abubakar Malami, has expressed optimism that President Muhammadu Buhari would assent the Chartered Institute of Forensic and Investigative Auditors in Nigeria (CIFIA) Bill when it gets to his table.
Malami, who noted that the institute’s activities were in tandem with the anti-corruption fight of the Buhari administration, disclosed this when the CIFIA President, Dr. Victoria Enape, led a team from the institute on a courtesy visit to him in Abuja.
The AGF, who also expressed support for the body was also conferred with fellow of the institute.
According to Malami, “This, indeed, CIFIA is an association that the ministry will be keen and exceptionally interested in partnering in terms of collaboration, cooperation and working together fundamentally on three plans.
“CIFIA is an institute that is rooted in the fight against corruption; it is an institute that can help the federal government in tackling the menace of insurgency and it can help in rooting out elements of fraud in bureaucratic processes and administration.
“To that extent, we believe that collaboration with CIFIA will eventually pay off by way of engaging the services being provided by federal government and reduce corruption in governance.
“In relation to the pending bill, it the desire of the federal government, to see to the passage of the bill because of its immense contribution to breaking to associated leakages inherent in our system. The federal government will be readily available to support the bill and see to its assent in the context of national interest,” he said.
Malami said as far as the CIFIA Bill was concerned, the institute and the federal government shared things in common. He expressed appreciation for the fellowship award, saying it would boost his commitment to what CIFIA stood for as an institute.
The AGF also pledged to work towards issuing a letter of collaboration and endorsement to CIFIA as well as signing a Memorandum of Understanding with the institute on training the staff of the Ministry.
Enape, had earlier in her remark, said CIFIA had sought to identify with the AGF because of his sterling performance.
“We are the one of the world’s leading provider of anti-fraud organisation offering training and education, we offer opportunity for practical professionals to learn the basic that go beyond knowledge of accounting, auditing and finance. CIFIA strives to promote the need for transparency in advanced audit through certification, training, conferences and seminars in forensic auditing field.
“We carry out specialised fraud investigation by utilising using specialised forensic audit tools and equipment. Forensic auditors are mainly professionals from accounting background, lawyers, bankers, criminologists, cyber security experts among others.
“It is not limited to accountants; that is why we are unique. Our training cuts across all these areas. It cuts across investigation, auditing and accounting; it integrates accounting, auditing and investigative skills in resolving fraud cases.
“It encompasses litigation support, witness testimony, presentation of expert document that shows fraud- that is why this ministry if very important to the institute,” she said.
She had also solicited the support of the AGF on the CIFIA Bill which had gone through public hearing, collaboration with the Ministry of Justice, letter of endorsement and training agreement on forensic and investigative auditing.
A three-day training/induction of Professors and Doctors of Accounting/Other Executives into CIFIA ended yesterday in Abuja.

Sunday, 22 April 2018

The celebrated sex-for-grade scandal that rocked Ambrose Alli University, Ekpoma, Edo State, eight years ago, involving Engr. Peter Otubu, a lecturer in the Department of Electrical and Electronics of the institution and Miss Juliet Ivie Okosun has climaxed in the conviction of two siblings, Miss Judith Ivie Okosun and Juliet Obehi Okosun.
Chief Magistrate Martina Iluobe of Ekpoma Chief Magistrate Court, Esan West Local Government Area, last weekend sentenced the two former students who had since graduated from the institution to two years imprisonment, for unlawful detention and indecent assault of Dr. Otubu.
Delivering judgement in the case marked MEK/18C/2012, Iluobe recalled that Juliet Obehi Okosun (second accused person) had admitted in her evidence before the court that she had the key to the apartment where the first accused person, Judith Ivie Okosun, unlawfully assaulted Dr. Otubu.
The lecturer was held hostage and stripped Unclad at their one-room apartment in a private female hostel near the university on 17 July 2010.
The accused persons were also said to have made Dr. Otubu to issue a cheque in the sum of N100,000 in favour of Judith Ivie Okosun.
The court specifically established that in the recorded video clips which was also posted in the internet by one Oziengbe, now at large, the second accused person had told court that she was in possession of the key to the apartment where Engr. Otubu was held, making her liable for the unlawful detention of the lecturer.
Chief Magistrate Iluobe, however, discharged and acquitted the accused persons who were both undergraduate students at AAU at the time they were charged to court on counts 1, 5, and 6 which bothered on conspiracy and stealing and frivolous petition against Engr. Otubu, following the failure of the prosecution to prove these beyond reasonable doubt.
It also discharged and acquitted the 3rd to 7th accused persons, Esther Ogbeide (21), Samson Ogbeide (32), Igbudu Samuel (42), Ojeabulu Eghosa Clement (37) and Aruya Ohis Williams (24) for lack of substantial evidence against them.
According to the court, the failure of Mobile Telecommunications Network (MTN), to provide calls log of conversations between the first Principal Witness (Engr. Iluobe) and some of the accused persons as required by the prosecution to prove his case was fatal to the prosecution.
Chief Magistrate Iluobe tongue-lashed Engr. Otubu, saying he “suffered for the sin of immorality to have gone to the room of her student which resulted in the show of shame, humiliation and torture which left his career in ruins.
“This court is of the view that there is a very strong conspiracy and set up against Engr. Peter Otubu, even though the defense Counsel had submitted before the court that suspicion does not amount to conspiracy.
”Throughout the length and breadth of the case, there is a thread which runs through criminal procedure of the case against the accused persons.
“Therefore, I hold that count 1 has not been proved as required by the law. For count 2, the the first and second accused persons had testified that the allegations were communicated to the school authorities about the show of shame.
“I believe them in this, because judging from the position of the the Principal Witness (PW1) and the first accused person, the whole truth was found and doctored. Such situation is highly embarrassing to him as a lecturer, his family and the university community.”
Responding to the judgment, counsel to the defendants, Mr. Olayowola Afolabi, agreed with the judgement on the sexual promiscuity of PW1, describing it as “a show of shame.”
But he pleaded with the court for clemency for the convicted persons on the ground that they were first offenders, stressing that the second convict is a nursing mother.
“The first accused person, my lord, is about to get married. I had to plead with the husband to allow her to come to court.
“My lord, the first and second accused persons were first offenders. My lord also has the option to caution the convicts in view of the circumstances. My lord is a woman who knows where the shoe is pinching us.
“So, my lord, I am pleading. Literally, my lord, I am on my knees. It is a show of shame for the lecturer to come to the house of his student”.
Following the pleading from the counsel to the defendants, Chief Magistrate Iluobe handed down an option of fine to the first and second accused persons in lieu of imprisonment.
Engr. Otubu who was highly elated, said the judgement has vindicated him.
“I am okay. The principal suspect, Ivie Okosun and her sister, Juliet Obehi Okosun, have been convicted and jailed, whether they were given an option of fine or not.
“To correct the erroneous impression that I was dismissed, I was never dismissed from AAU. My appointment was terminated following the video that was posted on the Internet,” he said.

Saturday, 14 April 2018

A Global Research Fellow , International Center for Not for profit Law ( ICNL ) Washington DC, Solomon Okedara has criticized the Federal Government for releasing what he described as a political looters list.
The Lagos based legal practitioner in a statement lamented that the Federal Government ignored the decision of a Federal High Court , Lagos on July 2017 which ordered them to release to Nigerians information about the names of high ranking public officials from whom public funds were recovered and the circumstances under which such funds were recovered , as well as the exact amount of funds recovered from each public official .
According to him , the Attorney General of the Federation , Mr . Abubakar Malami ( SAN ) , shortly after the judgment , declared that the Federal Government should publish the names of treasury looters intermittently after it must have met some conditions.
He noted that the wait for the names has been a mirage as nothing has happened for about nine months now until the list released by the Information Minister Lai Mohammed .
“ Clearly , the lists released by the information minister appear to serve a political purpose only . Apparently , it came as a response to a remark by the leadership of the People’ s Democratic Party (PDP ) that the Federal Government should go beyond mere rhetoric and media war in labeling the officials of past government as ‘ looters ’ but to specifically name the looters .
“ If it took the Federal Government less than 24 hours to respond to PDP via a Press conference with a list of ‘ looters ’ , one then wonders why has the same Federal government been unable to give effect to the judgment of a court of competent jurisdiction .
“ Why does a name like Orji Kalu who is still standing trial for corruption charges is missing on the list ? Is there a connection between his defection to APC and non -inclusion of his name on the list? How serious does the government take its institutions?
Civil rights lawyer , Mr . Emeka Nwadioke has advised the Lagos state House of Assembly to “ urgently repeal ” the controversial land use charge law 2018 .
In a statement at the weekend, Nwadioke described the LUC law as “ unconstitutional, ” noting that the law is in breach of the 1999 constitution.
“ The land use charge law 2018 as presently enacted is in clear breach of article 1 ( j) of the fourth schedule to the 1999 constitution , ” said nwadioke who is also a member of the Nigerian Bar Association (NBA ) criminal justice reform committee.
“ The schedule, pursuant to section 7 ( 5 ) of the constitution , unequivocally vests the assessment of privately owned houses or tenements for the purpose of levying rates on the Local government , ” he said .
“ While we have taken notice of the remark by the speaker of the Lagos State House of assembly that ‘ the ( LUC ) law was all about increasing the revenue generation of the state , ” Nwadioke said “ it is unthinkable and highly worrisome that a duly constituted group of lawmakers sworn on the constitution would contemplate such brazen undermining of the same constitution merely in a quest to shore up internally generated revenue . ”
According to him , all lovers of democracy and rule of law must rise in defence of the Nigerian constitution from this latest onslaught .
The cavalier manner in which the lawmakers have treated the Nigerian constitution , he said , is unacceptable .
“ No amount of legislative gymnastics can alter the right exclusively vested by the constitution in the Local government to levy tenement rates .
“ It is heart - warming that the Nigerian Supreme Court had in Knight Frank Rutley Nigeria v Attorney General of Kano state ( 1998 ) 4 sc 251 upheld this unambiguous provision of the constitution . The same is true of the Rivers State High Court in Grinaker Ita limited v board of internal revenue ( suit phc / 2842 /2010 ) .

Saturday, 24 March 2018

The Supreme Court on Friday dismissed an appeal by the Ondo State Governor, Oluwarotimi Akeredolu, for lack of merit.
Akeredolu had, by the appeal, challenged a July 20017 judgment of the Court of Appeal, Abuja, which upheld an order by a Federal High Court in Abuja, granting permission to Olusegun Abraham to serve Akeredolu through substituted means, court documents in relation to the suit he (Abraham) filed.
Abraham’s suit is challenging the outcome of the primary of the All Progressives Congress (APC), which produced Akeredolu as the party’s candidate for the last governorship election in Ondo State.
In a unanimous judgment, a five-man panel of the Supreme Court held that Akeredolu’s appeal was without merit.
Justice John Okoro, in the lead judgment, but read by Justice Ejembi Eko, upheld the earlier decision of the Court of Appeal and awarded N500,000 cost against Akeredolu, in favour of Abraham.

Monday, 19 March 2018

Representative Actions
There are situation where a person or group of persons may want to sue, or a person may want to sue someone else but neither of the above categories possesses the capacity to sue or be sued. Such suits must be instituted by or against some other persons who have the legal capacity to sue and be sued, on behalf of such persons lacking capacity. Needs leave of the Ct to bring such an action and a consent order authorising the few to represent them
Order 10 rule 8 Abuja: Where more persons than one have the same interest in one suit, one or more of them may, with the approval of the Court, be authorised by the other persons interested to sue or to defend the suit on behalf of all parties.
Order 13 rule 12 Lagos: Where there are numerous person having the same interest in one suit, one or more of such persons may sue or be sued on behalf of or for the benefit of all persons so interested. Where there are numerous persons having the same interest in one suit and they seek to defend the action, a Judge may allow one or more of such persons to defend the action on behalf or for the benefit of all persons so interested.
Example:
Ojo Madu, Dupe Wazobia suing for and on behalf of themselves and the WAZOBIA FAMILY as Defendants

Procedure:
The representatives must be appointed by those to be represented
The representatives will seek the leave of the Court to sue as such via a Motion Ex parte supported with an affidavit exhibiting the memorandum signed by a majority of members authorising the representation and a written address. The content of the Affidavit in support will disclose the names of the representatives, when appointed and the believe that they can represent the group.

The Conditions for a Representative Action are:
a. Common interest and grievance of all the persons sought to be represented
b. The reliefs sought must be beneficial to all represented.
See ATANDA V. OLAREWAJU

Tuesday, 6 March 2018

Pleadings are written statements or allegations of the parties in an action begun by WRIT OF SUMMONS AT THE HIGH COURT setting out in summary form the particulars of the materials facts on which each party relies for his claim or defence.
No definition of pleadings in statute. Only cases give the definition of pleadings – sets out material facts in dispute. A brief summary of each parties case: Ascertainment of disputes btw the parties and those with which there is agreement btw them – Mobil v LASEPA. Pleadings are peculiar to actions started by way of writ. Pleadings are for actions in the High Ct. It is briefs in the Ct of Appeal
ORDER 23 ABUJA; ORDER 15 LAGOS

RELATIONSHIP BETWEEN WRIT OF SUMMONS AND PLEADINGS
Writ of summons ordinarily does not form part of pleadings-LEWIS V. PARKER
A Writ of Summons may qualify as a pleading if it is specially endorsed.
However, once a statement of claim is filed, it SUPERCEDES the writ. Any statement in the writ not in the Statement of Claim is deemed abandoned.
Where a Statement of Claim refers to the writ. BOTH MUST BE READ TOGETHER.

FUNCTIONS OF PLEADINGS
Pleadings define and ascertain the various matters in dispute between the parties and those upon which they are agreed. HIGHGRADE MARITIME LTD V. FBN LTD.
Pleadings serve as a notice to the other party as to what to expect and thus forestalls the springing of surprises thus saving time and cost. GEORGE V. DOMINION FLOUR MILLS LTD.
They serve as a guide to the court as to the precise matters to decide between the parties.
Pleadings constitute a permanent record of the issues and questions raised and determined between the parties and constitute public record.
Pleadings show on whom the burden of proof lies on the respective issues raised-BAKARE V. ACB LTD.
It aids the parties to determine the proper approach to the opponents’ case. A party may upon the pleadings apply for judgment upon admission –
Order 28 Rule 3 (ABJ); Order 19 Rule 4 (LAG)
Determines the evidential burden and shows where the burden of proof must lie

CONTENTS OF PLEADINGS
These are the cardinal rules as to what the pleadings should contain or should not contain.
0rder 23 Rule 4 Abuja Rules 2004;
0rder 15- Order 19 Lagos Rules 2012
AGU V.IKEWIBE
1. Every pleading must contain only material facts. The material facts are those facts essential to the party’s case. BRUCE V. ODHAM’S PRESS LTD.
2. Pleadings must not CONTAIN EVIDENCE but shall contain facts by which the evidence is shown.
3. A party is not allowed to PLEAD LAW OR LEGAL ARGUMENTS OR CONCLUSIONS. OBIJULU V. OZIM EXCEPT Where the point of law pleaded will dispose of the entire action-MARTINS V. FED ADMINISTRATOR GENERAL
4. The facts must be stated precisely, positively, distinctly and briefly
5. Pleadings must contain relief sought or prayers.

FORMAL REQUIREMENTS OF PLEADINGS
1a. Pleadings should be printed, have the heading of the court, suit No., parties title.
  b. Introduction ⇒ introduces the parties in a statement of claim; states the general traverse in a statement of defence.
  c. The body ⇒ facts which gave rise to the suit
  d. The relief/prayer part
  e. Pleadings must be dated
  f. Signature of the claimant’s counsel or the claimant himself – SLB Consortium v NNPC (legal practitioner should sign the document in the name he is called to the bar), before adding the firm’s name, then state plaintiff or defendant’s counsel
 g. Address of defendant or claimant for service
2. Pleadings are arranged in paragraphs and numbered consecutively
a. The paragraphs should be written in a chronological order
b. Avoid the use of pronouns
c. There must be consistency in the nomenclature e.g. Deed of lease. This is so as to avoid confusion or ambiguity
d. Dates, sums and numbers shall be written in figures and not words. However, 0rder 23 Rule 4(2) Abuja permits the expression of these items in words too).
NB: when documents are pleaded, there is no need to state that the document is hereby attached as Exhibit A. Just state that the document will be relied on at trial. This is because unlike affidavits, pleadings do not constitute evidence.