On the 30th of August, 2021, the Chief Justice of Nigeria (as he then was), His Lordship, Muhammed Tanko summoned six Chief Judges for issuing different and conflicting judgements from their courts. The then Chief Justice of Nigeria, who, by the virtue of that position, serves as the Chairman of the National Judicial Council (NJC), was said to have been completely embarrassed by the development. The perceived attempt at judicial rascality was later forwarded to the National Judicial Council (NJC), a statutory body responsible for the promotion and discipline of judicial officers.
In a similar vein, Chief Wole Olanipekun SAN –the distinguished lawyer and incumbent Chairman of the Body of Benchers– had on October 19, 2022, at the valedictory court session held in honour of Justice Mojeed Owoade who retired as Court of Appeal Justice, described as “worrisome” the disturbing trend of conflicting decisions of the Court of Appeal and the Supreme Court. In his words:
There is no gainsaying the fact that nowadays, our appellate courts give conflicting decisions at very regular intervals, thus throwing the profession into confusion. More particularly so, when those conflicting decisions interfere with and derail the agelong doctrine of ‘stare decisis’.
The learned silk conclusively added that the conflicting judgements significantly obstructed lawyers’ ability to effectively predict the position of the law in the delivery of legal opinions for clients.
In the face of this seeming judicial haphazardry, this article attempts to shed light on the relevance, judicial hierarchy and precedence and the position of law on such conflicting judgements, especially if the lower courts were to follow and apply such judgements in subsequent instances.
𝗜𝗡𝗧𝗥𝗢𝗗𝗨𝗖𝗧𝗜𝗢𝗡
The doctrine of judicial precedent simply emphasizes the established standard whereby judges of lower courts are to follow and apply the decisions of higher courts on decided cases where the facts are of sufficient similarity to the present case before the court. In 𝙲𝙻𝙴𝙼𝙴𝙽𝚃 𝚟. 𝙸𝚆𝚄𝙰𝙽𝚈𝙰𝙽𝚆𝚄, the Supreme Court, per Oputa, JSC held:
“𝘈 𝘱𝘳𝘦𝘤𝘦𝘥𝘦𝘯𝘵 𝘪𝘴 𝘢𝘯 𝘢𝘥𝘫𝘶𝘥𝘨𝘦𝘥 𝘤𝘢𝘴𝘦 𝘰𝘳 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯 𝘰𝘧 𝘢 𝘩𝘪𝘨𝘩𝘦𝘳 𝘤𝘰𝘶𝘳𝘵 𝘤𝘰𝘯𝘴𝘪𝘥𝘦𝘳𝘦𝘥 𝘢𝘴 𝘧𝘶𝘳𝘯𝘪𝘴𝘩𝘪𝘯𝘨 𝘢𝘯 𝘦𝘹𝘢𝘮𝘱𝘭𝘦 𝘰𝘳 𝘢𝘶𝘵𝘩𝘰𝘳𝘪𝘵𝘺 𝘧𝘰𝘳 𝘢𝘯 𝘪𝘥𝘦𝘯𝘵𝘪𝘤𝘢𝘭 𝘰𝘳 𝘴𝘪𝘮𝘪𝘭𝘢𝘳 𝘲𝘶𝘦𝘴𝘵𝘪𝘰𝘯 𝘢𝘧𝘵𝘦𝘳𝘸𝘢𝘳𝘥𝘴 𝘢𝘳𝘪𝘴𝘪𝘯𝘨 𝘰𝘯 𝘴𝘪𝘮𝘪𝘭𝘢𝘳 𝘲𝘶𝘦𝘴𝘵𝘪𝘰𝘯 𝘰𝘧 𝘭𝘢𝘸.”
In practice, this means that inferior courts are bound to apply the legal principles set down by superior courts in earlier cases. This provides consistency and substantial predictability on the position of law on certain issues or causes of action. In fact, the doctrine mandates the strict application of the decisions of the higher courts, no matter the purported level of ingenuity and wit professed by the lower courts (See 𝙴𝙼𝙴𝙻𝚄𝚆𝙰 𝚟. 𝙾𝙽𝚄𝙸𝙶𝚆𝙴 (2011) 13 𝙽𝚆𝙻𝚁 𝙿𝚝.1265 𝙲𝙰). Such is the significance of the doctrine that even the Supreme Court held that lower courts are inexcusably expected to follow the decisions of the higher courts however wrong they are and whatever injustice they may inflict. (See 𝙽𝙰𝚃𝙸𝙾𝙽𝙰𝙻 𝙴𝙻𝙴𝙲𝚃𝚁𝙸𝙲 𝙿𝙾𝚆𝙴𝚁 𝙰𝚄𝚃𝙷𝙾𝚁𝙸𝚃𝚈 𝚟. 𝙾𝙽𝙰𝙷 (1997) 1 NWLR (Pt. 484) Page 680 at 688 𝚂𝙲).
However, what happens when a lower court is faced with two conflicting judgements of a superior court of equal jurisdiction? In practice, which decision will the High Court apply when faced with two conflicting judgements of the Court of Appeal? In a similar vein, which decision will the Court of Appeal adopt and follow when two conflicting decisions of the Supreme Court are presented before it?
𝗟𝗘𝗚𝗔𝗟 𝗦𝗖𝗥𝗨𝗧𝗜𝗡𝗬
The issue in this regard was put to rest by the Supreme Court in the case of 𝙾𝚂𝙰𝙺𝚄𝙴 𝚟. 𝙵𝙴𝙳𝙴𝚁𝙰𝙻 𝙲𝙾𝙻𝙻𝙴𝙶𝙴 𝙾𝙵 𝙴𝙳𝚄𝙲𝙰𝚃𝙸𝙾𝙽, where His Lordship, Ogbuagu, JSC held:
…𝘍𝘰𝘳 𝘵𝘩𝘦 𝘶𝘮𝘱𝘵𝘦𝘦𝘯𝘵𝘩 𝘵𝘪𝘮𝘦, 𝘸𝘩𝘦𝘳𝘦 𝘵𝘩𝘦𝘳𝘦 𝘢𝘱𝘱𝘦𝘢𝘳 𝘵𝘰 𝘣𝘦 𝘤𝘰𝘯𝘧𝘭𝘪𝘤𝘵𝘪𝘯𝘨 𝘫𝘶𝘥𝘨𝘦𝘮𝘦𝘯𝘵𝘴 𝘰𝘧 𝘵𝘩𝘪𝘴 𝘊𝘰𝘶𝘳𝘵, 𝘵𝘩𝘦 𝘭𝘢𝘵𝘦𝘳 𝘰𝘳 𝘭𝘢𝘵𝘦𝘴𝘵 𝘸𝘪𝘭𝘭 𝘰𝘳 𝘴𝘩𝘰𝘶𝘭𝘥 𝘢𝘱𝘱𝘭𝘺 𝘢𝘯𝘥 𝘮𝘶𝘴𝘵 𝘣𝘦 𝘧𝘰𝘭𝘭𝘰𝘸𝘦𝘥 𝘪𝘧 𝘵𝘩𝘦 𝘤𝘪𝘳𝘤𝘶𝘮𝘴𝘵𝘢𝘯𝘤𝘦𝘴 𝘢𝘳𝘦 𝘵𝘩𝘦 𝘴𝘢𝘮𝘦.
The Court of Appeal, in its elaborate position in regard to the subject matter, held in 𝙲𝙱𝙽 𝚟. 𝚉𝙰𝙺𝙰𝚁𝙸, thus:
𝘛𝘩𝘦 𝘭𝘢𝘸 𝘸𝘰𝘶𝘭𝘥 𝘢𝘱𝘱𝘦𝘢𝘳 𝘵𝘰 𝘣𝘦 𝘴𝘦𝘵𝘵𝘭𝘦𝘥 𝘵𝘩𝘢𝘵 𝘢 𝘊𝘰𝘶𝘳𝘵 𝘣𝘦𝘭𝘰𝘸 𝘵𝘩𝘪𝘴 𝘊𝘰𝘶𝘳𝘵 𝘤𝘢𝘯𝘯𝘰𝘵 𝘰𝘯 𝘪𝘵𝘴 𝘰𝘸𝘯, 𝘦𝘭𝘦𝘤𝘵 𝘵𝘰 𝘤𝘩𝘰𝘰𝘴𝘦 𝘸𝘩𝘪𝘤𝘩 𝘰𝘯𝘦 𝘰𝘧 𝘵𝘩𝘦 𝘤𝘰𝘯𝘧𝘭𝘪𝘤𝘵𝘪𝘯𝘨 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯𝘴, 𝘰𝘳 𝘱𝘦𝘳𝘤𝘦𝘪𝘷𝘦𝘥 𝘤𝘰𝘯𝘧𝘭𝘪𝘤𝘵𝘪𝘯𝘨 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯𝘴 𝘰𝘧 𝘵𝘩𝘪𝘴 𝘊𝘰𝘶𝘳𝘵, 𝘪𝘵 𝘪𝘴 𝘵𝘰 𝘧𝘰𝘭𝘭𝘰𝘸. 𝘛𝘩𝘪𝘴 𝘪𝘴 𝘫𝘶𝘴𝘵 𝘢𝘴 𝘵𝘩𝘪𝘴 𝘊𝘰𝘶𝘳𝘵 𝘢𝘯𝘥 𝘪𝘯𝘥𝘦𝘦𝘥 𝘢𝘯𝘺 𝘰𝘵𝘩𝘦𝘳 𝘴𝘶𝘣𝘰𝘳𝘥𝘪𝘯𝘢𝘵𝘦 𝘊𝘰𝘶𝘳𝘵 𝘪𝘯 𝘵𝘩𝘦 𝘫𝘶𝘥𝘪𝘤𝘪𝘢𝘭 𝘩𝘪e𝘳𝘢𝘳𝘤𝘩𝘺 𝘰𝘧 𝘵𝘩𝘪𝘴 𝘤𝘰𝘶𝘯𝘵𝘳𝘺 𝘩𝘢𝘷𝘦 𝘯𝘰 𝘱𝘰𝘸𝘦𝘳 𝘵𝘰 𝘦𝘭𝘦𝘤𝘵 𝘸𝘩𝘪𝘤𝘩 𝘰𝘯𝘦 𝘰𝘶𝘵 𝘰𝘧 𝘢𝘯𝘺 𝘤𝘰𝘯𝘧𝘭𝘪𝘤𝘵𝘪𝘯𝘨 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘚𝘶𝘱𝘳𝘦𝘮𝘦 𝘊𝘰𝘶𝘳𝘵, 𝘪𝘵 𝘸𝘪𝘭𝘭 𝘰𝘳 𝘴𝘩𝘰𝘶𝘭𝘥 𝘧𝘰𝘭𝘭𝘰𝘸. 𝘛𝘩𝘦 𝘚𝘶𝘱𝘳𝘦𝘮𝘦 𝘊𝘰𝘶𝘳𝘵 𝘩𝘢𝘴 𝘮𝘢𝘥𝘦 𝘪𝘵 𝘢𝘣𝘶𝘯𝘥𝘢𝘯𝘵𝘭𝘺 𝘤𝘭𝘦𝘢𝘳 𝘵𝘩𝘢𝘵 𝘪𝘯 𝘭𝘪𝘯𝘦 𝘸𝘪𝘵𝘩 𝘵𝘩𝘦 𝘱𝘳𝘪𝘯𝘤𝘪𝘱𝘭𝘦 𝘰𝘧 𝘴𝘵𝘢𝘳𝘦 𝘥𝘦𝘤𝘪𝘴𝘪𝘴 𝘢𝘯𝘥 𝘴𝘵𝘳𝘪𝘤𝘵 𝘳𝘦𝘤𝘰𝘨𝘯𝘪𝘵𝘪𝘰𝘯 𝘰𝘧 𝘪𝘵𝘴 𝘴𝘶𝘱𝘳𝘦𝘮𝘢𝘤𝘺 𝘢𝘴 𝘪𝘵 𝘸𝘦𝘳𝘦, 𝘵𝘩𝘪𝘴 𝘊𝘰𝘶𝘳𝘵 𝘮𝘶𝘴𝘵 𝘧𝘰𝘭𝘭𝘰𝘸 𝘪𝘵𝘴 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯 𝘵𝘩𝘢𝘵 𝘪𝘴 𝘭𝘢𝘵𝘦𝘳 𝘪𝘯 𝘵𝘪𝘮𝘦 𝘪𝘯 𝘵𝘩𝘦 𝘦𝘷𝘦𝘯𝘵 𝘢𝘯𝘺 𝘰𝘧 𝘪𝘵𝘴 𝘤𝘰𝘯𝘧𝘭𝘪𝘤𝘵𝘪𝘯𝘨 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯𝘴 𝘢𝘳𝘦 𝘱𝘭𝘢𝘤𝘦𝘥 𝘣𝘦𝘧𝘰𝘳𝘦 𝘵𝘩𝘪𝘴 𝘊𝘰𝘶𝘳𝘵 𝘪𝘯 𝘳𝘦𝘴𝘱𝘦𝘤𝘵 𝘰𝘧 𝘢𝘯𝘺 𝘮𝘢𝘵𝘵𝘦𝘳 𝘪𝘯 𝘤𝘰𝘯𝘵𝘦𝘯𝘵𝘪𝘰𝘯 𝘣𝘦𝘧𝘰𝘳𝘦 𝘪𝘵” (See also 𝙲𝙱𝙽 𝚟. 𝙾𝙺𝙾𝙹𝙸𝙴 (2015) 14 𝙽𝚆𝙻𝚁 (𝙿𝚝.1479) 239 𝙿.263 𝚙𝚊𝚛𝚊 𝙶. 𝚂𝙲)
To put it more succinctly, the Court of Appeal, in the case of 𝙶𝙻𝙰𝚇𝙾 𝚂𝙼𝙸𝚃𝙷𝙺𝙻𝙸𝙽𝙴 𝙿𝙻𝙲 𝚟. 𝙰𝙻𝙸 𝚉𝙰𝙺𝙰𝚁𝙸 𝙹𝙸𝚈𝙰, further held thus:
…𝘪𝘵 𝘪𝘴 𝘢𝘯 𝘦𝘴𝘵𝘢𝘣𝘭𝘪𝘴𝘩𝘦𝘥 𝘱𝘳𝘪𝘯𝘤𝘪𝘱𝘭𝘦 𝘰𝘧 𝘭𝘢𝘸 𝘵𝘩𝘢𝘵 𝘸𝘩𝘦𝘯 𝘵𝘩𝘪𝘴 𝘊𝘰𝘶𝘳𝘵 𝘪𝘴 𝘧𝘢𝘤𝘦𝘥 𝘸𝘪𝘵𝘩 𝘵𝘸𝘰 𝘤𝘰𝘯𝘧𝘭𝘪𝘤𝘵𝘪𝘯𝘨 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘚𝘶𝘱𝘳𝘦𝘮𝘦 𝘊𝘰𝘶𝘳𝘵 𝘪𝘯 𝘢𝘯 𝘪𝘴𝘴𝘶𝘦, 𝘵𝘩𝘦 𝘊𝘰𝘶𝘳𝘵 𝘪𝘴 𝘣𝘰𝘶𝘯𝘥 𝘵𝘰 𝘧𝘰𝘭𝘭𝘰𝘸 𝘵𝘩𝘦 𝘭𝘢𝘵𝘦𝘴𝘵. 𝘛𝘩𝘪𝘴 𝘪𝘴 𝘴𝘰 𝘣𝘦𝘤𝘢𝘶𝘴𝘦 𝘵𝘩𝘦 𝘚𝘶𝘱𝘳𝘦𝘮𝘦 𝘊𝘰𝘶𝘳𝘵 𝘩𝘢𝘴 𝘢𝘯 𝘪𝘯𝘩𝘦𝘳𝘦𝘯𝘵 𝘱𝘰𝘸𝘦𝘳 𝘵𝘰 𝘰𝘷𝘦𝘳𝘳𝘶𝘭𝘦 𝘪𝘵𝘴𝘦𝘭𝘧. 𝘐𝘧 𝘵𝘩𝘦 𝘭𝘢𝘵𝘦𝘴𝘵 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯 𝘪𝘴 𝘪𝘯 𝘤𝘰𝘯𝘧𝘭𝘪𝘤𝘵 𝘸𝘪𝘵𝘩 𝘵𝘩𝘦 𝘦𝘢𝘳𝘭𝘪𝘦𝘳 𝘰𝘯𝘦, 𝘪𝘵 𝘧𝘰𝘭𝘭𝘰𝘸𝘴 𝘵𝘩𝘢𝘵 𝘵𝘩𝘦 𝘭𝘢𝘵𝘦𝘴𝘵 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯 𝘩𝘢𝘴 𝘰𝘷𝘦𝘳𝘳𝘶𝘭𝘦𝘥 𝘵𝘩𝘦 𝘦𝘢𝘳𝘭𝘪𝘦𝘳 𝘰𝘯𝘦.
Based on the foregoing, can it then be safely held that the previous decision that the latest decision has overruled is completely useless or nugatory? Also, can it be held that the decisions that were made on the basis of the overruled decision are vitiated or automatically nullified? It would not seem so.
In fact, the Court has held that the overruled decisions of the higher courts should not be treated with disdain but with respect. The Court would further posit, in the case of 𝙲𝙷𝚁𝙸𝚂𝚃𝙾𝙿𝙷𝙴𝚁 𝚟. 𝙼𝚄𝙾𝙱𝙸𝙺𝙴, thus:
𝘞𝘩𝘦𝘯 𝘵𝘩𝘦 𝘚𝘶𝘱𝘳𝘦𝘮𝘦 𝘊𝘰𝘶𝘳𝘵 𝘥𝘦𝘱𝘢𝘳𝘵𝘴 𝘧𝘳𝘰𝘮 𝘪𝘵𝘴 𝘦𝘢𝘳𝘭𝘪𝘦𝘳 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯 𝘰𝘯 𝘢 𝘱𝘰𝘪𝘯𝘵, 𝘵𝘩𝘦 𝘥𝘦𝘱𝘢𝘳𝘵𝘶𝘳𝘦 𝘥𝘰𝘦𝘴 𝘯𝘰𝘵 𝘰𝘱𝘦𝘳𝘢𝘵𝘦 𝘵𝘰 𝘨𝘦𝘯𝘦𝘳𝘢𝘭𝘭𝘺 𝘰𝘷𝘦𝘳𝘳𝘶𝘭𝘦 𝘢𝘯𝘥 𝘯𝘶𝘭𝘭𝘪𝘧𝘺 𝘢𝘭𝘭 𝘱𝘳𝘦𝘷𝘪𝘰𝘶𝘴 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯𝘴 𝘵𝘩𝘢𝘵 𝘧𝘰𝘭𝘭𝘰𝘸𝘦𝘥 𝘵𝘩𝘦 𝘦𝘢𝘳𝘭𝘪𝘦𝘳 𝘥𝘦𝘤𝘪𝘴𝘪𝘰𝘯 𝘪𝘵 𝘩𝘢𝘴 𝘥𝘦𝘱𝘢𝘳𝘵𝘦𝘥 𝘧𝘳𝘰𝘮. 𝘛𝘩𝘦 𝘥𝘦𝘱𝘢𝘳𝘵𝘶𝘳𝘦 𝘴𝘦𝘳𝘷𝘦𝘴 𝘵𝘰 𝘤𝘩𝘢𝘳𝘵 𝘢 𝘯𝘦𝘸 𝘥𝘪𝘳𝘦𝘤𝘵𝘪𝘰𝘯 𝘵𝘰 𝘣𝘦 𝘧𝘰𝘭𝘭𝘰𝘸𝘦𝘥 𝘸𝘪𝘵𝘩𝘰𝘶𝘵 𝘢𝘧𝘧𝘦𝘤𝘵𝘪𝘯𝘨 𝘵𝘩𝘦 𝘱𝘳𝘦𝘷𝘪𝘰𝘶𝘴 𝘴𝘵𝘢𝘵𝘶𝘴 𝘲𝘶𝘰.
Emphasising the position of law in regard to the consequential part of overruled judgements, the Court held further:
“𝘛𝘩𝘦 𝘨𝘦𝘯𝘦𝘳𝘢𝘭 𝘱𝘳𝘪𝘯𝘤𝘪𝘱𝘭𝘦 𝘰𝘧 𝘭𝘢𝘸 𝘪𝘴 𝘵𝘩𝘢𝘵 𝘢 𝘤𝘩𝘢𝘯𝘨𝘦 𝘪𝘯 𝘭𝘢𝘸 𝘥𝘰𝘦𝘴 𝘯𝘰𝘵 𝘳𝘦𝘴𝘶𝘭𝘵 𝘪𝘯 𝘵𝘩𝘦 𝘯𝘶𝘭𝘭𝘪𝘧𝘪𝘤𝘢𝘵𝘪𝘰𝘯 𝘰𝘧 𝘳𝘪𝘨𝘩𝘵𝘴 𝘢𝘯𝘥 𝘪𝘯𝘵𝘦𝘳𝘦𝘴𝘵𝘴 𝘣𝘢𝘴𝘦𝘥 𝘰𝘯 𝘵𝘩𝘦 𝘱𝘳𝘦𝘷𝘪𝘰𝘶𝘴 𝘭𝘢𝘸. 𝘖𝘯 𝘵𝘩𝘦 𝘣𝘢𝘴𝘪𝘴 𝘰𝘧 𝘵𝘩𝘪𝘴 𝘨𝘦𝘯𝘦𝘳𝘢𝘭 𝘱𝘳𝘪𝘯𝘤𝘪𝘱𝘭𝘦, 𝘪𝘵 𝘪𝘴 𝘵𝘩𝘦 𝘭𝘢𝘸 𝘱𝘳𝘦𝘷𝘢𝘪𝘭𝘪𝘯𝘨 𝘢𝘵 𝘵𝘩𝘦 𝘵𝘪𝘮𝘦 𝘵𝘩𝘦 𝘳𝘪𝘨𝘩𝘵 𝘰𝘳 𝘪𝘯𝘵𝘦𝘳𝘦𝘴𝘵 𝘢𝘤𝘤𝘳𝘶𝘦𝘥 𝘰𝘳 𝘢𝘵 𝘵𝘩𝘦 𝘵𝘪𝘮𝘦 𝘢 𝘴𝘪𝘵𝘶𝘢𝘵𝘪𝘰𝘯 𝘢𝘳𝘰𝘴𝘦 𝘢𝘯𝘥 𝘯𝘰𝘵 𝘵𝘩𝘦 𝘯𝘦𝘸 𝘭𝘢𝘸 𝘵𝘩𝘢𝘵 𝘥𝘦𝘵𝘦𝘳𝘮𝘪𝘯𝘦𝘴 𝘪𝘵𝘴 𝘷𝘢𝘭𝘪𝘥𝘪𝘵𝘺.” (𝘚𝘶𝘱𝘳𝘢)
𝗖𝗢𝗡𝗖𝗟𝗨𝗦𝗜𝗢𝗡
In recognition of the summation of all aforementioned points and expatriation of judicial rulings expressed herein, it can be tenably held and substantially deduced that the position of law is crystal clear that should there be an instance of conflicting judgments of Courts of equal jurisdiction, the decision that is latter in time prevails, hence, such decision would and must be applied by lower courts of record.
In addendum, it is also important to note that the decisions reached on the basis of the overruled judgements are not vitiated or nullified by the later decision that takes precedence over it.
***
𝗢𝗸𝗶 𝗔𝗹-𝗛𝗮𝘀𝘀𝗮𝗻 𝗩𝗶𝗰𝘁𝗼𝗿, popularly known as 𝘈𝘮𝘣𝘪𝘥𝘦𝘹𝘵𝘳𝘰𝘶𝘴, is an undergraduate at the Faculty of Law, Adekunle Ajasin University, Akungba Akoko. He can be reached via okihassanvictor@gmail.com
Editor’s note: This op-ed was published with minimal editing to preserve author’s original intent.
𝐑𝐄𝐅𝐄𝐑𝐄𝐍𝐂𝐄𝐒
Ejekwonyilo, A. (August 30, 2021). Conflicting Court Orders: CJN summons six Chief Judges, NBA laments. Premium Times. https://www.premiumtimesng.com/news/headlines/482106-conflicting-court-orders-cjn-summons-six-chief-judges-nba-laments.html
Vanguard (October 11, 2022). Appellate Courts’ conflicting decisions worrisome, says Olanipekun. Vanguard. https://www.vanguardngr.com/2022/10/appellate-courts-conflicting-decisions-worrisome-says-olanipekun/
- CLEMENT & ANOR V. IWUANYANWU & ANOR. (1989) NWLR (Pt.107) 39 (1989) 4 SC Pt II 89
- Osakue v. Federal College of Education (Technical) Asaba 2010 5 SCM 185
- Glaxo Smithkline Plc v. Ali Zakari Jiya (2014) LPELR-22902(CA)
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