Tuesday, 22 March 2022

FreelanceEconomy.NG How Does It Work?

 Https://FreelanceEconomy.NG How Does It Work?


https://FreelanceEconomy.ng (or Freelance Economy) is an opportunity sharing platform where Nigerian freelancers make money by solving every day business problems for Nigerian business owners 


Is Freelance Economy Legit?

It is an open platform where business owners post different gigs, part time jobs and deals, (depending on their needs) while freelancers make money every day by doing these gigs for a flat fee or a commission. It is 100% legit


What Kind of Deals and Jobs Are on Freelance Economy?

Users typically post a wide range of opportunities on the platform, depending on the needs of the business owner. Some businesses need freelancers that can bring in buyers for their products, some need freelancers that can bring in more users to their platform, while some are looking for part-time people to hire 


Transaction Example

For example, a car dealer puts up a post offering 100k to anyone who can quickly find a buyer for his car. One of the freelancers finds him a buyer quickly, and earns the N100k. Both parties are happy, and each move on the the next deal.


Founder of Freelance Economy 

The platform was founded by Kema Ufelle, a business lawyer and member of the World Economic Forum. He created Freelance Economy to organize all legitimate money-making opportunities in the semi-formal economy, for young Nigerians to access


Benefits of FreelanceEconomy.NG

The platform is a very innovative and simple-to-navigate platform that provides several legit money making opportunities every single day for young Nigerians. It also gives business owners a down-to-earth opportunity to source all the help needed in solving their day-to-day problems


What Is Unique About Freelance Economy?

Unlike foreign freelance platforms, this is a simple platform that is unique to the semi-formal middle-man style of doing business in Nigeria. The platform does not take a commission from whatever the freelancers earn. The freelancers only pay a N200 monthly subscription to access all opportunities on the platform (free for the first 7 days). However, it is free for the business owners who post deals on the platform.


Click here to visit https://FreelanceEconomy.ng

Sunday, 6 March 2022

Joinder of Issues and the Determination of Objection on Cause of Action.

One of the common feature of preliminary objections to civil cases is the complaint of non- disclosure of reasonable cause of action. Like many objections against jurisdiction, a plaintiff or claimant's case can be defeated on that score. The rationale behind the principle is that an aggregate of facts pleaded in the Statement of claim or facts ought to have disclosed an actionable wrong against the Defendant. In deserving circumstances however, this objection can be upheld, leading to the termination of the case.

The focus of this post however deals with the recent decision of the Supreme Court in the case of Adejugbe v. Aduloju (2022) 3 NWLR (Pt. 1816) 131. In that case, the apex court considered the procedural step a Court should take when an objection relating to disclosure of cause of action is made. More often than not, most defendants are always eager to hear their objections, even before the substantive suit is determined. Some of the reasons for this push may not be far fetched. It saves time for the Defendant and prevents the full hearing of the case on the merits. For practical reasons, a defendant may also wish to buy time or delay the hearing of the case, all of which are more within the realm of litigation management.

The powers of the Court to entertain a preliminary objection at any stage is however wide and discretionary. Most of the Rules of Court prescribe a discretionary power to the Court to exercise, whether the preliminary objection should be heard at the beginning of the suit, or whether the objection should be heard alongside the substantive case. The decision of the Supreme Court in Adejugbe v. Aduloju might however have limited this discretionary powers of the Courts, when dealing with objections on disclosure of reasonable cause of action. This limitation deals with the status of the pleadings as at when the objection was raised. In the case, the Supreme Court considered the issue and held thus:

Once issues have been joined, an objection based on want of cause of action is no longer available. In this case, the appellant and the 2nd respondent had filed a statement of defence and had joined issues with the 1st respondent on the facts in the statement of claim putting them up for trial. Further, the 1st respondent had filed his reply to the said statement of defence. At that stage, the contention that the 1st respondent’s case disclosed no reasonable cause of action should have been determined after conclusion of evidence and final addresses, along with the merit of the case in the judgment of the trial court. [S.P.D.C. Ltd. v. X. M. Federal (2006) 16NWLR (Pt. 1004) 189 referred to.] (P. 161

The clear purport of the decision of the apex court is to put the exercise of discretion on when to hear the objection on cause of action to check. Once pleadings have been concluded, the objection ought not be taken till the end of the case. A further merit in this position of the court is that hearing the objection together with the substantive suit would prevent the court from making decisions that would prejudge the substantive suit. It would also aid the speedy dispensation of justice.

However, the practicability of this procedure might have reduced the chances of hearing such objections to none! More often than not, most Rules of procedure now require a Defendant to file his statement of defence alongside the objections. The implication is that once the Claimant files his Reply to the Defence (which incorporates the objection), hearing such preliminary objection on grounds of non-disclosure of cause of action would have been rendered otiose. The only avenue would then be for the Defendant to refuse to file a Defence, but merely file a preliminary objection alone, which could lead to demurrer, which in turn, in now prohibited under the Rules. 

These are my early thoughts on the decision. Kindly share your take on it in the comment section. Again, thanks for reading. 

Sunday, 17 October 2021

Whether a joint application can be filed by more than one person to enforce a right under the Fundamental Rights (Enforcement Procedure) Rules



FINAMEDIA GLOBAL SERVICES LTD v. ONWERO (NIG) LTD & ORS
(2020) LPELR-51149(CA)


"On the propriety of two or more persons filing a joint application for the enforcement of their fundamental rights, it is important to understand that, as rightly pointed out, an action for the enforcement of fundamental rights is quite unlike an action in a civil suit, where parties may, expectedly, be joined in an action as plaintiffis quite unlike an action in a civil suit, where parties may, expectedly, be joined in an action as plaintiff. This cannot happen in an action under the fundamental rights enforcement procedure rules 2009, because of the sui generis nature of fundamental rights. The contention that the respondents' grievances is the determining factor is hollow, to say the least, because Fundamental Rights are so basic and inalienable to every person, individually. That explains the use of the word "any person" in Section 46 (1) of the Constitution; See RAYMOND S. DONGTOE V. CIVIL SERVICE COMMISSION, PLATEAU STATE & ORS (2001) 4 SCNJ Page 131. The right to approach a Court to enforce a Fundamental Right is conferred by Section 46 (1) and (2) of the 1999 Constitution of the Federal Republic of Nigeria (as amended), sub Section (1) provides: "Any person who alleges that any of the provisions of this chapter has been, is being, or likely to be contravened in any State in relation to him may apply to a High Court for redress." In this appeal under consideration, the application was brought by two applicants (1) Onwero Nigeria Ltd and (2) Mr. Uchenna John Paul Chidokwe. The words used in Section 46(1) of the Constitution are very clear, and it is not by accident that the constitution and the rules use the same adjective in qualifying who can apply to a Court to enforce a Right as, "any", which denotes singular, and does not admit pluralities in any form. Individual rights and not collective rights take prominence in fundamental rights applications; see R.T.F.T.C.I.N. V. IKWECHEIGH (2000) 13 NWLR Part 683 at Page 1 and OKECHUKWU V. ETUKOKWU (1998) 8 NWLR Part 562 Page 511. It is significant that the respondents' brief concedes and argued that the genesis of the claim under the Fundamental Right (Enforcement Procedure) Rule, arose from the act of eviction or locking up of the shops by the appellant or its agents. That being so; as was held by the Supreme Court in EGBUONU V. BORNU RADIO TELEVISION CORPORATION (1997) 12 NWLR (Pt. 531) 29 at 40, 42, 43, 44 - 45; the learned trial judge, with respect, was in error to have assumed jurisdiction to entertain, hear and determine the application, because stricto sensu, this has nothing to do with fundamental rights as enshrined in Chapter 4 of the Constitution. The vain effort on the part of the respondents, at justifying it by relying on Section 44 of the Constitution fell flat on its face because, any grievance founded on trespass, however stretched, cannot come within the ambit of the fundamental rights enforcement procedure rules. The position of this Court, and indeed the Supreme Court in recent times is that Chapter IV of the 1999 Constitution, as amended protects individuals and not groups as the expression "every individual", "every person" and "every citizen" clearly suggest. See R.T.F.C.I.N. v. IKWECHEGH? (2000) 2 NWLR part 683 page 1 and UDO V ROBSON & ORS (2018) LPELR-45183. Learned counsel to the appellant relied on UMARU KWAGE & 7 ORS V. UPPER SHARIA COURT GWANDU & ORS (supra) to drive home the point that joint application of fundamental rights application is allowed. This contention however, failed to take into consideration, the fact that the issue of joint application was neither raised nor addressed by this Court, for reasons of which it cannot be an authority on the issue, same as the issue of joint application was neither raised nor addressed by the Supreme Court in DIAMOND BANK PLC V H.R.H.EZE DR PETER OPARA & ORS (2018) LPELR-SC. On whether there is a need to call in aid Section 14 of the Interpretation Act, for the purpose of interpreting the word 'any person" in Section 46 (1) of the Constitution, I would hasten to add that the necessity for that has not arisen, because the word is clear and unambiguous, and therefore not likely to lend itself to any other interpretation. See SARAKI V. FRN (2016) 3 NWLR part 1500 page 531 and BRONIK MOTORS LTD V. WEMA BANK LTD (1983) 1 SCNLR 296. The 2009 Rules was promulgated to enhance the enforcement of fundamental rights; Order IX Rule 1 is particularly revolutionary in this regard, because it sought to cure defects and technicalities. Be that as it may, no exception was made for multiple applications. If indeed there was any intention or desire to allow for multiple applications, it would have been provided for in Order IX Rule 1. Alas, no such exception was made. Reliance on the said rule is of little or no help to the respondents in this case; for the avoidance of doubt, it reads: 1. Where any stage in the course of or in connection with any proceedings there has, by any reason of anything done or left undone, been failure to comply with the requirement as to time, place or manner of form, the failure shall be treated as an irregularity and may not nullify such proceedings except as they relate to- i) Mode of commencement of the application; ii) The subject matter is not within Chapter IV of the Constitution or the African charter on Human and People's Rights (Ratification and Enforcement) Act. The respondents' case before the trial Court was incompetent for all these reasons, thus the judgment emanating from the incompetent action cannot stand." Per MOHAMMED MUSTAPHA, JCA (Pp 12 - 17 Paras E - B)

Saturday, 16 October 2021

JUDGMENT AND ORDER - STAY OF EXECUTION OF JUDGMENT - Whether a party can apply for stay of execution of a judgment in the absence of a pending competent appeal

 

 

IN RE: THE SHERIFF, HIGH COURT OF JUSTICE RIVERS STATE, PORT HARCOURT & ANOR (2017) LPELR-42509(CA)

 "The second limb of the objection is that as at the time of filing the Motion for stay of execution by the Applicant on the 5th March, 2014, there was no pending appeal which absolutely rendered their said Motion filed pending appeal incompetent. To resolve this, it may be necessary hereat to beam on the decision in Intercontractors vs. UAC (1988) NWLR Part 76 page 303, per Karibi-Whyte, J.S.C; where it was stated that every judgment takes effect on pronouncement. A Judgment Debtor seeking to stay the execution must show that he is challenging the judgment, or is asking for time to comply with the terms of the judgment. If it is a challenge of the judgment, a Notice of Appeal ought to have been filed, or will, on undertaking, be filed. See Oladapo V. ACB (1951) 13 WACA 110. See also the decision of this Court in Shinning Star Nigeria Ltd & anor vs. A. K. S. Steel Nigeria Ltd & ors (2010) LPELR CA/L/558M/2009, per Saulawa, J.C.A; where the Supreme Court case of Oladapo vs. ACB (supra) was referred to. It was recognised that although the general principle is that for an application for stay of execution or proceedings to be worthy of being granted, it must be predicated upon certain grounds which include that there must have been filed a valid and pending appeal, however, an application for stay could be granted in exceptional circumstances without any pending appeal.
Further, in the case of Nigerian Agricultural Co-operative Bank Ltd. vs. Ozoemelam (2016) LPELR-26051 (SC), the Supreme Court, per Ngwuta, J.S.C; reiterated the principle that an application for stay of execution pending the determination of appeal presupposes that an appeal had been filed before or simultaneously with the application. After all, a major consideration in the application is whether or not there are arguable grounds of appeal. Be that as it may; in exceptional or appropriate circumstances, the order for stay may be granted when the appeal had not been lodged upon an undertaking to file the Notice of Appeal without delay. See NDLEA vs. Okorodudu (1997) 3 NWLR Part 492 page 221; Fatoyinbo vs. Osadeyi (2002) 5 SC Part 11 page 1.
All these established that even with or without a pending Notice of Appeal, an application for stay of execution can be considered by the Court where there is an undertaking by the Applicant to file the Notice or there is already pending, an application for leave to appeal or for extension of time to appeal which is a clear manifestation of the Applicant's eagerness or intention or a seeming undertaking to file the Notice of Appeal the moment the order of the Court granting leave or extension of time to appeal is made therein.
In the instant application, the Applicant in paragraph 10 of its 3rd Further Affidavit in support of this Motion filed on 14/11/2016 averred that on the 31st October, 2016, and consequent upon the extension of time to appeal against the judgment of the lower Court granted by this Court, the Applicant filed a Notice of Appeal on the 1st November, 2016 attached as Exhibit "N" thereto.
What matters is the state of events at the time of considering the application or granting the order for stay of execution. At the time of consideration of this application, there was already filed, a Notice of Appeal by the Applicant pending before his Court.
In Nwabueze vs. Nwosu (1988) NWLR Part 88 page 257, the Supreme Court held the Court has discretion to grant stay of execution on being satisfied that there are exceptional circumstances which warrant the exercise of the Court's discretion in the application's favour. This is so whether there is an appeal pending or not.
All these evidently emasculated the contentions of the 1st Respondent under the second limb of its objection, and, as such, this Court is presented with no further option than to overrule the preliminary objection raised by it. Accordingly, the preliminary objection raised by the 1st Respondent is hereby disallowed."   Per ORJI-ABADUA ,J.C.A (Pp. 21-25 paras. F)

Friday, 17 September 2021

Arguing against grant of cost for Litigation Fees? This might be your line...


The Claim for Litigation cost is quite a recurring fact in most court processes. I do not intend to bring the argument here. In certain circumstances, courts have granted these sort of claims. In others, the court would refuse them. The court of Appeal in the case of  GUINNESS (NIG) PLC v.NWOKE (2000) LPELR-6845(CA) refused the claim for solicitor's fees. As a matter of fact, the court found that placing the burden of litigation on another party would go against public policy. The Court held as follows:



I agree with the observation of the learned trial Judge who held, inter alia, that the cross-appellant's claim of his Solicitor's fees of N500,000.00 is in the nature of 'special damages'. The rule that special damages must be strictly proved applies to cases of tort. The rule requires anyone asking for special damages to prove strictly that he did suffer such special damages as he claimed. This, however, does not mean that the law requires a minimum measure of evidence or that the law lays down a special category of evidence required to establish entitlement to special damages. What is required of proof of special damages is that the person claiming should establish his entitlement to that type of special damages by credible evidence that would convince the Judge that he is entitled to an award under that head. In other words, the evidence must be of such a quality that a reasonable Tribunal would accept. See Oshinjinrin & Ors. v. Alhaji Elias & Ors. (1970) 1 All NWLR 153 at 161; Odunlaja v. Haddad (supra) 839; Osuji v. Isiocha (supra) 638 and Kosile v. Folarin (supra) 12 and 13.

The antecedent of this head of claim is that it arose as fees payable to the cross-appellant's Solicitor. In other words, the fees in point are sequel to the damages suffered by the cross-appellant for which the said Solicitor was briefed. It is not in doubt that the head of claim was pleaded with some particularity and was strictly proved. The crucial question is; Did this head of claim arise as a result of damage suffered by the cross-appellant in the course of any transaction between him and the cross-appellant? This is the question that ought to preoccupy the mind of any reasonable Tribunal dealing with the circumstances of the instant head of claim. A reasonable Tribunal, such as this Court, will definitely opine that the quality of evidence adduced by the cross-appellant on this score fell below the standard of acceptability because the circumstances making up the so-called 'special damages' occurred after the cause of action in this case had arisen. The seemingly financial inconvenience of the Solicitor's fees of staggering N500,000.00 to the cross-appellant did not form part of the basis of the tort of detinue on which the cross-appellant pivoted his cause of action. It is also unethical and an affront to public policy to pass on the burden of Solicitor's fees to the other party, in this case the cross-respondent.

In addition, the character of the act forming the said Solicitor's fees of N500,000.00 made as a head of claim by the cross-appellant is obviously not cumulative to the tort of detinue committed by the cross-respondent. It is outside it. I am of the strong view that this type of claim is outlandish to the operation of the principle of special damages and it should not be allowed. It is absolutely improper to allow the cross-appellant to pass his financial responsibility couched as 'special damages' to the cross-respondent. I accordingly resolve issue No.3 in favor of the cross-respondent.

The sanctity of Terms of Employment and Requirement of Proof for Claims



Cases are won and lost on proof. The position of evidence cannot be underestimated, particularly in claims for declarations. This same proposition works with labour disputes and where a court is called upon to pronounce on the employer / employee relationship, the scope has to be defined by the terms of employment as contained in the contract of employment. In SUIT NO: NICN/LA/52/2015 MR. OBINNA NKWONTA V. MULTICHEM INDUSTRIES LTD the National Industrial Court found as follows:


In any employment relationship especially where there is a written contract, the contract document defines the terms and conditions of the relationship. The same written contract outlines the rights, obligations and liabilities of the parties under and in relation to same. In event of dispute arising between the parties therefore and judicial intervention is sought, the duty of the Court is limited simply to the construction of the contract document existing between the parties. See Okogie & Ors. Epoyun (2010) LPELR-9145 (CA).It is not for the Court to re-write contract for the parties, see Nwaolisa v. Nwabufo (2011) LPELR-2115 (CA)' and neither is it within the power of the Court to give to a party rights or benefits not available to it under the contractual terms and conditions applicable to the parties.


In that case, the claimant (employee) had sought to prove his entitlement to bonuses but which the court found unsuccessful. The court further held thus regarding the claims:

 

 In the instant case, Exh. D1 is the evidence of contract entered into by the parties in this case. I examined the 4-page document. There is nothing in that exhibit either directly or indirectly touching on the entitlement of the Claimant to Bonus in whatever form of guise. I so find and so hold. Now, the Claimant had urged the Court to hold that there exists an implied term of his entitlement to Bonus in the contract between him and  the Defendant. Usually the need to resort to any implied terms of contract will arise where there is a lacunae in the contract document and the terms and conditions contained in it. In much the same vein, the facts of the case and the surrounding circumstances will be of immense assistance in finding what any implied term may be. The facts of this case and its surrounding circumstances do not convey any intention on the part of the parties for any implied terms to be imputed into their contract. Exh. D1 - letter of Contract contains detailed provisions respecting commencement and validity of contract, Place of work, Remuneration as well as Responsibilities. If Bonus were to be an issue it would no doubt have been contained in the contract. Interestingly, aside from assertions of the Claimant and the diverse e-mail messages sent by him to the Defendant's officers, there is no other evidence in support of the existence of oral promise respecting Bonus to be paid to the Claimant. Indeed, the Claimant attested to this in the course of cross examination. 


Lastly, it is always important to place the right pieces of evidence before the court. Although the National Industrial Court would seem to have a bit of room to avoid strict principles of the rules of Evidence as contained under the Evidence Act, 2011, the court still has the inherent jurisdiction to refuse inadmissible evidence. In the same case under review, the court held as follows regarding inadmissible piece of evidence:


Now, as part of the evidence in proof of his claim for bonus, the Claimant tendered Exh. C8. That exhibit is headed ''Overall Outstanding To: Obinna Nkwonta Micheal By Multichem Industries Limited (Nigeria)'', it states the entitlement of the Claimant to =N=40,000.00 as salary for August 2014 and ''overall total sales bonuses being owned to me is =N=2,305,227.1''. That exhibit has no name as the author. It carries no date. It also has no signature. It is apparent from the content that it was prepared by the Claimant. Although the Court already admitted this exhibit, the Court is in no way precluded from expunging it if the need arises or refuse to place any reliance on it. See Bayode Afolabi v. Chief Samuel Fehintola Alaremu (2011) LPELR-8894 (CA). The law is settled that an unsigned and undated document has no probative value. See  Udo v. Essien & Ors. (2014) LPELR-22684 (CA). I therefore hold that  Exh. C8 is of no probative value and is thus expunged from record. I note that Exh. C1 is the foundation upon which the success or failure of Relief 1 rests. Thus, having found and held that there nothing in that exhibit supporting the Relief 1, I refuse the claim for the alleged Claimant's bonus entitlement from 2012 to 2014 as claimed.


Thanks for reading!


 




Monday, 22 March 2021

The Ground of Appeal that Needs not Arise from the Decision of the Lower Court



 Most times when we are confronted with this rather knotty area of law, the conclusion is quite straight forward. It goes thus: "The Ground of Appeal is incompetent, having not arose from the decision of the Lower Court." This position is replete from decisions of our courts and it is in keeping with another similar principle of law that a party should not be allowed to change his case on appeal. The case must be the same. Otherwise, litigants would clearly turn courts to play grounds where theories and fantasies could be entertained.

More often than not however, and under the particular instance that I wish to restate in this post, that salient position might not be regarded as an altruism. The Rules of Court in clear terms do not restrict the Court to a particular number of Grounds of Appeal, as the Courts are allowed to raise such grounds in resolving an appeal. This is also clearly made not to stifle or bind the hands of the court and prevent it from doing justice. However, courts seldom make recourse to this principle. The one stated above remains sacrosanct and almost like they say, the rock of Gibraltar.


Perhaps I should go straight to that point. Well, in direct terms, this principle relates to issues of jurisdiction of a court. Once a ground of appeal exists which challenges the jurisdiction of a court to entertain a suit, such ground of appeal need not arise from the decision of the lower court for it to enjoy the validity of being treated at the appellate court. It would, in the circumstances, not be clogged by that principle in the first paragraph above, nor would it be referred to as being outside the decision of the court. It is merely in keeping with the position of the law that the issue of jurisdiction can be raised at any particular time, and in any particular manner. 

Finally, the Supreme Court restated this position of the law in the case of AGWU & ORS V. JULIUS BERGER (NIG) PLC (2019) LPELR-47625(SC) where the Court held as follows:


 "The first arm of the argument of the Learned Counsel for the appellant is based on the general rule that a ground of appeal against a decision must relate to the decision and should constitute a challenge to the ratio of the decision. This is a well settled proposition of Law in respect of which there can hardly be a departure. See Egbe v Alhaji (1989)1 NWLR (Pt.128) 546, Saraki v Kotoye (1992)9 NWLR (Pt.264)156. For every general rule there is an exception, in order to accommodate certain unforeseen circumstances. Where a ground of appeal questions the jurisdiction of a Court, it does not matter whether the issue of jurisdiction constituted the ratio of that decision or not, such a ground of appeal cannot be said to be incompetent by reason that it does not arise from the decision and constitute a challenge to its ratio decidendi. In Kalejaiye v LPDC & 1 Or  (unreported Appeal No.SC.429/2015) delivered on 15th March, 2019 the issue of change in the quorum of the LPDC was not the ratio of the decision of the LPDC, yet it was the only ground upon which the appeal was determined by this Court.

The ground of appeal against which the Appellants hinge their argument complained that the lower Court had no jurisdiction to decide substantive matter at interlocutory stage. This Court in a number of decisions has held that Courts are not allowed to delve into or decide the main complaint at an interlocutory stage. See FSB International Bank Nig. Ltd v Imam Nig. Ltd (2000)11 NWLR (Pt.678) 620 at 639, A.G. Kwara State & Anor. v Lawal & Ors (2017) LPELR-4234 (SC); Egbe v Onogun (1972) 1 All NLR (Pt.1)95, Ojukwu v Governor of Lagos State (1986)3 NWLR (Pt.26)35, Olaniyi v Aroyehun (1991)5 NWLR (Pt.194)652, Madubuike v Madubuike (2001)9 NWLR (Pt.719)698 at 707.

Before the trial Court were substantive suit initiated by writ of summons and a motion on notice which were filed on the 1st of July 1999. Both processes prayed for injunctive orders restraining the Respondent from declaring the Appellants redundant and ejecting them from their official quarters. The motion of 4th of October, 2000 sought for reinstating the Appellants and deeming them as employees of the Respondent. Clearly the writ of summons, and the motion of 1st July 1999 as well as the motion of 4th October 2000 sought to perpetuate the Appellants on their jobs. The language used in the three process is a matter of semantics, as there does not seen to be so much difference in the prayers. It is therefore not out of place if any of the parties complained that the trial Court decided the claims endorse on the writ when it ruled on the application of 4th October, 2000. As I have stated elsewhere in this judgment, the first ground of appeal at the lower Court being a jurisdictional question, or issue, same can be raised at any stage of proceedings including the appellate Court for the first time. See Nwankwo & Ors v. Yar'adua & Ors (2010)12 NWLR (Pt.1209) 518. In FHA v Kalejaiye (2010)19 NWLR (Pt.1226)149 at 164 para b, this Court, per Rhodes Vivour JCS said:-

"The issue of jurisdiction can be raised for the first time in any Court and at any stage of the proceedings and in the Supreme Court for the first time."

Jurisdiction is a threshold issue and it is so fundamental in that where a Court has no jurisdiction to determine an issue, the entire proceedings and judgment will be an exercise in futility. Once the issue of jurisdiction is raised, the Court is bound to examine whether it is spurious or genuine ground. In the instant case, the lower Court was right when it overruled the preliminary objection in order to consider the complaint embedded in the first ground of appeal."  Per GALUMJE ,J.S.C (Pp. 11-14 paras. D-D)


Again, I'll leave you with this quote. I hope you enjoyed reading it half as much as I enjoyed typing this.