CORAM
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HEYDEN PETROLEUM LIMITED
TOP LEADER SHIPPING INC RESPONDENTS
AREA(S) OF LAW
SUMMARY OF FACTS
This is an appeal against the Ruling of the Federal High Court, Lagos Judicial Division, in which the application by the Appellant to set aside the registration of a foreign judgment entered in favour of the Respondent was dismissed for lacking in merit. The Appellant was dissatisfied with the ruling of the Court below and had promptly appealed to this Court. The gist of the case of the Appellant as can be gleaned from the affidavit and documentary evidence in the record of appeal was that a foreign judgment was obtained by the Respondent against the Appellant on a contract of carriage of goods entered into between the Appellant as Charterer and one Atlantic Management SA as Owner MV Emantha (Vessel), as contained in the Charter recap fixture dated 1/4/2013. The Respondent a stranger to the said contract had commenced an arbitration proceeding against the Appellant in London and obtained an award, which was subsequently entered as a judgment of the Queens Bench of the High Court of Justice of England. The Respondent never had transaction or dealing with the Appellant in respect of the Charter contract and was also never referred to as Vessel Owner or Principal of any Agent. In the circumstances, the Appellant ignored the proceedings commenced by a stranger that never had any dealings with it, more so when all payments involved in the course of the charter contract were to be paid as between the Appellant and Atlantic Management SA. In the arbitral proceedings, the Respondent concealed the charter party recap fixture showing the proper parties to the Charter agreement and succeeded in misleading the Arbitrator with deceit and misrepresentation that it was owner of the Vessel and that Atlantic Management S.A, was merely the manager of the Vessel and obtained an arbitral award against the Appellant, which was subsequently entered as the judgment of the High Court of England. The Respondent sought and obtained the order of the Court below registering the said foreign judgment for the purposes of enforcing it against the Appellant. Upon service of the Notice of Registration made on the orders of the Court below, the Appellant applied to the Court below to set aside the registration of the said foreign judgment on the ground that it was a judgment obtained by a non-party to a contract without the requisite locus standi, which rendered the foreign Court incompetent to have entertained the action filed by the Respondent, being one of the grounds provided for by the 1958 Ordinance for setting aside the registration of a foreign judgment. The application was duly heard and dismissed by the Court below contrary, in the Appellants contention, to Section 3(2)(b) of the 1958 Ordinance, hence the appeal. On the other hand, the application was duly heard and rightly, in the contention of the Respondent, dismissed by the Court below for lacking in merit.
HELD
Appeal Allowed.
ISSUES
Having regard to the state of the affidavit evidence of the parties, whether the Court below was right when it dismissed the Appellants application to set aside the registration of the foreign judgment by the Court below?
RATIONES DECIDENDI
TECHNICALITIES – ATTITUDE OF COURT TO TECHNICALITIES WHERE THE ISSUE OF JURISDICTION HAS BEEN RAISED
“My lords, while in today’s jurisprudence of substantial justice the issue of mere technicality no longer hold sway, yet it is truism that competence is the soul of adjudication. It is in this sense the issue of competence can no longer in law truly be regarded as mere technicality but rather be seen as substantial issue of law. In other words while eschewing technicality for its sake, a Court can only exercise jurisdiction where all conditions precedent to the exercise of its powers have been fulfilled. See Madukolu V. Nkemdilim (1962) 1 ALL NLR 587.see also P. E. Ltd. V. Leventis Trading Co. Ltd. (1992) 6 SC. (PT. 1)1 @ PP. 27 – 28; Dangana & Anor. V. Usman & Ors. (2012)2 SC (PT. 1)3.”
PRELIMINARY OBJECTION – MODE OF RAISING A PRELIMINARY OBJECTION BORDERING ON THE COMPETENCE OF AN APPEAL
“A preliminary objection that an appeal should not be heard and determined on the merit is a serious issue and if founded on grounds alleging incompetence of the appeal it should be taken seriously and considered and resolved one way or the other since without competence there is really no basis for adjudication and decision on the merit by a Court. Thus an issue bordering on the competence or incompetence of the entire grounds of appeal in an appeal is one which can validly be raised by means of a notice of preliminary objection and not by way of motion of notice. In the instant appeal, there are only two grounds of appeal both of which are being challenged as to their competence by the Respondent and therefore, the contention by the Appellants Counsel that the challenge ought to have been by way of a motion on notice and not by means of a notice of preliminary objection is not well founded and consequently hereby discountenanced. See Odunukwe V. Ofomata (2010) 18 NWLR (P. 1225) 404. See also Lafia Local Government V. Nasarawa State Government (2012) 17 NWLR (PT. 1328) 124.
In Inspector Isa Sarki V. John Lamela (2016) LPELR 40338 (CA), I had reiterated the above position of the law inter alia thus:
‘It is the law that where the purpose of an objection is merely to challenge some of the grounds of appeal and not the competence of the entire appeal, the best procedure is by way of a motion on notice since its success would not in an way terminate the entire appeal in limine. On the other hand, where the purpose of an objection is to terminate in limine the entirety of the appeal, the best procedure is by way of a notice of preliminary objection challenging the competence of the entire appeal.”
GROUNDS OF APPEAL – WHETHER A COUNSEL OR PARTY OUGHT TO BE PUNISHED FOR INELEGANTLY DRAFTING THE GROUNDS OF APPEAL
“In considering the preliminary objection of the Respondent challenging the competence of the entire two grounds of appeal in this appeal, I have taken a calm look at both grounds of appeal in the light of the decision of the Court below being appealed against together with the grounds for the preliminary objection, and I thought I should observe from the onset that while the principal purpose of a ground of appeal is to give notice to the other party and the Court of the nature of the grouse or complaint which the Appellant has against the decision of the lower Court and as long as it flows from or is related to and or connected to the issues in the decision complained against, then it would be said to be competent, notwithstanding how inelegant, perhaps, it may have been couched, after all a litigant does not couch grounds of appeal, his counsel does and he should not unnecessarily be penalized for inelegant drafting or couching by his counsel. See Adegbuyi V. A.P.C (2015) 2NWLR (PT. 1442) 1. See also Silencer & Exhaust Pipes Co V. Farah (1998) 12 NWLR (PT. 579); Babba V. Tafashiya (1999) 5 NWLR (PT. 603) 468; Audu V. Gideon (2015) 12 NWLR (PT. 1474) 495.”
GROUNDS OF APPEAL – OBJECTIVES OF GROUNDS OF APPEAL AND ATTITUDE OF COURTS THERETO
“Thus, in law the foundational objectives of grounds of Appeal is to notify the other party of the nature of the case he would meet in the appeal and once what the Appellant is appealing against is discernible, the Court would be reluctant to accede to a request to summarily terminate the appeal at the behest of the Respondent since to do so may and in most cases would amount to a denial of both the right of appeal and fair hearing of the Appellant as enshrined in Section 36(1) of the Constitution of the Federal Republic of Nigeria, 1999 (as amended). This would then relate back to the issue earlier addressed in this judgment, the need to allow mere technical justice ride roughshod over and above substantial justice. See British Airways V. Atoyebi (2006) 1 ALRN (PT.1) 23 @ P. 32 per Saulawa, JCA. See also OGBORU V. IBORI (2006) 7 NWLR (PT. 1000 342; Ogunbi V. Kosoko (1991) 8 NWLR (PT. 211) 616; Ekanem V. Akpan (1991) 8NWLR (PT. 211) 616; Ezegbu V. Fatb (1992) 1NWLR (PT. 220) 699; Panache Communications Ltd V. Aikhomu (1994) 2NWLR (PT. 327) 420.”
GROUND OF APPEAL – PREREQUISITE FOR THE VALIDITY AND COMPETENCE OF A GROUND OF APPEAL
“Having observed as above, I am aware, and it is the law, that a ground of appeal must challenge the ratio of a decision of a Court appealed against in order to be valid and competent. It cannot be mere attack on side remarks or side comments commonly referred to as obiter since if it does, it would be rendered incompetent. Thus, for a ground of appeal to be valid and competent, it must flow from the decision appealed against and there is no middle course on this settled position of the law. See Chukwu & Ors V. MTN (Nig) Comm Ltd & Anor (2016) LPELR – 41053 (CA). See Also Omega Bank Plc V. Government Of Ekiti State (2007) ALL FWLR (PT. 386) 658 @ PP. 687 – 688; Amobi V. Nzegwu & Ors (2013) LPELR 21863 (SC) @ PP. 40 41; Ahmad Damzomo V. Musa & Anor. (2013) LPELR – 20761(CA); Kotoye V. Saraki (1992) 11 – 12 SCNJ (PT. 1) 26.”
ISSUE FOR DETERMINATION – STATUS OF AN ISSUE FOR DETERMINATION NOT ARISING FROM ANY VALID GROUND OF APPEAL
“It is also the law, when it comes to formulation of issues for determination in an appeal, that it is only from a competent ground or grounds of appeal that a valid issue for determination could be distilled. Thus, an issue for determination distilled from an incompetent ground of appeal as well as an issue not arising from any valid ground of appeal is incompetent and liable to be struck out or simply discountenanced by the Court. See Olufeagba V. Abdulraheem (2010) ALL FWLR (PT. 512) 1034; Tahir & Anor. V. Bon Ltd (2006) LPELR – 11654 (CA); Okparanta V. Elechi (2007) ALL FWLR (PT. 358) 1185; Dalek (Nig) Ltd V. OMPADEC (2007) 7 NWLR (PT.1033) 402 @ P. 430; Elemchukwu Ibator & Ors V. Chief Beli Barakuro & Ors (2007) LPELR – 1384(SC); Njemanze V. Njemanze (2013) LPELR – 19885 (SC); Obi – Odu V. Duke (2006) 1 NWLR (PT. 961) 375.”
GROUNDS OF APPEAL – BASIS FOR THE VALIDITY OF GROUNDS OF APPEAL AND ISSUES FOR DETERMINATION
“In law, once the grounds of appeal are competent, and the issue for determination flows from them, such issues would be held to be valid and competent to be heard and resolved on the merit.”
REGISTRATION OF FOREIGN JUDGMENT – LAWS THAT GOVERN REGISTRATION OF FOREIGN JUDGMENTS AND ARBITRAL AWARDS IN NIGERIA
“In Nigeria, registration of foreign judgment, including arbitral award is governed by the provisions of Reciprocal Enforcement of Judgments Ordinance, Cap 175, Laws of the Federation of Nigeria, 1958. ”
JUDGMENT OF COURT – WHETHER A COURT CAN PRONOUNCE JUDGMENT IN A JURISDICTION BEYOND ITS OWN TERRITORY
“Generally, the powers of the Courts are limited by their territorial boundaries or jurisdiction. Thus a judgment pronounced by the Court of one jurisdiction may have no force or effect beyond its own territory except in situations where other jurisdictions have agreed to allow such judgment enforceability within their own territories presumably through reciprocal agreements to that effect based principally on principles of reciprocity and obligation. See Schibsby V. Westenholz (1870) LR 6 QB 155 @ P. 159. See also Adams V. Cape Industries Plc (1990) CH. 433.”
ENFORCEMENT OF FOREIGN JUDGMENT – STATUTES THAT REGULATE ENFORCEMENT OF FOREIGN JUDGMENTS IN NIGERIA
“However, there are two principal statutes regulating the enforcement of foreign judgments in Nigeria, namely; Reciprocal Enforcement of Foreign Judgments Ordinance, Cap 175, Laws of the Federation of Nigeria and Lagos, 1958 (the 1958 Ordinance) and Foreign Judgments (Reciprocal Enforcement) Act, Cap 152, Laws of the Federation of Nigeria, 1990. See Dale Power Systems Plc V. Witt & Busch Ltd. (2001) 8 NWLR (PT. 716) 699. See also Halaoui V. Grosvernor Casinos Limited. (2002) 17 NWLR (PT. 795) 28; Macaulay V. R.Z.B. Austria (2003) 18 NWLR (PT. 852) 282.By virtue of these legislations in order for a foreign judgment to be enforceable in Nigeria, it must have been pronounced by a superior Court of the country of the original Court.”
REGISTRATION OF FOREIGN JUDGMENT –REQUIREMENT FOR THE QUALIFICATION OF REGISTRATION OF FOREIGN JUDGMENT
“Thus to qualify for registration, the foreign judgment must be a money judgment and must be for a sum certain which can be by ascertained by simple mathematical process. Furthermore, the judgment must be final and conclusive as between the parties thereto. See Section 2(1) of the Foreign Judgments (Reciprocal Enforcement) Act, Cap 152, Laws of the Federation of Nigeria, 1990. See also Section 3(2)(b) of the 1990 Act; Beatty V. Beatty (1924) 1 KB 807 CA; Nouvion V. Freeman (1889) 15 AC 1 @ P. 14.”
REGISTRATION OF FOREIGN JUDGMENT – CONDITIONS FOR THE REGISTRATION AND NON- REGISTRATION OF FOREIGN JUDGMENTS IN NIGERIA
“Thus, in law a judgment which is capable of being varied or rescinded by the Court that gave it is not registrable. A judgment shall also not be registered if at the date of the application for registration the judgment has been wholly satisfied (paid) by the judgment debtor or if the judgment could not be enforced by execution in the original Court. To be registrable, the sum payable under the judgment must be expressed in Naira and if the judgment sum is expressed in a currency other than the Naira, the law requires the sum to be converted into the Naira at the rate of exchange prevailing at the date of judgment. Thus, if at the date of the application for registration, the judgment of the original Court has been partly satisfied, the judgment will be registered in respect of the balance due only and not the whole sum. Upon registration, a registered judgment has the same force and effect as the original judgment and proceedings may be taken on it but the registering Court has the same control over execution, as if the registered judgment had been one originally given by the registering Court and entered on the date of registration. See the proviso to Section 4 of the 1990 Act; See also Section 4(3); 4(4) and 7(4) of the 1990 Act; Dicey and Morris, the Conflict of Laws 3rd Edition Vol. 1 @ p. 191; Ferdinand Wagner V. Laubscher Brothers & Co (1970) 2 ALL ER 174 @ P. 175; Adwork Ltd. V. Nigeria Airways Ltd. (2000) 2 NWLR (PT. 645) 415 @ PP. 429 430. It is of great importance to observe that to be registrable, the sum payable under the judgment must be expressed in Naira. If the judgment sum is expressed in a currency other than the Naira, the law requires the sum to be converted into the Naira at the rate of exchange prevailing at the date of judgment. However, if at the date of the application for registration, the judgment of the original Court has been partly satisfied, the judgment will be registered in respect of the balance due only and not the whole sum. Submission to Jurisdiction.”
ENFORCEMENT OF FOREIGN JUDGMENT – CIRCUMSTANCES WHEN THE ISSUE OF ENFORCEMENT OF FOREIGN JUDGMENT MAY ARISE
“The issue of enforcement in Nigeria can only arise if the judgment debtor submitted to the jurisdiction of the foreign Court and a Defendant would be taken to have submitted to the jurisdiction of the foreign Court if he files an unconditional appearance or if he moved that Court to set aside a default judgment and at the same time applied for an order that the Claimant deliver a statement of claim and when he applied for an order for security for cost. See Halaoui V. Grosvernor Casinos Limited (2002) 17 NWLR (PT. 795) 28.”
REGISTRATION OF FOREIGN JUDGMENT – CIRCUMSTANCES WHEN COURT MAY SET ASIDE THE REGISTRATION OF FOREIGN JUDGMENTS
“Now, while the Court below has the plenitude of powers to register a foreign judgment in Nigeria pursuant to the relevant provisions of the applicable legislations, it also reserves the powers under the said laws to set aside registration under Section 3(2)(b) of the 1958 Ordinance if, on an application to set aside the registration of a foreign judgment it is shown amongst others grounds that the original Court in the foreign Country had no jurisdiction in the circumstances of the case. However, where registration of a foreign judgment is set aside solely on the ground that the judgment was not at the date of the application for registration enforceable by execution in the country of the original Court, such as declaratory judgments or where an appeal is pending in the country of the original Court, the setting aside of the registration shall not be a bar to the bringing of a further application to register the judgment when the appeal has been disposed of or if and when the judgment becomes enforceable in that country as the case may be. See Section 7(1) of the 1990 Act.”
FOREIGN JUDGMENT – WHETHER A PARTY WHO HAS OBTAINED JUDGMENT IN A FOREIGN COUNTRY MAY RELITIGATE SAME IN A NIGERIAN COURT
“In law a person, who has obtained judgment in a foreign country, being a country which accords judgments given by the High Courts of Nigeria reciprocity, is estopped from suing on the original cause of action that was the subject matter of litigation in the foreign Court as this principle is based on a public policy consideration that it is for the common good that there must be an end to litigation. See generally Halsburys Laws of England 4th Edition (Re – issue) Vol. 8 @ pp. 156 157. See also Nigeria: Legal Regime for the Enforcement of Foreign Judgments in Nigeria: An Overview by Godwin Omoaka.”
REGISTRATION OF FOREIGN JUDGMENT – POWER OF COURT TO SET ASIDE THE REGISTRATION OF A FOREIGN JUDGMENTS
“My lords, having sufficiently averted my mind as above to the guiding principles of the law on registration of foreign judgments in Nigeria, it is clear that while the law permits the application to register a foreign judgment to be by ex – parte petition, it reserves the power in the Court below to set aside its registration on grounds as set aside in Section 3(2) of the 1958 Act on grounds including lack of jurisdiction in the original Court that entered the judgment.”
DOCTRINE OF PRIVITY OF CONTRACT – WHETHER A PARTY WHO IS NOT PRIVY TO A CONTRACT AGREEMENT CAN ENFORCE SAME IN COURT
“The simple issue placed before the Court below was whether or not the Respondent was, on the terms of the Charter – Party Contract Agreement, a party to the Charter – Party Contract? If the answer is yes, and which can only be determined by reference to the terms of the Charter – Party Agreement itself, and not to contents of the arbitral award or the foreign judgment which are not the contract of the parties sought to be enforced in the action in England by the Respondent against the Appellant, that would be the end of the matter as the registration would then not be set aside. However, if the Respondent was not a party to the Charter – Party Contract, of which onus to prove lies on the Respondent who claims to be a party thereto, then in law the Respondent being not a party to the contract cannot enforce it in a Court of law even if it was made solely for its own benefit by virtue of the operation of the doctrine of privity of contract. The law is so both in England and Nigeria. See Makwe V. Nwukor (2001) 14 NWLR (PT. 733) 356 @ P. 372; Eafulukwe V. John Holt Ltd (1996) 2 NWLR (PT. 432) 511 @ P. 522. In Law a person, such as the Respondent in the instant appeal, would have no locus to enforce a contract to which he is not a party and thus lacking any privity of contract with the Appellant. See Prince Alabi V. Shittu Ogunlowo & Ors. (1997) 6 NWLR (PT. 509) 1, where Onu, JSC., had emphatically pronounced thus:
‘In law, there is privity of contract, it is always between the contracting parties who must stand or fall, benefit or lose from the provisions of their contract. Their contract cannot bind third parties nor can third parties take or accept liabilities under it, nor benefit there – under’.”
LOCUS STANDI – WHETHER THE MERE SUBMISSION OF A DEFENDANT TO THE JURISDICTION OF THE COURT AUTOMATICALLY CONFERS LOCUS STANDI ON THE CLAIMANT
“The issue of locus standi transcends submission to jurisdiction. In other words, the fact that a Defendant had submitted to the jurisdiction of a Court does not confer locus standi on the Claimant or obviate the fundamental issue of locus standi of the Claimant, which must be shown to exist if questioned for the claim to be competent and by implication for the Court to have the requisite jurisdiction over such a claim.”
REGISTERATION OF FOREIGN JUDGMENT – WHETHER THE LAW PREVENTS A PARTY FROM CHALLENGING THE REGISTERATION OF A FOREIGN JUDGMENT
“The law does neither encourage nor close all avenues to challenge the registration of foreign jurisdiction once registered but rather set out some conditions upon which registration of a foreign judgment could be refused or a registration could be set aside by the Court on the application by the alleged judgment debtor.”
REGISTERATION OF FOREIGN JUDGMENT – CIRCUMSTANCE FOR SETTING ASIDE THE REGISTRATION OF A FOREIGN JUDGMENT
“In law therefore, a registration of a foreign judgment contrary to the stipulated conditions would render such registration liable to be set aside without much ado.”
REGISTRATION OF FOREIGN JUDGMENT – WHETHER THE REFUSAL OR THE SETTING ASIDE OF THE REGISTRATION OF A FOREIGN JUDGMENT AMOUNTS TO AN OVERTURNING OR SETTING ASIDE OF A FOREIGN JUDGMENT
“It must be noted and very pertinently too that a refusal of registration or setting aside of the registration of a foreign judgment does not amount to overturning or setting aside the foreign judgment as in law the same still remains valid and the refusal does not operate as a bar to further or subsequent application for its registration if the conditions for registration of foreign judgment are subsequently met by the Judgment Creditor.”
REGISTRATION OF FOREIGN JUDGMENT – INSTANCE WHEN A FOREIGN JUDGMENT WILL NOT BE REGISTERED
“Thus, registration of foreign judgment is not automatic nor is it a fait accompli and therefore, once it is shown that there was a failure or want of competence such a judgment should not be registered and if inadvertently registered, being that the procedure for registration is ex – parte, such wrongful registration should be set aside.”
CONTRACT AGREEMENT – DETERMINATION OF THE PARTIES TO A CONTRACT AGREEMENT
“In matters of this nature it is the terms of the contract agreement between the parties that is the determining factor as to who are the parties to the contract and not the contents of the foreign judgment whose registration is sought to be set aside.”
COMMENCEMENT OF A CLAIM – CONSEQUENCES OF A FAILURE TO OBSERVE A CRUCIAL CONDITION PRECEDENT TO THE VALID COMMENCEMENT OF A CLAIM IN A FOREIGN COURT
“Thus a crucial condition precedent to the valid commencement of the claim by the Respondent against the Appellant was not met by the Respondent and thus the foreign Court was robbed of its jurisdiction as rightly contended by the Appellant. See Madukolu V. Nkemdilim (1962) ALL NLR 587; SLB Consortium Ltd V. NNPC (2011) NWLR (PT. 1252) 317 @ P. 335.”
REGISTRATION OF A FOREIGN JUDGMENT – CONDTIONS FOR SETTING ASIDE THE REGISTRATION OF A FOREIGN JUDGMENT
“Registration of a foreign judgment may be set aside under Section 6(1) of the Foreign Judgments (Reciprocal Enforcement) Act. 1960, so held the Supreme Court in the case of Obasi v. Mikson Establishment Industries Ltd. (2016) 16 NWLR (pt. 1539) 335 at 364 and 366. Section 6(1) of the Foreign Judgments (Reciprocal Enforcement Act. 1960 reads
“6(1) On an application in that behalf duly made by any party against whom a registered judgment may be enforced, the registration of the judgment-
(a) shall be set aside if the registering Court is satisfied-
(i) that the judgment is not a judgment to which this Part of this Ordinance applies or was registered in contravention of the foregoing provisions of this Ordinance; or
(ii) that the Courts of the country of the original Court had no jurisdiction in the circumstances of the case; or (iii) that the judgment debtor, being the defendant in the proceedings in the original Court, did not (notwithstanding that process may have been duly served on him in accordance with the law of the country of the original Court) receive notice of those proceedings in sufficient time to enable him to defend the proceedings and did not appear: or
(iv) that the judgment was obtained by fraud; or
(v) that the enforcement of the judgment would be contrary to public policy in Nigeria; or
(vi) that the rights under the judgment are not vested in the person by whom the application for registration was made;
(b) may be set aside if the registering Court is satisfied that the matter in dispute in the proceedings in the original Court had previously to the date of the judgment in the original Court been the subject of a final and conclusive judgment by a Court having jurisdiction in the matter.”
OBJECTION TO FOREIGN PROCEEDINGS – WHETHER AN OBJECTION THAT A FOREIGN PROCEEDINGS IS CONTRARY TO NATURAL JUSTICE CAN BE TAKEN IN THE COUNTRY WHERE THE JUDGMENT HAS BEEN REGISTERED
“Halsburys Laws of England (Fourth Edition) page 141 paragraph 153 states aptly inter alia that the objection that the foreign proceedings were contrary to natural justice (fair hearing. for example) may be taken in the country where the judgment has been registered even though it could have been or was taken before the original Court the judgment was entered citing in support the English case of Jet Holdings Inc. v. Patel [1990] 1 QB 335, (1989) 2 All ER 648, CA. It follows in my modest opinion following Halsbury’s Laws of England (supra) that an objection founded upon lack of notice or lack of an opportunity to be heard may be taken against a foreign judgment registered in this country, both on the ground of jurisdiction and substantial justice as lack of notice of the proceedings by non-service of process affects the jurisdiction of the Court and goes to the doing of substantial justice vide Okoye And Anor. V. Centre Point Merchant Bank Ltd. (2008) 15 NWLR (PT.1110) 335 at 359 – 360.”
CASES CITED
Not Available
STATUTES REFERRED TO
Foreign Judgments (Reciprocal Enforcement) Act, Cap 152, Laws of the Federation of Nigeria, 1990.|Foreign Judgments (Reprocal Enforcement) Act. 1960|Reciprocal Enforcement of Foreign Judgments Ordinance, Cap 175, Laws of the Federation of Nigeria and Lagos, 1958 (the 1958 Ordinance)|Reciprocal Enforcement of Judgments Ordinance, Cap 175, Laws of the Federation of Nigeria, 1958|