Daily Law Tips (Tip 770) by Onyekachi Umah, Esq., LL.M,
ACIArb(UK)
![image](/2021/04/lawp1.jpg")
Introduction:
There are a lot of cases of people that had their property wrongly
seized by court. Among the powers of a court is the power to order
the seizure of property of a party to a case before the court. The
Judges and Magistrates that make the orders, need not enforce the
orders themselves. Rather, the courts act through the bailiffs and
sheriffs (staff of court) from the execution unit of the courts.
During an enforcement, the property of an innocent person may be
mistakenly attached and seized.
![image](/2021/01/payne-alex.jpg")
Since courts work according to laid down legal procedures, where
there is an attachment and seizure of property (whether rightly or
wrongly seized), it is only a court that can order for the release
of the seized property. This simply means that a person whose
property was wrongly seized cannot recover the seized property by
begging or violence, rather may recover it by approaching the
concerned court.
Nothing is ever automatically granted or obtained from a court.
Courts are like the Benin Kingdom’s “Iye Akugbe” (Mother of Unity),
a female seer that protects the community but will never render her
services unless she is beckoned. So, in seeking for a court to
release a wrongly seized property, the party/person seeking such
release must beckon on the court. However, there is a single simple
issue that can frustrates the entire process of praying a court to
release a wrongly seized property. The issue is the only limitation
to the recovery of a property wrongly seized by a court.
Duty on an Interpleader:
Generally, the process or procedure for seeking to recover a
property that was wrongly seized by a court, as well as the
party/person seeking for such recovery/release of property are
known as “an Interpleader”. The proper court processes
(form/document) to file in court and commence an interpleader is
known as “Interpleader Summons”. The duty on the interpleader is
the greatest limitation to the recovery of a property that was
wrongly seized by a court.
Logically any person that makes any claim should be the person
to prove his claim. So, where a person claims that a seized
property belongs to him, the same person must show evidence to
prove that he truly owns the seized property. It is never enough to
merely state a claim without proving the claim. This is the summary
of the duty on an Interpleader. An interpleader, being a person
that claims that his property was wrongly seized by a court, must
be able to convince the court that the seized property belongs to
him and that the seized property was wrongly seized. This is the
duty on an interpleader in a court and where an interpleader fails
this duty, he fails to recover the seized property. Hence, proving
that a seized property belongs to an interpleader and that the same
property was wrongly seized by a court, make up the limitation to
the recovery of property wrongly seized by a court.
The Supreme Court of Nigeria as well as the Court of Appeal of
Nigeria have both made known their support for the above
understanding, through their judgments. Among such judgments
are;
1. The apex court had in the case of ALHAJI MUSA KALA v. ALHAJI
BURAU POTISKUM & ANOR (1998) LPELR-1648(SC), held that; “It is
trite that in interpleader proceedings, the claimant generally is
deemed to be the plaintiff and the judgment creditor, the
defendant. Accordingly the burden of proof, again as a general
rule, is on the claimant as the plaintiff in the proceedings. The
onus lies on him to establish his title to the property in dispute,
or where his claim is not absolute title, he must prove the precise
interest or title he claimed. Where, however, the claimant was in
possession of the property in issue at the time of its attachment,
it would seem that the judgment creditor shall, in that case, be
deemed a plaintiff and the burden of proof shall reverse
accordingly. In that case, the onus must be on the judgment
creditor to establish his claim. See Rabiu Jinadu v. Babaoye (1966)
2 All N.L.R. 241 per Taylor, C.J., as he then was. ”Per IGUH ,J.S.C
(Pp. 25 paras. C).
1. In the case of DALE POWER SYSTEMS PLC v. WITT & BUSCH LTD &
ANOR (2007) LPELR-4011(CA), where the Court of Appeal, held that;
“In an interpleader proceedings the burden of establishing
ownership of the attached goods is on the applicant.” Per PAUL
ADAMU GALINJE ,J.C.A ( P. 13, para. C)
1. The Court of Appeal in the case of ISOKO COMMUNITY BANK LTD
v. EDOFREN (NIG) LTD & ORS (2018) LPELR-44998(CA), held that “No
doubt, the purpose of inter-pleader proceedings is to seek relief
by initiating an action to determine the ownership of the property
or goods seized or attached by the sheriff or intend to seize or
attach in the Court against a judgment debtor. The third party who
claims ownership of such property or goods in question has the onus
under the law to establish title to the property or goods wrongly
attached. See BULUS VS OKPALA & ANOR (2017) LPELR 43423 (CA). In
OLATUNDE VS OAU & ANOR (1998) 5 NWLR (PT. 549) 178 the Supreme
Court held that in inter-pleader proceedings, the claimant is
deemed to be the plaintiff and the judgment creditor, the
defendant. Accordingly, the onus is generally on the claimant, to
establish title to the property he claims to be his.” Per SAMUEL
CHUKWUDUMEBI OSEJI ,J.C.A ( Pp. 26-27, paras. C-A )
3. Same was held in the case of COBRA LTD & ORS v. OMOLE ESTATES
& INVESTMENT LTD (2000) LPELR-6809(CA), when the Court of Appeal,
held that; “The learned trial Judge was right in dismissing the
Inter pleader/appellant summons based on affidavit evidence and the
documents placed before him. The Inter pleader claimant should not
act fraudulently so as to defeat judgment creditor’s interest by
claiming that the title to the seized goods are vested in the third
party. In Okwoche v. Dibia (1994)2 NWLR Part 325 at P.195 at page
205 this case per Uwaifo JCA (as then was) had this to say: “The
good faith of the claimant in the present case is certainly come
into question as a crucial issue having regard to the question in
nature of the alleged transfer of the vehicle under which judgment
debtor would endeavour to avoid his obligation to the judgment
creditor. The fraudulent transfer took place no doubt, after the
case of execution had been delivered to the sheriff. The claimant
cannot be said to have established his claim upon the facts. It
must be said that he has discharged this burden before he can be
granted relief. He has, in my view, from the totality of the
evidence failed in regard…” It is in the light of what have been
said above that I feel that the learned Judge gave the Inter
pleader/Claimant an opportunity of being heard before dismissing
their claims. I also affirm that decision.” Per SULEIMAN GALADIMA
,J.C.A ( Pp. 25-26, para. E )
Conclusion:
Part of the basic tenets of law and court room procedures, is that
the party that makes a claim must be the party to prove the claim.
Hence, where a party comes to court to claim that his property was
wrongly seized, it is the party that must prove that the seized
property belongs to him or that part of the property belongs to
him. Where a party fails to prove his total or partial ownership of
a wrongly seized property, the party cannot have a good stand to
pray for the wrongly seized property to be released. This duty to
prove ownership or interest on a wrongly seized property is the
Limitation to the Recovery of Property Wrongly Seized By Court.
My authorities, are:
1. Sections 1, 2, 3, 4, 5, 6, 36, 318 and 319 of the
Constitution of the Federal Republic of Nigeria, 1999.
2. Judgment of the Supreme Court of Nigeria in the case of ALHAJI
MUSA KALA v. ALHAJI BURAU POTISKUM & ANOR (1998) LPELR-1648(SC)
3. Judgment of the Supreme Court of Nigeria in the case of OBUMSELI
& ANOR v. UWAKWE (2019) LPELR-46937(SC).
4. Judgment of the Court of Appeal in the case of DALE POWER
SYSTEMS PLC v. WITT & BUSCH LTD & ANOR (2007) LPELR-4011(CA)
5. Judgment of the Court of Appeal in the case of ISOKO COMMUNITY
BANK LTD v. EDOFREN (NIG) LTD & ORS (2018) LPELR-44998(CA)
6. Judgment of the Court of Appeal in the case of COBRA LTD & ORS
v. OMOLE ESTATES & INVESTMENT LTD (2000) LPELR-6809(CA)
7. Judgment of the Court of Appeal in the case of DAWOOD GLOBAL
INTERGRATED CO. LTD v. GAJERE & ANOR (2017) LPELR-43369(CA).
8. Judgment of the Court of Appeal in the case of MUHAMMED v.
MARTINS ELECTRONICS CO. LTD (2017) LPELR-43138(CA).
9. Judgment of the Court of Appeal in the case of NATHANIEL BULUS
v. A.C. OKPALA & ANOR (2017) LPELR-43423(CA).
10. Judgment of the Court of Appeal in the case of WEST AFRICAN
COTTON LTD & ANOR v. MAIWADA (2007) LPELR-5097(CA).
11. Judgment of the Court of Appeal in the case of TANGENT LIMITED
v. BARR. JUDE I. OGAMBA & ORS (2018) LPELR-44803(CA).
12. Onyekachi Umah, “How to Recover Property Wrongly Seized by
Court.” (LearnNigrianLaws.com, 9 March 2021) <https://learnnigerianlaws.com/how-to-recover-property-wrongly-seized-by-court/[1]> accessed 6 April
2021
13. Onyekachi Umah, “Effect of an Application Brought Under a Wrong
Order or Rule of Court” (LearnNigerianLaws.com, 8 March 2021)
<https://learnnigerianlaws.com/effect-of-an-application-brought-under-a-wrong-order-or-rule-of-court/[2]> accessed 9 March
2021.
14. Onyekachi Umah, “Why Courts Must Hear Stupid
Applications/Motions?” (LearnNigerianLaws.com, 17 September 2020)
<https://learnnigerianlaws.com/why-courts-must-hear-stupid-applications-motions/>
accessed April 2021
15. Onyekachi Umah, “When Courts Must Refuse To Consider
Issues/Applications Before It” (LearnNigerianLaws.com, 10 September
2020) <https://learnnigerianlaws.com/when-courts-must-refuse-to-consider-issues-applications-before-it[3]/> accessed April
2021
16. Onyekachi Umah, “Oral Application for Bail is Allowed in High
Courts” (LearnNigerianLaws.com, 31 August 2020) <https://learnnigerianlaws.com/oral-application-for-bail-is-allowed-in-high-courts/[4]> accessed April
2021
17. Chris Admin, “A High Court of the Federal Capital Territory
(FCT) ordered the issuance of contempt proceedings against the
directors of Diamond Bank PLC” (LearnNigerianLaws.com, 9 August
2018) <https://learnnigerianlaws.com/a-high-court-of-the-federal-capital-territory-fct-ordered-the-issuance-of-contempt-proceedings-against-the-directors-of-diamond-bank-plc/[5]> accessed April
2021
18. Onyekachi Umah, “You Cannot Enforce A Judgement After 2 Years
and 6 Years Against A Party and His Representatives Respectively”
(LearnNigerianLaws.com, 1 August 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-154-you-cannot-enforce-a-judgement-after-2-years-and-6-years-against-a-party-and-his-representatives-respectively/[6]> accessed April
2021
Sabi Law Projects:
#SabiLaw
#DailyLawTips
#SabiBusinessLaw
#SabiElectionLaws
#SabiHumanRights
#SabiLawOnTheBeatFm
#SabiLawLectureSeries
#CriminalJusticeMonday
#SabiLawVideoChallenge
Speak with the writer, ask questions or make inquiries on this
topic or any other via onyekachi.umah@gmail.com,
info@LearnNigerianLaws.com or +2348037665878 (whatsapp). To receive
free Daily Law Tips, join our free WhatsApp group via
https://chat.whatsapp.com/L7h4f1exItZ38FeuhXG4WN or Telegram group,
via the below link: https://t.me/LearnNigerianLaws
To keep up to date on all free legal awareness projects of Sabi
Law Foundation, follow us via
Facebook Page:@LearnNigerianLaws,
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Twitter: @LearnNigeriaLaw,
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Facebook group:
(https://www.facebook.com/groups/129824937650907/?ref=share)
or visit our website: (www.LearnNigerianLaws.com)
Please share this publication for free till it gets to those
that need it most. Save a Nigerian today! NOTE: Sharing, modifying
or publishing this publication without giving credit to the author
or Sabi Law Foundation is a criminal breach of copyright and will
be prosecuted. This publication is the writer’s view not a legal
advice and does not create any form of relationship. You may reach
the writer for more information.
This publication is powered by www.LearnNigerianLaws.com {A Free
Law Awareness Program of Sabi Law Foundation, supported by the law
firm of Bezaleel Chambers International (BCI).} Sabi Law Foundation
is a Not-For-Profit and Non-Governmental Legal Awareness
Organization based in Nigeria. For sponsorship and partnership,
contact: sponsorship@learnnigerianlaws.com, sabilaw.ng@gmail.com or
+234 903 913 1200.
Daily Law Tips (Tip 770) by Onyekachi Umah, Esq., LL.M,
ACIArb(UK)
Introduction:
There are a lot of cases of people that had their property wrongly
seized by court. Among the powers of a court is the power to order
the seizure of property of a party to a case before the court. The
Judges and Magistrates that make the orders, need not enforce the
orders themselves. Rather, the courts act through the bailiffs and
sheriffs (staff of court) from the execution unit of the courts.
During an enforcement, the property of an innocent person may be
mistakenly attached and seized.
Since courts work according to laid down legal procedures, where
there is an attachment and seizure of property (whether rightly or
wrongly seized), it is only a court that can order for the release
of the seized property. This simply means that a person whose
property was wrongly seized cannot recover the seized property by
begging or violence, rather may recover it by approaching the
concerned court.
Nothing is ever automatically granted or obtained from a court.
Courts are like the Benin Kingdom’s “Iye Akugbe” (Mother of Unity),
a female seer that protects the community but will never render her
services unless she is beckoned. So, in seeking for a court to
release a wrongly seized property, the party/person seeking such
release must beckon on the court. However, there is a single simple
issue that can frustrates the entire process of praying a court to
release a wrongly seized property. The issue is the only limitation
to the recovery of a property wrongly seized by a court.
Duty on an Interpleader:
Generally, the process or procedure for seeking to recover a
property that was wrongly seized by a court, as well as the
party/person seeking for such recovery/release of property are
known as “an Interpleader”. The proper court processes
(form/document) to file in court and commence an interpleader is
known as “Interpleader Summons”. The duty on the interpleader is
the greatest limitation to the recovery of a property that was
wrongly seized by a court.
Logically any person that makes any claim should be the person
to prove his claim. So, where a person claims that a seized
property belongs to him, the same person must show evidence to
prove that he truly owns the seized property. It is never enough to
merely state a claim without proving the claim. This is the summary
of the duty on an Interpleader. An interpleader, being a person
that claims that his property was wrongly seized by a court, must
be able to convince the court that the seized property belongs to
him and that the seized property was wrongly seized. This is the
duty on an interpleader in a court and where an interpleader fails
this duty, he fails to recover the seized property. Hence, proving
that a seized property belongs to an interpleader and that the same
property was wrongly seized by a court, make up the limitation to
the recovery of property wrongly seized by a court.
The Supreme Court of Nigeria as well as the Court of Appeal of
Nigeria have both made known their support for the above
understanding, through their judgments. Among such judgments
are;
1. The apex court had in the case of ALHAJI MUSA KALA v. ALHAJI
BURAU POTISKUM & ANOR (1998) LPELR-1648(SC), held that; “It is
trite that in interpleader proceedings, the claimant generally is
deemed to be the plaintiff and the judgment creditor, the
defendant. Accordingly the burden of proof, again as a general
rule, is on the claimant as the plaintiff in the proceedings. The
onus lies on him to establish his title to the property in dispute,
or where his claim is not absolute title, he must prove the precise
interest or title he claimed. Where, however, the claimant was in
possession of the property in issue at the time of its attachment,
it would seem that the judgment creditor shall, in that case, be
deemed a plaintiff and the burden of proof shall reverse
accordingly. In that case, the onus must be on the judgment
creditor to establish his claim. See Rabiu Jinadu v. Babaoye (1966)
2 All N.L.R. 241 per Taylor, C.J., as he then was. ”Per IGUH ,J.S.C
(Pp. 25 paras. C).
1. In the case of DALE POWER SYSTEMS PLC v. WITT & BUSCH LTD &
ANOR (2007) LPELR-4011(CA), where the Court of Appeal, held that;
“In an interpleader proceedings the burden of establishing
ownership of the attached goods is on the applicant.” Per PAUL
ADAMU GALINJE ,J.C.A ( P. 13, para. C)
1. The Court of Appeal in the case of ISOKO COMMUNITY BANK LTD
v. EDOFREN (NIG) LTD & ORS (2018) LPELR-44998(CA), held that “No
doubt, the purpose of inter-pleader proceedings is to seek relief
by initiating an action to determine the ownership of the property
or goods seized or attached by the sheriff or intend to seize or
attach in the Court against a judgment debtor. The third party who
claims ownership of such property or goods in question has the onus
under the law to establish title to the property or goods wrongly
attached. See BULUS VS OKPALA & ANOR (2017) LPELR 43423 (CA). In
OLATUNDE VS OAU & ANOR (1998) 5 NWLR (PT. 549) 178 the Supreme
Court held that in inter-pleader proceedings, the claimant is
deemed to be the plaintiff and the judgment creditor, the
defendant. Accordingly, the onus is generally on the claimant, to
establish title to the property he claims to be his.” Per SAMUEL
CHUKWUDUMEBI OSEJI ,J.C.A ( Pp. 26-27, paras. C-A )
3. Same was held in the case of COBRA LTD & ORS v. OMOLE ESTATES
& INVESTMENT LTD (2000) LPELR-6809(CA), when the Court of Appeal,
held that; “The learned trial Judge was right in dismissing the
Inter pleader/appellant summons based on affidavit evidence and the
documents placed before him. The Inter pleader claimant should not
act fraudulently so as to defeat judgment creditor’s interest by
claiming that the title to the seized goods are vested in the third
party. In Okwoche v. Dibia (1994)2 NWLR Part 325 at P.195 at page
205 this case per Uwaifo JCA (as then was) had this to say: “The
good faith of the claimant in the present case is certainly come
into question as a crucial issue having regard to the question in
nature of the alleged transfer of the vehicle under which judgment
debtor would endeavour to avoid his obligation to the judgment
creditor. The fraudulent transfer took place no doubt, after the
case of execution had been delivered to the sheriff. The claimant
cannot be said to have established his claim upon the facts. It
must be said that he has discharged this burden before he can be
granted relief. He has, in my view, from the totality of the
evidence failed in regard…” It is in the light of what have been
said above that I feel that the learned Judge gave the Inter
pleader/Claimant an opportunity of being heard before dismissing
their claims. I also affirm that decision.” Per SULEIMAN GALADIMA
,J.C.A ( Pp. 25-26, para. E )
Conclusion:
Part of the basic tenets of law and court room procedures, is that
the party that makes a claim must be the party to prove the claim.
Hence, where a party comes to court to claim that his property was
wrongly seized, it is the party that must prove that the seized
property belongs to him or that part of the property belongs to
him. Where a party fails to prove his total or partial ownership of
a wrongly seized property, the party cannot have a good stand to
pray for the wrongly seized property to be released. This duty to
prove ownership or interest on a wrongly seized property is the
Limitation to the Recovery of Property Wrongly Seized By Court.
My authorities, are:
1. Sections 1, 2, 3, 4, 5, 6, 36, 318 and 319 of the
Constitution of the Federal Republic of Nigeria, 1999.
2. Judgment of the Supreme Court of Nigeria in the case of ALHAJI
MUSA KALA v. ALHAJI BURAU POTISKUM & ANOR (1998) LPELR-1648(SC)
3. Judgment of the Supreme Court of Nigeria in the case of OBUMSELI
& ANOR v. UWAKWE (2019) LPELR-46937(SC).
4. Judgment of the Court of Appeal in the case of DALE POWER
SYSTEMS PLC v. WITT & BUSCH LTD & ANOR (2007) LPELR-4011(CA)
5. Judgment of the Court of Appeal in the case of ISOKO COMMUNITY
BANK LTD v. EDOFREN (NIG) LTD & ORS (2018) LPELR-44998(CA)
6. Judgment of the Court of Appeal in the case of COBRA LTD & ORS
v. OMOLE ESTATES & INVESTMENT LTD (2000) LPELR-6809(CA)
7. Judgment of the Court of Appeal in the case of DAWOOD GLOBAL
INTERGRATED CO. LTD v. GAJERE & ANOR (2017) LPELR-43369(CA).
8. Judgment of the Court of Appeal in the case of MUHAMMED v.
MARTINS ELECTRONICS CO. LTD (2017) LPELR-43138(CA).
9. Judgment of the Court of Appeal in the case of NATHANIEL BULUS
v. A.C. OKPALA & ANOR (2017) LPELR-43423(CA).
10. Judgment of the Court of Appeal in the case of WEST AFRICAN
COTTON LTD & ANOR v. MAIWADA (2007) LPELR-5097(CA).
11. Judgment of the Court of Appeal in the case of TANGENT LIMITED
v. BARR. JUDE I. OGAMBA & ORS (2018) LPELR-44803(CA).
12. Onyekachi Umah, “How to Recover Property Wrongly Seized by
Court.” (LearnNigrianLaws.com, 9 March 2021) <https://learnnigerianlaws.com/how-to-recover-property-wrongly-seized-by-court/[1]> accessed 6 April
2021
13. Onyekachi Umah, “Effect of an Application Brought Under a Wrong
Order or Rule of Court” (LearnNigerianLaws.com, 8 March 2021)
<https://learnnigerianlaws.com/effect-of-an-application-brought-under-a-wrong-order-or-rule-of-court/[2]> accessed 9 March
2021.
14. Onyekachi Umah, “Why Courts Must Hear Stupid
Applications/Motions?” (LearnNigerianLaws.com, 17 September 2020)
<https://learnnigerianlaws.com/why-courts-must-hear-stupid-applications-motions/>
accessed April 2021
15. Onyekachi Umah, “When Courts Must Refuse To Consider
Issues/Applications Before It” (LearnNigerianLaws.com, 10 September
2020) <https://learnnigerianlaws.com/when-courts-must-refuse-to-consider-issues-applications-before-it[3]/> accessed April
2021
16. Onyekachi Umah, “Oral Application for Bail is Allowed in High
Courts” (LearnNigerianLaws.com, 31 August 2020) <https://learnnigerianlaws.com/oral-application-for-bail-is-allowed-in-high-courts/[4]> accessed April
2021
17. Chris Admin, “A High Court of the Federal Capital Territory
(FCT) ordered the issuance of contempt proceedings against the
directors of Diamond Bank PLC” (LearnNigerianLaws.com, 9 August
2018) <https://learnnigerianlaws.com/a-high-court-of-the-federal-capital-territory-fct-ordered-the-issuance-of-contempt-proceedings-against-the-directors-of-diamond-bank-plc/[5]> accessed April
2021
18. Onyekachi Umah, “You Cannot Enforce A Judgement After 2 Years
and 6 Years Against A Party and His Representatives Respectively”
(LearnNigerianLaws.com, 1 August 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-154-you-cannot-enforce-a-judgement-after-2-years-and-6-years-against-a-party-and-his-representatives-respectively/[6]> accessed April
2021
Sabi Law Projects:
#SabiLaw
#DailyLawTips
#SabiBusinessLaw
#SabiElectionLaws
#SabiHumanRights
#SabiLawOnTheBeatFm
#SabiLawLectureSeries
#CriminalJusticeMonday
#SabiLawVideoChallenge
Speak with the writer, ask questions or make inquiries on this
topic or any other via onyekachi.umah@gmail.com,
info@LearnNigerianLaws.com or +2348037665878 (whatsapp). To receive
free Daily Law Tips, join our free WhatsApp group via
https://chat.whatsapp.com/L7h4f1exItZ38FeuhXG4WN or Telegram group,
via the below link: https://t.me/LearnNigerianLaws
To keep up to date on all free legal awareness projects of Sabi
Law Foundation, follow us via
Facebook Page:@LearnNigerianLaws,
Instagram:@LearnNigerianLaws,
Twitter: @LearnNigeriaLaw,
YouTube: Learn Nigerian Laws,
WhatsApp Groups via
(https://chat.whatsapp.com/L7h4f1exItZ38FeuhXG4WN),
Telegram Group: (https://t.me/LearnNigerianLaws),
Facebook group:
(https://www.facebook.com/groups/129824937650907/?ref=share)
or visit our website: (www.LearnNigerianLaws.com)
Please share this publication for free till it gets to those
that need it most. Save a Nigerian today! NOTE: Sharing, modifying
or publishing this publication without giving credit to the author
or Sabi Law Foundation is a criminal breach of copyright and will
be prosecuted. This publication is the writer’s view not a legal
advice and does not create any form of relationship. You may reach
the writer for more information.
This publication is powered by www.LearnNigerianLaws.com {A Free
Law Awareness Program of Sabi Law Foundation, supported by the law
firm of Bezaleel Chambers International (BCI).} Sabi Law Foundation
is a Not-For-Profit and Non-Governmental Legal Awareness
Organization based in Nigeria. For sponsorship and partnership,
contact: sponsorship@learnnigerianlaws.com, sabilaw.ng@gmail.com or
+234 903 913 1200.