As to what constitutes a “Dispute”, Uwais, CJN, (Rtd) in his Ruling in the case of Attorney-General of the Federation v Attorney-General of Abia State & 35 others (supra), stated as follows:- “What constitutes a dispute under section 212 subsection (1) of the Constitution of the Federal Republic of Nigeria, 1979, which has exactly the same provisions as section 232 subsection (1) in question, had been considered by this Court in the cases of Attorney-General of Bendel State v Attorney-General of the Federation & 22 others (1981) 10 SC 1 and Attorney-General of the Federation v Attorney-General of Imo State & 2 others (1983) 4 NCLR 178. In Attorney-General of Bendel State’s case , Bello, JSC, (as he then was), stated as follows on pages 48 to 49 thereof:- ‘To invoke the original jurisdiction of this Court there must be a dispute as so qualified between the Federation and a State or between States. The issue of jurisdiction was contested on three grounds, firstly, that there is no dispute which affected the interest of the Federation and Bendel State between the plaintiff (Bendel State) and the Federation. Secondly, . . . I think the first point may be easily disposed of from the definition of the word “dispute”. The Oxford Universal Dictionary defines it as ‘the act of arguing against, controversy, debate, contention as to rights, claims and the like or on a matter of opinion . . .’
Ogbuagu JSC also held as follows on page 320 thereof:- “It is well established principle of the interpretation of constitution that the words of a constitution are not to be read with stultifying narrowness – United States v Classic 313 U.S 299 and Nafiu Rabiu v The State (1980) 8-11 SC 130. The word ‘dispute’ in section 212(1) should therefore be given such meaning that will effectuate rather than defeat the purpose of that section of the Constitution. Webster’s New Twentieth Century Dictionary (2ed), provides that ‘dispute’ is synonymous with controversy, quarrel, argument, disagreement and contention”. (Relied on in AG Kano State v AG Federation (2007) – SC 26/2006)