In Nigeria, the operation of legislative powers by the national assembly and House of Assembly of a State is itemized in two list; the Exclusive Legislative list and Concurrent list, these vest powers on the legislature to legislate upon certain items. The exclusive list is the exclusive preserve of the National Assembly which has 68 items. The item Traffic on Federal Road” is provided for under item 63 2nd schedule part I in the Exclusive legislative list. Study of part I of the 2nd Schedule, Item 63 i.e “Traffic on Federal Trunk roads” gave rise to the promulgation of Federal Road safety Commission (Establishment) Act, 2007 by the National Assembly for the maintenance and security of public safety and order.
— A.O. Obaseki-Adejumo, JCA. FRSC v Ehikaam (2023) – CA/AS/276/2019