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INTEREST IS THE MEASURING ROD FOR A CAUSE OF ACTION – (ECOWAS Court)

Dictum

ODAFE OSERADA V. ECOWAS COUNCIL OF MINISTERS, ECOWAS PARLIAMENT & ECOWAS COMMISSION, ECW/CCJ/JUD/01/08 @ 27, the Court held that: “Generally, and from a legal standpoint, the necessity for an Applicant to provide justification of interest in a case is attested to by the adage that where there is no interest, there is no action, and also an interest is the measuring rod for an action. In other words, an application is admissible only when the applicant justifies that he brings a case before a Judge for the purposes of protecting an interest or defending an infringement of such. Such an interest must be direct, personal and certain.”

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DETERMINING THE EXISTENCE OR NONEXISTENCE OF A CAUSE OF ACTION

In determining the existence or non-existence of a cause of action in a suit, the Court is to consider the Writ of Summons and the statement of claim. And what distinguishes a claim which discloses cause of action from the one that does not is that where a statement of claim discloses some reasonable cause...

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THE LAW FOR DETERMINING A CASE IS THE LAW AS AT THE TIME CAUSE OF ACTION AROSE

The injury complained of by the Claimant occurred on 14th July 2012. This means that the cause of action arose on that said date. By OBIUWEUBI V. CBN [2011] 7 NWLR (PT. 1247) 465 the law for determining a case is the law as at the time the cause of action arose. This means that the law for determining the instant case is the Employee’s Compensation Act 2010 which replaced the Workmen’s Compensation Act.

— E.N. Agbakoba, J. Igenoza v Unknown Defendant (2019) – NICN/ABJ/294/2014

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CAUSE OF ACTION IS SET OF FACTS WHICH JUSTIFIES PLAINTIFF TO SUE

Para. 21: “A cause of action is a set of facts sufficient to justify a right to sue. It must contain a clear and concise statement of the material facts upon which the pleader relies for his claim with sufficient particularity to enable the opposite party to reply thereto. The term “cause of action” was defined in McKenzie v Farmers’ Co-operative Meat Industries Ltd 1922 AD 16 at 23 as “…”every fact which would be necessary for the plaintiff to prove, if traversed, in order to support his right to the judgment of the Court. It does not comprise every piece of evidence which is necessary to prove each 22 fact, but every fact which is necessary to be proved.” See also Mousa Leo Keita (2004-2009) CCJELR pg. 75 See also Afolayan V. Oba Ogunrinde & 3 ORS, (1990), 1 NWLR, (Pt. 127) 369 @ 371. SCNJ 62. Where Karibi-Whyte JSC stated that a cause of action means: ‘a) A cause of complaints; b) A civil right or obligation for the determination by a Court of law; c) A dispute in respect of which a Court of law is entitled to invoke its judicial powers to determine.’”

— Osaghae v Nigeria (2017) – ECW/CCJ/JUD/03/17

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WHAT IS A “DISPUTE”

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...

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DETERMINATION CONFINED TO CAUSE OF ACTION

It must be borne in mind, the settled principle that the hearing and determination of any cause or matter must be confined to the cause of action and the issues raised on the pleadings. – Ejinwunmi JSC. Awoniyi v. AMORC (2000) Was this dictum helpful? Yes 0 No 0...

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WHAT IS A CAUSE OF ACTION?

What then is a “cause of action ? Admittedly, the term “cause of action” defies a single precise definition. However, it has been variously defined or described as a bundle or aggregate of facts which the law recognizes as giving a Plaintiff a right to claim a relief or remedy against a defendant. It is...

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