The issues, as framed, appeared to have served no purpose whatsoever in the appeal. For after framing the nine issues, Counsel went back to argue his grounds of appeal one after another. He made no further reference to the issues framed, in his argument. The proper practice is, of course, that after framing the issues, the statement of facts and the argument to follow should be based on, and be referable to the issues as framed and not to the grounds of appeal. This is the only way whereby counsel can derive maximum benefit from his brief.
— Nnaemeka-Agu, JSC. Ugo v Obiekwe (1989) – SC.207/1985