Judiciary-Poetry-Logo
JPoetry

DEFINITION OF CAUSE OF ACTION

Dictum

The Supreme Court in the case of A.G. OF ADAMAWA STATE & ORS v. A.G. OF THE FEDERATION (2014) LPELR-23221(SC) (P. 28, paras. C-F) Per PETER-ODILI, J.S.C, defined cause of action thus: ”The definition that has been followed on cause of action is that cause of action is the fact or facts which establish or give rise to a right of action. It is the factual situation which gives a person a right to judicial relief. Thus, when an action is said to be statute-barred, what it connotes is that the plaintiffs may have an actionable cause of action, but their recourse to judicial remedy is voided. No proceedings could be brought to prosecute the action. Muhammed v Military Administration, Plateau State (2001) 16 NWLR (Pt.740) 510 at 544 – 545; Egbe v Adefarasin (1985) 1 NWLR (Pt. 3) 1; Yusuf v C.C.B. Ltd (1994) 7 NWLR (Pt.359) 676.”

Was this dictum helpful?

SHARE ON

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 of action on the facts alleged in it, it is where the claim has some chances of success and once it raises some issues of law or fact calling for determination by the Court. Put differently, it is irrelevant to consider the weakness of the plaintiff’s claim but whether it raise some questions fit to be decided by a Court. And for a statement of claim to be said to disclose no cause of action it must be such as nobody can understand what claim he is required to meet.

– Shuaibu JCA. Diamond Bank v. Mocok (2019)

Was this dictum helpful?

ESTOPPEL: ISSUE & CAUSE OF ACTION ESTOPPEL

Two types of Estoppel by record are:- (a) Cause of Action Estoppel – which precludes a party to an action or his agents and privies from disputing as against the other party in any subsequent proceedings, matters which had been adjudicated upon previously by a court of competent jurisdiction between him and his adversary and involving same issue. (b) Issue Estoppel which precludes a party his servant, agent or privy from re-opening or relitigating as against the other party or his agents and privies in any subsequent proceedings, issues which were distinctly raised in a cause of action and appropriately resolved or determined in any suit between the parties in a court of competent jurisdiction.

– ADEKEYE, JCA. NOGA v. NICON (2007)

Was this dictum helpful?

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

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.”

Was this dictum helpful?

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?

AN ILLEGALITY CANNOT BE MADE THE SUBJECT MATTER OF AN ACTION

In Langston vs. Hughes (1813) 1 M&S 593 or 12 Digest 270 at 2214, Ellenborough, C.J., held that: “What is done in contravention of the provisions of an Act of Parliament cannot be made the subject-matter of an action” cited in Bostel Bros. Ltd. vs. Hurlock (1948) 2 All E.R. 312 at 313.

Was this dictum helpful?

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 thus, a factual situation which gives a person a right to judicial remedy. It is the operative fact or factual situation which gives rise to a right of action which itself is a remedial right EGBE Vs. ADEFARASIN (1987) 1 SC at 34 36. Cause of action may be defined as; (i) a cause of complaint; (ii) a civil right or obligation by a Court of Law; (iii) a dispute in respect of which a Court of Law is entitled to invoke its judicial powers to determine; (iv) consequent damages; See A. G. F. VS ABUBAKAR (2007) 10 NWLR (Pt1047) 1 SC MOBIL OIL PLC VS DENR (2004) 1 NWLR (Pt 853) 142. Thus, the words “cause of action” comprises every fact which would be necessary for the Plaintiff to prove, if traversed to support his right to the Judgment of the Court READ VS. BROWN (1882) 22 4 BD. it is all those things necessary to give a right of action whether they are to be done by the Plaintiff or a 3rd party. per Agbaje JSC in E. O. Amodu vs. Dr J, O, Amode & 4 Ors ( 1 990) 9 SCNJ 1, at 9 . It has also been defined simply as “a factual situation” the existence of which entitles one person to obtain from the Court a remedy against another THOMAS vs OLUFOSOYE (1996) 1 NWLR (pt 18) 6691 per Obaseki JSC.

— A.A. Wambai, JCA. Skye Bank v. Haruna & Ors. (CA/K/264/2011, 17th December, 2014)

Was this dictum helpful?

No more related dictum to show.