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FAIR HEARING IS NOT A SPARE PART

Dictum

Adebayo v. AG, Ogun State (2008) LPELR – 80 (SC) 23 – 24 “I have seen in recent times that parties who have bad cases embrace and make use of the constitutional provision of fair hearing to bamboozle the adverse party and the Court, with a view to moving the Court away from the live issues in the litigation. They make so much weather and sing the familiar song that the constitutional provision is violated or contravened. They do not stop there. They rake the defence in most inappropriate cases because they have nothing to canvass in their favour in the case. The fair hearing provision in the Constitution is the machinery or locomotive of justice; not a spare part to propel or invigorate the case of the user. It is not a casual principle of law available to a party to be picked up at will in a case and force the Court to apply it to his advantage. On the contrary, it is a formidable and fundamental constitutional provision available to a party who is really denied fair hearing because he was not heard or that he was not properly heard in the case. Let litigants who have nothing useful to advocate in favour of their cases, leave the fair hearing constitutional provision alone because it is not available to them just for the asking.”

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FAIR TRIAL – RECOURSE TO SUPRA NATIONAL COURT

In the Case Concerning Bryan v. United Kingdom, 22 November 1995, paragraph 44, the European Court held that “A fair trial is a right which does no more than enable an aggrieved person to have recourse to a supra national court, so that the one who governs him may be condemned if the proof of a violation of his rights is established; the court must have jurisdiction to examine the points of fact and of law in the case which has come before it, in order that it may reform it…”

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FAIR HEARING IS SYNONYMOUS WITH FAIR TRIAL

Fair hearing has been interpreted by the courts to be synonymous with fair trial and as implying that every reasonable and fair minded observer who watches the proceedings should be able to come to the conclusion that the court or other tribunal has been fair to all the parties concerned.

– Ejiwunmi JSC. Unibiz v. Lyonnais (2003)

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FAIR HEARING BEING SO FUNDAMENTAL MUST BE RAISED IN GOOD FAITH

My lords, so fundamental and crucial is the right to fair hearing of the citizen before all Courts of the land that a failure by a Court to observe it in the litigation processes would invariably vitiate both the proceedings and judgment of such a Court, notwithstanding the merit or otherwise of the cases of the parties or indeed how meticulous the proceedings were conducted or even how sound the resultant judgment was on the merit, they are all a nullity. However, it must be pointed out at once that the issue of fair hearing must be raised with all seriousness and in good faith. It must never be raised in bad faith or merely intended as a red herring to raise a storm in a teacup without any factual basis. See Agbogu V. Adiche (2003) 2 NWLR (Pt. 805) 509@ p. 531. See also Agbapuonwu V. Agbapuonwu (1991) 1 NWLR (Pt. 165) 33 @p.40; Adegbesin V. The State (2014) 9 NWLR (pt. 1413) 609 @pp. 641 – 642.

— B.A. Georgewill, JCA. UBA v. Ashimina (2018) – CA/L/1033/2014

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EXPEDITIOUS HEARING MUST BE IN ACCORDANCE WITH FAIR HEARING

I am an adherent and a indeed devoted fan of expeditious hearing and determination of pending cases by the Courts but still it has to be in consonance with laid down rules of procedures and principles, particularly the observance of the inalienable right of the parties to be fairly heard in line with their constitutionally guaranteed right to fair hearing. In my view no Court no matter how zealous a Court is for the expeditious hearing and determination of matters before it can empower it to take away or infringe on the right to fair hearing of the parties and expect the Court to come out untouched by the tinge of invalidity and or nullity of both its proceedings, no matter how well conducted, and its decision, no matter how sound.

— B.A. Georgewill, JCA. UBA v. Ashimina (2018) – CA/L/1033/2014

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ONE MUST BE GIVEN THE CHANCE TO EXCULPATE HIMSELF

It is my considered view that after the Disciplinary Investigation Panel had completed its investigation, each of such students against who disciplinary action was contemplated must be informed of the available evidence against him and in addition given reasonable opportunity of exculpating himself. It is essential that in the exercise, the Vice Chancellor must observe the principles of impartiality and fairness. – Coker, J.S.C. Garba & Ors. v. The University Of Maiduguri (1986) 1 NWLR (Pt.18) 550

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FAIR HEARING APPLIES FROM THE BEGINNING TO THE END OF THE TRIAL

From its tenor, therefore, the Court is required to conduct the trial or hearing of a case with all fairness to both parties to the suit and without bias or partiality in favour of, or against either party. That is the rationale for the prescription that a complaint of breach of fair hearing is usually against the Court or Tribunal, whether the parties before the Court were afforded equal opportunity to fully ventilate their grievance. Okanlawon v. State (2015) LPELR-24838 (SC) 52-53; E-B; Peters Pam and Anor v. Mohammed and Anor (2008) 5-6 SC (Pt. 1) 83; Deduwa v. Okorodudu (1976) NMLR 236, 246; 9-10 SC 329. Such is its primacy in our administration of justice that no decision can be regarded as valid unless the trial Judge or Court has heard both sides in the conflict. State v. Onagoruwa (1992) LPELR -3228 (SC) 33; D-E; Deduwa v. Okorodudu (supra). This test of fair hearing applies once a trial has commenced, after issue has been joined, State v. Onagoruwa (supra); nay more, it applies from the beginning to the end of the trial. Oyewole v. Akande and Anor (2009) LPELR-2879 (SC) 36-37; Deduwa v. Okorodudu (1976) 9 -10 SC 329; News Watch Comm. Ltd. v. Attah (2006) 12 NWLR (Pt. 993) 144; A. G Rivers State v. Ude (2006) 17 NWLR (Pt. 1008) 436.

— C.C. Nweze JSC. Onuwa Kalu v. The State (SC.474/2011, 13 Apr 2017)

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