The case of Cole v. Martins (1968) All NLR 16 was determined in 1968 by this court. This court held that the effect of registering a business name under the registration of Business Names Act, 1961 is that where only one person constitutes that business it is correct to describe that person as in the terms of the registered business name. In other words, Lardner &. Co. here referred solely to Mr. H.A. Lardner. That having regard to the context of rule 4 of the registration of titles (appeals) rule, purpose of which on this rule, is to ensure that the name of the legal practitioners giving notice of appeal and representing the appellant is clearly known, then it is a sufficient compliance with the requirement for a legal practitioner to sign and give his name, under which he is registered as a business name, as this can only refer and apply to the legal practitioner who so hold himself out as practicing under the business name. No possible doubt or confusion can therefore arise in these circumstances.
— J.A. Fabiyi, JSC. FBN v. Maiwada (2012) – SC.269/2005
