The judge, by ordering consolidation, does not give finality to any of the cases; rather he brings them under the umbrella of a single trial to decide all matters between parties or their privies in respect of the same subject matter. The essence of consolidation is to save time and costs by avoiding a multiplicity of litigations where one will suffice. If for any reason in course of trial, the court that ordered consolidation deems it expedient to deconsolidate, whether because those parties are not contesting the same issue or subject matter, or the parties are not the same and justice would demand separate trials, deconsolidation will be ordered. Consolidation does not make the judge ordering it functus officio, he continues with the hearing of the consolidated matter. The order for consolidation therefore being interlocutory can only be appealed against from the High Court to the Court of Appeal by leave. As no leave was obtained in this instance, the purported appeal is a nullity as it is not based on any lawful premise; for such an appeal cannot be filed as of right as provided by S.220(1) of the Constitution.
— S.M.A. Belgore JSC. Bennett Ifediorah & Ors. V. Ben Ume & Ors. (1988)