Atolagbe v. Shorun (1985) 1 NWLR (Pt. 2) 360 at 365 where Coker, J.S.C. in dealing with the main function of pleadings in the trial of an action had this to say: – “The primary function of pleadings is to define and delimit with clarity and precision the real matters in controversy between the parties upon which they can prepare and present their respective cases and upon which the court will be called to adjudicate between them. It is designed to bring the parties to an issue on which alone the court will adjudicate between them party is bound by his pleading and cannot go outside it to lead evidence or rely on facts which are extraneous to those pleaded.”
PARTY MUST TRAVERSE EACH ALLEGATIONS OF FACT
The law is that each party must traverse specifically each allegation of fact which he does not intend to admit. The party pleading must make it clear how much of his opponent’s case he disputes. The law is notorious that a traverse must not be evasive, but must answer the point of substance. The basic rule of pleading is that a traverse whether by denial or refusal to admit, must not be evasive but must answer the point of substance. The pleader must deal specifically with every allegation of fact made by his opponent: he must either admit it frankly or deny it boldly. Any half-admission or half-denial is evasive.”
— O. Oyebiola, J. Yakubu v. FRCN (2016) – NIC/LA/673/2013