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Kaduna Peace Model: How Uba Sani’s Non-Kinetic Strategy Turned Fear into Hope

By Sani Liman Kila

For years, Kaduna’s name struck fear into the hearts of travellers and traders. Once-vibrant local economies in Birnin Gwari, Giwa, Kajuru and Kauru became graveyards of opportunity — haunted by abductions, bloodshed and despair. The old “force-first” method — military raids, aerial bombardments and curfews — brought temporary relief but no lasting peace. Instead, it hardened resentments and deepened the gulf between government and governed.

The numbers told a grim story. By the time the kinetic approach reached its peak, hundreds of innocent civilians had been killed or displaced, thousands of children were out of school, and entire markets had collapsed. The countryside was silenced by fear.

Between 2015 and 2023, Kaduna recorded 1,660 security incidents, resulting in 4,876 deaths. In 2021 alone, 1,192 people were killed, 3,348 kidnapped, and 891 injured. The first quarter of 2022 saw 360 killed and 1,399 abducted — in just three months. In frontline LGAs such as Birnin Gwari, Giwa, Kajuru and Chikun, fatalities ranged between 400 and 800 lives per area over the eight-year period. These were not mere statistics — they were human tragedies that tested Kaduna’s endurance and spirit.

But a new doctrine was on the horizon — one that would upend the conventional wisdom of fighting terror with terror. When Governor Uba Sani assumed office, he refused to accept that Kaduna’s destiny was perpetual conflict. Guided by his conviction that “you cannot bomb peace into existence; you must build it with trust,” he launched what is now widely referred to as the Kaduna Peace Model — a bold non-kinetic approach that is transforming the state’s security landscape and winning back hearts long lost to violence.

A Joint Blueprint: Kaduna Govt and ONSA Rewrite the Script

At the heart of this transformation lies a powerful collaboration between the Office of the National Security Adviser (ONSA) and the Kaduna State Government. Together, they established a joint technical committee made up of stakeholders, social scientists, and local administrators. This team didn’t arrive with tanks or drones — they came with empathy, dialogue and data.

In their first major engagement, 58 captives were released by bandits without a single gunshot. Encouraged by trust-building measures, over 80 more hostages were freed in the following weeks. Today, that number has risen to over 500 captives — all released unhurt, a historic milestone in Kaduna’s long quest for peace.

“The peace we are building in Kaduna is rooted in dialogue, not dominance,” Governor Uba Sani once pointed out.

The Turning Point: Dialogue and Demands

The breakthrough came during the second round of sittings between the ONSA–Kaduna special committee and leaders of the armed groups. It was an unconventional negotiation, but one anchored on realism.

The bandits, weary of endless clashes and displacement, tabled their conditions:

1. Re-opening of local markets;

2. Access to schools for their children;

3. Access to medical facilities — particularly in Birnin Gwari, Giwa and parts of Southern Kaduna.

Rather than dismiss these as mere tactics, the government saw them for what they were — the basic needs of citizens trapped between survival and surrender. Governor Sani swiftly approved the reopening of markets and directed the restoration of normal life in affected communities.

The results were immediate and visible. The once-ghostly corridors of Giwa and Birnin Gwari now bustle with activity. Travellers testify that one can journey through these areas “no matter how late” and still arrive safely — something unthinkable two years ago.

Clerics, Turji and the Wider Context

Separately, clerics led by Sheikh Musa Yusuf (Asadus-Sunnah) publicly disclosed that they had held deep-forest meetings with notorious bandit leader Bello Turji and other commanders.

According to a Vanguard report dated August 5, 2025, the cleric revealed that “32 captives were freed and arms surrendered” after dialogue engagements with Turji.

The Ripples Nigeria follow-up article on August 6, 2025, noted the initial peace gesture also included granting farmers access to fields previously sealed by insecurity.

This reporting matters for Kaduna’s model because it illustrates how local stakeholders and local administartors are creating openings for broader, state-level peace-building: releases, permissions for farmers to return to their fields, and limited disarmament that reduce immediate harms on the ground.

From Bandits to Peacekeepers

Perhaps the most striking evidence of this turnaround is the emergence of repented bandits now acting as protectors of the very peace they once shattered.

In Birnin Gwari, the once-dreaded ‘Jan Bros’ now patrols the same forests that hid his men, ensuring no new threats arise. In Southern Kaduna, a notorious figure known as ‘Yellow 1 million’ has become a mediator and peace advocate, preventing violence from resurfacing.

These conversions may sound improbable, but they are the real, raw fruits of a peace process that dared to engage rather than exterminate. As one security analyst put it, “Kaduna has done what many states only dream of — turning former adversaries into custodians of peace.”

Ongoing Engagement: A Living Model

The Kaduna Peace Model is not a one-off experiment; it’s a living, evolving process. Just last week, the special committee met again — this time with bandit leaders, district heads from Kajuru, Kauru, Kagarko and Kachia, alongside traditional rulers and local government chairmen. The meeting, chaired by Asadus-Sunnah, focused on consolidating existing gains and preventing any relapse.

This continuity — of dialogue, trust and surveillance — distinguishes Kaduna’s approach from earlier, short-lived peace efforts elsewhere in Nigeria.

Economic Rebirth: When Peace Pays Dividends

Peace has begun to yield tangible rewards. Farming in Giwa and Birnin Gwari and Southern Kaduna is at its most productive in years. Cattle trading, once crippled by fear, has roared back to life — with 20 to 30 trucks of cattle now plying routes that were sealed off by insecurity for decades.

The revival of commerce is not just economic; it’s symbolic — a reflection of dignity restored.

“Every reopened market is a victory over fear,” Governor Sani declared. “Every child back in school is proof that dialogue can defeat despair.”

The African Parallel: Peace Beyond the Gun

Kaduna’s model resonates far beyond Nigeria. Across Africa, nations have grappled with the futility of purely military solutions. From the Niger Delta Amnesty Programme to Rwanda’s post-genocide reconciliation and Uganda’s talks with the Lord’s Resistance Army, the lesson is the same: lasting peace is never born from the barrel of a gun — it is cultivated through inclusion, empathy and justice.

Governor Uba Sani and the ONSA team have localized this wisdom. Their approach demonstrates that soft power, guided by trust and backed by policy, can reclaim even the most hardened terrains.

Why the Kaduna Model Works

Three core principles underpin the Kaduna Peace Model:

1. Shared Ownership : Peace is co-created by communities, not dictated from government offices. Traditional rulers, youth, women, and security agents sit at the same table.

2. Socio-economic Inclusion : Reviving markets, schools and clinics removes the oxygen that fuels insurgency.

3. Trust through Consistency : Dialogue is ongoing, not episodic. ONSA’s involvement ensures institutional memory and continuity across agencies.

These principles align with public observations by National Security Adviser Nuhu Ribadu, who, in an interview with Channels TV on July 29, 2025, praised the unified non-kinetic strategy and confirmed that “hundreds of captives have been freed nationwide through coordinated peace-focused interventions.” Ribadu also noted that the “red-line now is credible intelligence, community involvement and permanent disengagement” rather than simply raids and arrests.

The Road Ahead

Even if sporadic threats still exist, the foundations of peace in Kaduna are firmer than before. Governor Uba Sani remains resolute: “We are not declaring victory; we are declaring commitment. Every day we sustain this peace is a day closer to permanent stability for our people.”

His words now echo across the once-desolate valleys of Birnin Gwari, other parts of Southern Kaduna and Giwa — places where gunfire has given way to the laughter of children and the hum of commerce.

Finally: A Lesson for Nigeria and Africa

The Kaduna Peace Model stands as living proof that even in Nigeria’s most volatile corridor, peace can be brokered through dialogue and sustained through development. It affirms a simple but profound truth — security without humanity is insecurity in disguise.

By partnering with the Office of the National Security Adviser, Governor Uba Sani has shown that the war for peace is not won in forests or airstrikes, but in hearts willing to forgive, leaders ready to listen, and communities bold enough to rebuild.

In Kaduna today, the guns are quieter, the roads are open — and hope is audible again.

•Malam Sani Liman Kila is Chief of Staff to the Governor of Kaduna State

By Sani Liman Kila For years, Kaduna’s name struck fear into the hearts of travellers and traders. Once-vibrant local economies in Birnin Gwari, Giwa, Kajuru and Kauru became graveyards of

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Wanted: Holistic Justice for Bamise

This article by Learned Senior Advocate Ebun-Olu Adegboruwa, discusses the sad case of 22 year old Bamise Ayanwole who was raped and murdered by Lagos State BRT Driver, Andrew Nice Omininikoron, who was convicted and sentenced to death after a protracted three year trial. Aside from explaining the lessons learned from this unfortunate incident, the Senior Advocate believes that for there to be holistic justice for Bamise, her family must be compensated by the Lagos State Government

Bamise’s Death and Conspiracy

n Friday, May 2, 2025, the High Court of Lagos State delivered judgement in the case of a driver in the employment of Lagos State, who raped and killed a lady passenger in cold blood. He was convicted and sentenced to death ,after a protracted trial that started in 2022. The deceased, Oluwabamise Toyosi Ayanwole was a young Nigerian lady who left her hometown in Ekiti State in search of greener pastures in Lagos, like many other Nigerians. She was 22 years old and the last child of her parents, Joseph and Comfort Ayanwole. She had nine other siblings and worked as a fashion designer, before her untimely death.

On February 26, 2022, after leaving work at Ajah area of Lagos State, Bamise boarded a Bus Rapid Transit (BRT) system at Chevron, Lekki heading to Oshodi on the Lagos Mainland around 7:30pm, with the intention of going to visit her elder brother’s family to spend the weekend. After boarding the bus, the driver flirted with her and told her to sit at the back. At the time, she was the only passenger in the bus and she observed that the interior was dark. She also noticed that, at least two other male passengers entered the bus afterwards. The driver did not pick more passengers. There were no CCTV cameras, in the bus. She immediately sent voice notes to her friend via WhatsApp, revealing her concerns. She also sent some video recordings of the bus interior with the bus plate number identifier to her friend, who advised her to alight as soon as possible at the next bus stop. Afterwards, further attempts by her friends and relatives to contact her via phone calls were unsuccessful. Prior to this, one of her last recorded conversations with her friend was “… Please, pray for me”. After several failed attempts to communicate with Bamise via her phone, the last known sound heard after a caller picked her phone revealed her struggling with an unidentified man. The following day, she was reported missing. On March 7, 2022, her lifeless body was discovered naked near the Carter Bridge on Lagos Island. An eyewitness stated that Bamise was still alive after she was thrown out of the BRT bus, but, she couldn’t be treated or rushed to the hospital before she died. There are conflicting reports in the media, as to whether her corpse was found whole or mutilated.

Arrest of the Culprit

The driver of the BRT was eventually traced and identified, as 50-year-old Andrew Nice Omininikoron. He kept mute after the incident. After Bamise’s disappearance was made public, he fled and went into hiding in neighbouring Ogun State. He was tracked down and arrested by the Department of State Security Operatives, and handed over to the Police for questioning and custody. He initially confessed to raping Bamise and abandoning her, but, he later changed his story, denying any involvement in her murder. He claimed that his bus was hijacked by armed robbers (referring to the men who entered the bus), who also kidnapped Bamise at gunpoint. His claims were challenged by Bamise’s relatives, friends and Nigerians. Accusations of rape and sexual assault were brought to light, by at least two other female victims of Andrew in similar circumstances. His suspected accomplices are also yet to be identified, to date. Public protests led to the suspension of BRT Transport operations in Lagos State, for some days.

The Criminal Trial

There was considerable public outrage regarding the circumstances leading to Bamise’s death, and demand for justice on her behalf. Initially, some mystery was woven around the incident which tended to mask the truth of what transpired, but, due to the vigilance of Bamise’s family, protest by Nigerians and extensive, relentless media coverage, the Lagos State Government swung into action.

Working with the Police and the family, investigation was expedited and the rapist killer was arraigned in Court on a five-count charge of conspiracy, felony, sexual assault, rape and murder. At the arraignment, the Honourable Attorney-General of Lagos State made a personal appearance, and vowed to ensure dutiful prosecution. He led the first prosecution witness, one Madam Odezulu, who narrated the vivid details of how Andrew (BRT driver) picked her up in Ajah the previous year on November 25, 2021, and forcefully raped her inside the same bus. In demonstration of the commitment of the Government to the trial, the Lagos State Director of Public Prosecutions was also involved in the trial, as well as other experienced Counsel from the Ministry.

I was present in court on one occasion, to witness the trial proceedings. The Police and the other law enforcement agencies teamed up with the Ministry of Justice, to ensure dutiful prosecution. Mr Kayode Aluko, a Fleet Operational Manager with the Lagos State BRT, also testified in court and identified Andrew as the driver of the bus in question. He was employed in 2021, through an outsourcing company. The case of the prosecution was very detailed and well packaged, such that one could reasonably predict the verdict of the court. On the other hand, the defence was very weak and porous. This resulted in delay tactics and filibustering by the defence to weary the prosecution and prolong the trial, leading to several adjournments, but: the public kept vigil with the court proceedings.

Upon the close of the prosecution’s case, the defence made a feeble no case submission which was promptly dismissed by the trial Court, prompting the Defendant to mount the witness box to testify in his defence. His case was very porous, weak and rather unconvincing. It therefore, did not come as a surprise to all that he was given the maximum sentence by the court, to give a sense of justice to Bamise’s family, to act as deterrent to other Andrews who may be lurking around, and also as a reward for the painstaking investigation and prosecution of the case. In its judgement, the trial court held that the prosecution successfully proved its case, relying on the doctrine of “last seen” and the deceased’s dying declarations to establish Ominikoron’s guilt.

The Lessons from Bamise’s Case

In the course of investigation of this case and the trial, several issues were thrown up, which deserve to be addressed. First, is that there are many unreported rape cases, due mainly to negative public perception and profiling, cultural limitations and religious constraints. Had the first victim Odezulu reported her case to the Police and the BRT authorities, Andrew may have been promptly checkmated.

Second, is the mentality of the Police, and their lame responses to citizens’ complaints. Usually, the Police should be a friendly institution that will encourage victims to speak out, but, that has not been the case. Indeed, there is a trending story that Complainants are forced to pay N50,000 before they are permitted to submit their petitions at a Police formation in Lagos. Then the Complainant has to fund the investigation, which has no standard measure, but is always dependent on the benevolence of the investigating Police Officer and the status of the Complainant. When Odezulu was asked by the defence Counsel during her cross-examination if she reported the case at the Police station, she said she did not do so because she had had a bad experience with the Police at Jakande Police Station, and that if she had reported, they would have insulted her. The common experience of rape victims is to be accused of indecent dressing, prostitution and such other degrading epithets.

Third, is the distrust for public commuting and public transportation generally. If what befell Bamise could happen in a Government facility, what then is the fate of commuters who patronise private operators daily? Hear Madam Odezulu: “After the incident, whenever I’m coming back from work and see any BRT bus, I used to look inside to see if it was him. I have seen him like four times at the Chevron Tollgate when he passed”. Imagine the trauma!

Another major lesson to learn from the Bamise case, is the intolerable delay in the administration of criminal justice. The trial started in 2022 and it was not concluded until 2025, spanning a long period of about three years. In the usual chequered history of trial of cases in Lagos, Bamise’s case is considered to have enjoyed accelerated hearing, perhaps, due to the direct involvement of senior officials of the Ministry of Justice and the public attention given to the case. The lesson here is to develop a mechanism of speedy adjudication of cases in the courts, so that parties will know their fate within a reasonable time.

Holistic Justice for Bamise

Justice in the Bamise case cannot and should not end with the verdict of the court, but should be extended to the family and her survivors. During the trial, the Defendant was confirmed to be an employee of Lagos State, which brings the issue of vicarious liability of the employer into focus. The crime took place right inside the BRT facility, owned and operated by the Lagos State Government. All worthy commendations go to the Governor, the law enforcement agencies and the Ministry of Justice for following up with the case to the end. However, a life has been lost and it cannot be replaced. The concept of justice will not be complete in this case, if there is no compensation for the Ayanwole family, in very reasonable proportions. Governor Sanwo-Olu paid compensation for all victims of #EndSARS, caused primarily by Police officers not under State control. It should therefore, not be difficult for the Governor to pay Bamise’s family in a case which is directly connected to and perpetrated by an agent of Lagos State Government. That will be real justice for Bamise.

Ebun-Olu Adegboruwa, SAN

This article by Learned Senior Advocate Ebun-Olu Adegboruwa, discusses the sad case of 22 year old Bamise Ayanwole who was raped and murdered by Lagos State BRT Driver, Andrew Nice Omininikoron, who was

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‘Inherited Colonial University Curriculum Requires Recalibration’

The Obafemi Awolowo University is not only one of the oldest in Nigeria, but, also has one of the oldest Law Faculties. The Faculty has birthed some of the most distinguished legal minds, including Judges, Senior Advocates, Academics, Businessmen, Politicians, and still counting. This has no doubt been without some challenges. Last week, the new Dean of this famous first generation Law Faculty, Professor Olugbemi Fatula had a chat with Onikepo Braithwaite and Jude Igbanoi on a wide range of issues, expressing his optimism about taking the Faculty to a higher academic pedestal, despite the obvious challenges

rof, you became the Dean of the Faculty of Law of Obafemi Awolowo University, one of the oldest Law Faculty’s in the country, a few months ago. But, a few years ago, OAU lost full accreditation. Has this challenge been overcome? What is the present status? What are your plans/agenda to restore the Faculty to its former glory?

Yes, the Faculty of Law, Obafemi Awolowo University, did experience a temporary setback when it lost accreditation some years ago. That experience was painful, but also purgative, because it compelled introspection and renewal. I often say that institutions, like individuals, sometimes go through seasons of pruning, in order to yield richer fruits.

I am pleased to say that, through the collective effort of the University management, my predecessors, and our committed Faculty members, the Faculty has long regained its accreditation. National Universities Commission (NUC) visited us last year for accreditation, and we were granted full accreditation. As you know, Law Faculties have two regulators – NUC and Council of Legal Education (CLE). The latter was to visit us shortly after I assumed office as Dean, but the visit was postponed through what I can term divine and transcendental intervention because our readiness was not complete. While some requirements and conditions for accreditation of the two bodies overlap, some notable differences exist in their expectations. For us to sustain the current wave of victorious accreditation outcomes, we are quite hopeful that when the re-scheduled accreditation visit eventually takes place, the outcome will meet our wishes, by the grace of God and the assistance of our distinguished Alumni and other well-wishers.

As Dean, my vision is anchored on three interlocking pillars: academic excellence, institutional renewal, and strategic partnerships. We are reviving and expanding the Ife Law and Allied Publications Series, under which a textbook on Legal Methods has already been published, with chapters contributed by our lecturers. The next in line is Introduction to Law, and subsequently, other core subjects such as Constitutional Law, Criminal Law, and Law of Contract etc.

The book publication project is very dear to my administration, because it presents us another opportunity to showcase the intellectual strength of the Faculty through the publication of high-quality and up-to-date law books. Our targeted audience goes beyond our students. It covers the broader Nigerian and international markets. However, we are constrained by funds. While the books are to be sold with minimal returns, raising the initial capital for production has been tough. Presently the Faculty can boast of five journals which are regularly produced, featuring well researched articles contributed by scholars within and outside the Nigerian state. In addition we are introducing another journal: Ife Journal of Law, Society and Developments. This review is intended to showcase our Faculty’s members contributions to discourse on contemporary topical issues of fundamental impact on law, society and development.

Again, we have set the machinery in motion to motivate our M.Phil./Ph.D. students to establish their own journal and submit, some of their already graded seminar papers for publication in the journal to be named Ife Postgraduate Students Law Journal. We are hoping that the maiden volume or part of the journal should be out in 2026.

Furthermore, we are revamping and repositioning the Obafemi Awolowo University Law Reports for productivity and viability. This Law Report, established in the Faculty by our Fathers, must not be allowed to go into extinction. Part of our plan is to engage the participation of private investors, in the production and sale of the journal. We also intend to encourage our students, particularly our postgraduate students and our alumni all over the world, to patronise the journal. Surely, the glory of the journal must be revived and solidified to the glory of God, the Supreme Essence.

Our administration also has certain programmes that we intend to implement, but, because we are yet to start, we wouldn’t want to mention them now, because of our belief as a transcendental Christian mystic that a plan not revealed has a better chance of success when implemented, than a plan revealed before any implementation.

We are also strengthening practical learning through the construction of a Clinical Legal Education Centre, which is being graciously sponsored by one of our eminently distinguished Alumni, who is a well known, public spirited Senior Advocate of Nigeria, SAN. This centre will bear his name upon completion.

Apart from the above, we have also presented a proposal for the establishment of a CENTRE FOR LABOUR LAW AND INDUSTRIAL STUDIES to be named in honour of another highly distinguished Alumnus of this great University. These are just a few of the steps, taken so far.

Several prizes and endowments have been instituted, to encourage academic excellence among our students. We intend to do more on this.

However, one of my key goals is to reinvigorate our alumni network. We are reaching out to our alumni across Nigeria and in the diaspora, to reconnect with their intellectual home. With their support, we will not only restore Ife Law’s glory – we will surpass it.

Recently, the Minster of Education announced that Mathematics would now be made compulsory for admission into any University, even for those who seek to study courses that aren’t related to Mathematics, such as Law. Has this policy been implemented by your Faculty? What are your views on the policy itself? Why would Law require Mathematics as a compulsory subject for admission?

I have followed the conversation around the compulsory inclusion of Mathematics for all university admissions, including Law, with deep interest. The policy, as far as I know, is not new in my Faculty.

Mathematics is not central to the study Law in reality. I believe that as far as Law is concerned, the status quo should remain.

In my O’ Level and A’ Level, I was in science courses before switching over to pure arts subjects due to several factors, in which inability to cope was not one of them. In fact, I considered and still consider mathematics and mathematically based subjects like Physics, to be easier than pure Arts subjects. The compelling factor is what I now call “Uncle Factor”. As you know, he who pays the piper dictates the tune. My Late uncle of blessed memory, a very kind hearted man, insisted that the family needed a Lawyer more than an Engineer. And, I became the family donation to the legal profession. So, to me, Mathematics is not a big deal. But, the question is:

Is introducing Mathematics as a requirement for admission into Law the solution, and what positive impact would that make on the quality of the legal profession?

It is true that Lord Denning, MR, and a few others, had their foundations in Mathematics and the Sciences. Indeed Roscoe Pound, the respected leading light of the American school of Sociological Jurisprudence had his background in Botany, where he had a Ph.D. But there are many equally great legal and judicial minds who had no background in Mathematics and related subjects. To me therefore, introducing mathematics makes no additional sense. Our policy makers should engage their minds on issues that would make positive impact on the profession. Introducing Mathematics at this stage is not one of them.

I must confess that I wouldn’t know the extent to which my years of flirtation with Mathematics, Physics, Additional Mathematics and Statistics has helped to shape my appreciation of Jurisprudence and Legal Theory. It could be that these subjects sharpened my analytical reasoning faculty, enabling my deep understanding of the logic and science of Law.

Some have argued that the curriculum for Law Students in Nigeria may be outdated. Even the Nigerian Law School, it has been suggested by some that Law should be made a second degree, or in the alternative, Law School should be made a two-year programme. It has also been argued that Law School may fast be becoming redundant, and that maybe it’s time to replicate what is done in US, where students prepare for the exams on their own and take the exams without a formal ‘Law School’ after obtaining the degree in Law. Kindly, comment on this

The debate about the adequacy of Nigeria’s legal curriculum and the structure of the Law School, is both timely and necessary. Law, as a living discipline, cannot be static. It must evolve with society. The curriculum we inherited from the colonial era has served us well in many respects, but, the time has come for a deep recalibration to reflect new realities – technology, artificial intelligence, environmental justice, gender dynamics, and global governance.

As a polyvalent thinker and transcendental mystic, I view legal education, not merely as professional training, but as civilisational formation. Our graduates must be philosophers of justice, architects of social order, and innovators in human governance. To that end, we need a curriculum that integrates law, technology, ethics, and leadership.

Regarding the Nigerian Law School, I would not call it redundant, but, rather, ripe for reform. The idea of making Law a second degree, as practiced in the United States, or extending the Law School to two years, has its merits. However, such proposals must be weighed carefully against Nigeria’s socio-economic realities.

Perhaps, the future lies in a hybrid model – where University Law Faculties are empowered to provide robust clinical and vocational training, and the Law School focuses on professional refinement, standards setting and ethical grounding. What matters most is not the form, but, the transformative quality of the legal mind we produce.

Left to me, the Council of Legal Education should be retained as the regulator and overall examination body. In other words, the point I’m trying to make is that private entities including established and reputable law firms as well as Universities’ Faculties of Law should be allowed to run law school’s programmes, while examinations, qualification criteria, practising requirements, among others, should reside within the purview of the Council of Legal Education. The Nigerian Law School should not be abrogated, but should also be part of the institutions or centres to be supervised and regulated by the Council, as it is currently. In view of the huge capital that the Nigerian State has spent on the establishment of the various campuses and their running, I won’t advocate for its cancellation, but, that it should have competitors while the Council of Legal Education should be the overall regulator. What we are advocating here is a sort of liberalisation of the professional legal education sector, with players drawn from public and private segments.

With this, the Nigerian State would be able to maintain high standards of legal education and practice.

The issue of sexual harassment is one that is everywhere – in the work place, in educational institutions, so much so that a University Lecturer of OAU was convicted and imprisoned a few years ago for harassing a female student. Even within our profession, some senior Lawyers are accused of harassing their female juniors, As a seasoned University Lecturer, can you tell us why this evil has become so prevalent in tertiary institutions? Do you think the laws enacted to curb sexual harassment in tertiary institutions have been effective? What more can be done to stem this ugly tide, which obviously is not peculiar to Nigeria alone?

Sexual harassment is a moral and institutional pathology, that thrives wherever power is abused and conscience is silenced. It is not peculiar to Nigeria; it is a global challenge that reveals the darker side of human relations – the misuse of influence, trust, and authority.

In Universities, the vulnerability of students and the authority of lecturers creates a delicate power dynamic. When ethical restraint collapses, exploitation can occur. But, beyond moral weakness, there is a deeper crisis of values – a failure to see others as sacred beings deserving of respect and dignity.

At Obafemi Awolowo University, we have taken strong measures to curb this evil. The University has policies and mechanisms for reporting and investigating sexual misconduct, and our Faculty upholds a zero-tolerance stance. The conviction of a former Lecturer, was a painful but necessary moment of institutional accountability.

However, laws alone cannot heal moral decay. There must be cultural renewal, ethical education, and spiritual reawakening. Students must be empowered to speak up without fear; Lecturers must be reoriented to see their vocation as a sacred trust, and their relationship with students as that of loco parentis; and society must stop normalising the trivialisation of sexual misconduct.

As a transcendental Christian mystic, I see this as a call for the restoration of conscience in the academy – the rediscovery of human decency as the foundation of knowledge. When we teach law, we must also teach love, justice, and respect – for without those, the law becomes hollow.

Tell us about the conditions of service of Lecturers? What are ASUU’s grievances? Are they germane? Presently, they have threatened to go on strike again, why?

The conditions of service for Lecturers in Nigerian universities are, frankly, less than ideal. To be a University teacher in Nigeria today, is to live perpetually between vocation and sacrifice. Lecturers are not merely employees; they are the custodians of a nation’s intellectual future. Yet, the economic and infrastructural support that should sustain that sacred duty is often inadequate.

The Academic Staff Union of Universities (ASUU) has been consistent in drawing attention to this reality. Its grievances, which include poor funding, salary stagnation, lack of autonomy, non-implementation of collective agreements, and infrastructural neglect, are not frivolous. They are germane, and speak to the soul of the University system.

When ASUU threatens to go on strike, it is less out of rebellion than desperation, a cry for institutional dignity. However, strike is avoidable when the Government is more responsive, and truly prioritises the education sector.

As a Faculty, we continue to motivate our staff intellectually and morally. We believe that, even within constraint, we can sustain excellence, but only if the nation rediscovers the value of the mind as its most precious resource.

Cultism has become the bane of most Nigerian Universities. What has been the experience of OAU? How do you control this in your Faculty? How effective is your screening process for new intakes into your Faculty?

Cultism is a tragic paradox. It represents the corruption of youthful idealism into destructive secrecy. The Obafemi Awolowo University has had its own difficult history with cultism, but, we have also developed one of the most resilient systems of prevention and response in the country.

At the Faculty of Law, we emphasise character as much as intellect. Our admission screening process is meticulous; we look beyond grades to the moral and psychological disposition of students. During orientation, we engage new intakes in mentorship programmes, introducing them to the noble ideals of justice, discipline, and community responsibility.

Our students also operate under the close mentorship of the Faculty Student Affairs Committee, in addition to Course Advisers who are close to students and attend to their needs promptly. We equally maintain an open-door policy, where students can confidentially report suspicious or troubling behaviour.

In the final analysis, cultism thrives where there is a vacuum of meaning. Our task, as educators, is to fill that vacuum with purpose, to show young people that greatness does not come from secrecy or violence, but from service and excellence.

Most Law Faculties in Nigerian Universities require their students to attend lectures in court regulation colours of black and white. Does your Faculty have this policy? What is the reason for this policy? Should Law students not be allowed to wear what they like, instead of being forced to dress as if they are still in secondary school?

Yes, our Faculty, like most Law Faculties in Nigeria, requires students to attend lectures in black and white attire. This is not a matter of authoritarian control or aesthetic preference; it is a symbolic discipline, part of the intellectual conditioning of a Lawyer.

The law is not only learned, but lived. It is a culture. The black and white dress code reminds students daily of the solemnity, order, and decorum required of members of the legal profession. It is a pedagogical tool, in character formation.

However, I agree that enforcement must be humane and intelligent. The goal is not uniformity for its own sake, but internal discipline and respect for professional ethos. A Lawyer who learns order in attire, is more likely to express order in reasoning and conduct.

As a Faculty, we also encourage freedom of thought and innovation. But, freedom without form becomes chaos; form without freedom becomes oppression. The black and white attire is our way of inculcating both, that is discipline without dullness.

What is the ratio of pass of OAU graduates at the Nigerian Law School?

The record of OAU Law graduates at the Nigerian Law School, has been consistently commendable. We maintain strong academic rigour at the undergraduate level, ensuring that our students develop not only legal knowledge, but also the critical and moral intelligence required for legal practice. While performance may vary across years, our graduates often rank among the top achievers.

However, we are not complacent. We are strengthening our pre-Law School preparatory sessions, integrating more clinical and problem-based learning, and maintaining mentorship relationships between our alumni in practice and current students. Our ultimate goal is not just to produce students who pass examinations, but Lawyers who transform society.

A few years ago, the Government came up with a policy that University Lecturers are required to earn a Doctorate Degree to become Professors. PhD Professors are said to be seriously depleted. What is the position in your Faculty/University?

The policy requiring a Doctorate Degree for appointment as a Professor, has long been entrenched in our Faculty. Undoubtedly, a Doctorate Degree promotes depth of scholarship and research culture. Today, I can authoritatively state that about 95% of our Lecturers have Ph.Ds, while all our Professors are Ph.D holders. As a matter of fact, this has been the tradition at OAU from the early 1960s, when the Faculty prided itself with the presence of legal juggernauts in the likes of Professors Ijalaye, Fabunmi, Oretuyi, Kasunmu, and Dr Akinola Aguda.

Interestingly, the Faculty enjoys the presence of Ph.D holders who received their postgraduate training within the Faculty and in some from other Law Faculties within the country, while some obtained theirs outside the shores of the country, thereby bringing diversity and depth to our teaching and research.

Post-UTME tests now come with an option to either take the test online or physical test. Which option does OAU Law Faculty adopt? Which is most reliable, and which option does your Faculty prefer, and why?

Technology is reshaping education globally, and universities must adapt intelligently. At OAU, the post-UTME process has evolved and now, it is done entirely online, though with strict monitoring and verification.

The future belongs to the University that can embrace innovations. OAU is positioning itself, to be that University.

The brain drain has become quite exacerbated, with a mass exodus of experienced Law teachers from Government Universities to Private Universities. Also, many have moved abroad. To what extent, has this affected your Faculty?

The brain drain phenomenon, is one of the most painful realities of our time. Many of our finest minds – in law, science, medicine, and the humanities – have sought better opportunities abroad or in private universities. This exodus has thinned the ranks of experienced teachers in public institutions, including ours.

At the Faculty of Law, OAU, we have indeed, felt the impact. Some of our valued colleagues have left. Today, our Faculty is grossly under-staffed and unless urgent steps are taken to rescue the ugly situation, it may constitute a serious threat to our future accreditation. But, not only that, the quality of teaching and research is bound to be negatively impacted, when lecturers are overwhelmed by official responsibilities.

Without exaggerating, our Faculty is the least staffed throughout the country especially in comparison with contemporary Law Faculties of ABU, UI, and UNN. This is in relation to the population of students vis-à-vis that of the teaching staff.

Sadly, the challenge that the Faculty currently faces is not limited to the shortage of academic staff, but, also paucity of funds. Without mincing words, the Faculty needs all the assistance it can get at the moment, especially from the alumni body to surmount the challenge of funds.

Ultimately, I believe no mind that truly loves truth ever leaves the University permanently. They may travel physically, but spiritually, they remain with us. Our task is to build a Faculty so excellent, that even those who left will long to return – to teach, to mentor, to give back.

Thank you Prof.

The Obafemi Awolowo University is not only one of the oldest in Nigeria, but, also has one of the oldest Law Faculties. The Faculty has birthed some of the most

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Legal Minds Seek Stronger Rule of Law, Digital Reform at PSDDF Dialogue

Legal and business experts have called for bold reforms, digital innovation, and institutional integrity to strengthen the rule of law and drive sustainable development in Nigeria. They made the call on Friday, at the 2025 Dialogue on the National Agenda for Democracy Strengthening (NADS), a landmark conversation dedicated to advancing judicial reforms and innovation in Nigeria.

The dialogue, organised by DigitsLaw in partnership with the American Business Council, the Centre for International Private Enterprise (CIPE), and NACCIMA, was held in Lagos under the theme: “Strengthening Specific Democratic Agencies: The Judiciary, Media, Electoral Bodies and Accountability Agencies”. It aimed to foster collaboration among policymakers, legal professionals, and private sector leaders towards a more transparent and technology-driven justice system.

Delivering his paper titled “Justice, Innovation, and Stability: Strengthening the Judiciary and Rule of Law for a Resilient Democracy”,Professor Bankole Sodipo, SAN, Dean of Law at Babcock University, emphasised that innovation and justice must go hand in hand. He highlighted the need to modernise legal education and courtroom procedures, including the adoption of artificial intelligence tools to improve efficiency. “Innovation in justice is not about technology alone”, he said. “It is about rethinking how justice serves the people – swiftly, fairly, and transparently.”

In his Keynote Address, Dr Anthony Idigbe, SAN, Chairman of Punuka Attorneys & Solicitors, underscored the central role of institutional integrity in sustaining the rule of law. He cautioned that without a strong ethical foundation and judicial independence, no technological reform would succeed. “The rule of law cannot thrive in an environment where systems are compromised by human weakness”, he said, urging stakeholders to strengthen judicial training, case management, and court infrastructure.

Speaking earlier in his welcome remarks, the Chairman of the Steering Committee of the Private Sector Development for Democracy Forum (PSDDF), Mr C.A. Candide-Johnson, SAN, described justice as the backbone of democracy and social progress. He called for the creation of a transparent and efficient justice ecosystem, that can attract investment and restore public trust. According to him, “A country’s justice system is the ultimate reflection of its values.

When people believe in the courts, they believe in their nation”.

In his goodwill message, the Managing Director of NACCIMA, Mr Olusola Obadimu, said the dialogue was convened to generate practical ideas for justice sector reform, and foster a culture of accountability and inclusivity in governance. He noted that Nigeria’s justice system must evolve with the realities of a digital economy, stressing that “the rule of law is not just a legal aspiration, but a development imperative”.

The Panel of discussants later explored how digital governance, arbitration, and legal-tech solutions can bridge existing gaps in access to justice. Participants agreed that integrating technology in case filing, record management, and virtual hearings could enhance transparency and reduce delays.

There was also a presentation by Miss Alaba Osho, Head of Communications and Partnerships at DigitsLaw, who unveiled a new software application designed to help Lawyers and law firms navigate financial, administrative, and client-relations challenges.

The event attracted top legal practitioners, academics, Judges, business leaders, and representatives of civil society – all united by a shared belief that a fair, efficient, and innovative justice system remains the foundation of national development.

Speakers at the Dialogue stressed need for judicial integrity, digital innovation, and inclusive reforms to strengthen Nigeria’s democracy

Legal and business experts have called for bold reforms, digital innovation, and institutional integrity to strengthen the rule of law and drive sustainable development in Nigeria. They made the call

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The Nigerian Legal Awards 2025, Slated for November 9

The ESQ Nigerian Legal Awards 2025 returns this year to celebrate excellence, innovation, and leadership within the legal profession; celebrating Lawyers who power businesses and shape economies.

The Publisher of Esquire Legal Magazine, Mr Lere Fashola, said in a release that “This year’s edition reinforces our commitment to spotlighting the transformative role of legal excellence in shaping commerce, justice, and national progress”.

Honouring Excellence, Integrity, and Impact

Among this year’s distinguished and very special honourees are:

• Babatunde Raji Fashola, SAN, Lawyer and Former Minister of Works of Nigeria

• Dr Jumoke Oduwole, Federal Minister of Industry, Trade and Investment

• Mr Festus Keyamo, SAN, Minister of Aviation

• Alhaji Hamed Raji, SAN, recipient of the Lifetime Achievement Award

• Dr Kayode Ajulo, SAN, Honourable Attorney- General of Ondo State

• Oyinkan Badejo-Okusanya, SAN, honoured as Legal Amazon of the Year, a recognition dedicated to exceptional female Lawyers.

Institutional Awardees include:

Securities and Exchange Commission (SEC) Nigerian Education Loan Fund (NELFUND) Standards Organisation of Nigeria (SON) Presidential Enabling Business Environment Council (PEBEC), Zenith Bank Plc, Nigerian Breweries Plc, Rendeavour Nigeria & Alaro City, and Oando Plc, among others.

A Tradition of Credibility and Distinction

Since its inception, the Nigerian Legal Awards has established itself as a legacy event within the legal and business community, celebrating exceptional individuals and institutions that exemplify professional excellence, ethics, and innovation.

Over the years, the Awards have honoured legal icons such as former Vice President Yemi Osinbajo, SAN; Chief Wole Olanipekun, SAN; Aare Afe Babalola, SAN; the late Oluwarotimi Akeredolu, SAN; Chief Bayo Ojo, SAN; late Hon. Justice Muhammed Uwais, CJN (Rtd) and Hon. Justice Alfa Belgore, CJN (Rtd).

The Law Firm Practice Area Categories

This flagship segment celebrates law firms and practice groups that have demonstrated exceptional skill, innovation, and commercial impact over the past 18 months. The category is deal-driven, assessing how legal solutions have directly influenced the success of clients’ businesses.

The Nigerian Rising Stars: 40 Under 40 Category

The Nigerian Rising Stars Award recognises 40 exceptional Lawyers of Nigerian descent under the age of 40 who have demonstrated leadership, innovation, and remarkable promise early in their careers. These are young professionals whose reputation, influence, and intellectual brilliance embody the finest ideals of the legal profession. Nominees are drawn from both local and international organisations — including law firms, corporations, NGOs, and regulatory agencies.

The Editors’ Merit Awards

This prestigious category honours distinguished individuals who represent the highest ideals of the legal profession – integrity, excellence, and enduring impact. The Editors’ Merit Awards celebrate legacies that transcend legal mastery to include transformative contributions to governance, policy, and national development.

Event Details

The event will hold on 9th November, 2025 at the Landmark Event Centre, Water Corporation Drive, Oniru, Victoria Island, Lagos.

The ESQ Nigerian Legal Awards 2025 returns this year to celebrate excellence, innovation, and leadership within the legal profession; celebrating Lawyers who power businesses and shape economies. The Publisher of

Battle for Ownership of 9mobile Moves to the Court of Appeal

Stories by Steve Aya

A businessman, Alhaji Abubakar Ismaila Isa, has filed a Notice of Appeal challenging the Ruling of Honourable Justice M.G. Umar of the Federal High Court, Abuja, delivered on the 24th day of September, 2025 in Suit No.: FHC/ABJ.CS/1971/2024.

Alhaji Abubakar Ismaila Isa had earlier sued Seltrix Limited & 8 Ors with respect to illegal transfer of 43 million ordinary shares in the capital of Teleology Nigeria Limited.

The Notice of Appeal was filed on the 13th day of October, 2025 at the Registry of the Federal High Court, Abuja. The Respondents in the appeal are Seltrix Limited, Hayatu Hassan Hadejia, Teleology Nigeria Limited, Mohammed Edewor, Emerging Markets Telecommunication Services Limited, Corporate Affairs Commission, Nigerian Communications Commission, LH Telecommunication Limited, and Gen. Theophilus Yakubu Danjuma.

The Judge struck out the Suit of the Appellant on the ground that the Appellant has no locus standi to institute the Suit. The Court in its Ruling held “I carefully perused the said exhibit to see if the allegation of the Plaintiff is substantiated, I did not find any. Nowhere was there any figure of the 43 million ordinary shares held in trust for the Plaintiff by the 1st Defendant mentioned…”.

However, the Appellant, Alhaji Abubakar Ismaila Isa faulted the decision of the Court in his Notice of Appeal, as contained in his two principal grounds of appeal. The Appellant insists that locus standi (the legal standing to sue) should be determined solely from the Writ of Summons and Statement of Claim, as per established case law (Pharmatek Ind. Ltd. v Trade Bank Nigeria Plc).

‎Abubakar Isa, through his legal team led by Femi Atteh, SAN, states that the lower court failed to recognise that when locus standi is challenged, all claims in the Statement of Claim should be accepted as correct. ‎The Appellant also raised the ground of improper consideration of substantive issues, at the preliminary stage.

‎Abubakar Ismaila Isa is contending that, the trial Judge incorrectly delved into the substantive issue of trust between the Appellant and the 1st Respondent, in his Ruling on the preliminary objection. ‎The Appellant said whether a trust existed regarding 43 million shares or not is a substantive issue, not to be decided before full trial.

‎The Appellant asserts that the 1st Respondent holds the shares in trust and has breached that trust, establishing the basis for locus standi. The Appellant is relying on Sections 10 and 11 of the Federal High Court Act.

‎Abubakar Ismaila Isa is, therefore, praying the Court of Appeal to allow the appeal and set aside the Ruling of the Federal High Court dated September 24, 2025. ‎He is also praying the Appellate Court to remit the case file to the Chief Judge of the Federal High Court, for reassignment to another Judge to hear and determine the Suit properly.

‎The Registrar of the Federal High Court has summoned all parties to appear on November 5, 2025 for the settlement of the Record of Appeal at the Federal High Court Headquarters in Abuja.

Stories by Steve Aya A businessman, Alhaji Abubakar Ismaila Isa, has filed a Notice of Appeal challenging the Ruling of Honourable Justice M.G. Umar of the Federal High Court, Abuja,

Whether Proof of Resulting Trust Can Invalidate Legal Title to a Property

In the Supreme Court of Nigeria

Holden at Abuja

On Friday, the 14th day of April, 2025

Before Their Lordships

Ibrahim Muhammed Musa Saulawa

Emmanuel Akomaye Agim

Chioma Egondu Nwosu-Iheme

Stephen Jonah Adah

Jamilu Yammama Tukur

Justices, Supreme Court

SC.1049/2016

Between

MICHAEL AFOLAJIMI JOLUGBO APPELLANT

(Suing on behalf of himself and other

Beneficiaries of the Estate of M.A. Julogbo)

And

1. MRS O.A. AINA RESPONDENTS

2. LAGOS STATE DEVELOPMENT AND

PROPERTY CORPORATION (L.S.D.P.C)

(Lead Judgement delivered by Honourable Jamilu Yammama Tukur, JSC)

Facts

The appeal challenges the judgement of the Court of Appeal, Lagos Division, in Appeal No. CA/L/362/14 delivered on 30th March 2016 against the Appellant. The dispute centred on the validity of the title transfer of Flat 5 Block A 78, LSDPC Low-Cost Housing Estate, Dolphin, Anikantamo, Lagos, from the late Mr Olayinka Aina to the late M.A. Julogbo. Believing the 1st Respondent, who is Mr. Olayinka Aina’s wife was frustrating the sale, Mr. Aina and Mr Julogbo’s late father initiated Suit No. LD/3276/94 at the High Court of Lagos State, seeking a declaration that Mr Aina was the legal and beneficial owner of the property, that the title transfer to Julogbo was valid, and that Julogbo was entitled to possession. The 1st Respondent also filed Suit No. LD/769/97, claiming a trustee relationship existed between Mr Aina and herself, and that she is the beneficiary of the trust. She asserted that though the tile document of the property is in her husband’s name, she provided the funds for purchase of the property which was held in trust for her. She thereby, sought to set aside the sale to M.A. Julogbo.

The cases were consolidated for trial. On 19th November, 2004, the trial court found that a trust relationship existed between the 1st Respondent and Mr Olayinka Aina. The court, accordingly, set aside the sale. The Appellant’s late father and Mr Aina appealed, but, the Court of Appeal dismissed the appeal on 30th March, 2016. Dissatisfied, the Appellant, on behalf of other beneficiaries of Mr Julogbo’s estate, filed an appeal to the Supreme Court.

Issues for Determination

Two issues were raised in the Appellant’s brief for determination, thus:

i. WHETHER the court processes filed by the 1st Respondent in the consolidated suits, are competent as to vest the lower court with jurisdiction to determine her right over the property in dispute?

ii. WHETHER from the evidence before the lower Court, a Resultant or implied Trust, can be implied to exist in favour of the 1st Respondent? If the answer is in the negative, whether the lower court, having found that the legal title resides in the 2nd Claimant, should not have held that the said Claimant validly transferred the legal title to the 1st Claimant?

Counsel for the 1st Respondent on his part raised four issues for determination of the appeal, while Counsel for the 2nd Respondent formulated two issues. The Supreme Court opined that the central question in the appeal is – Whether the lower courts were right to have granted the 1st Respondent’s title over the disputed property, on the principle of resulting trust.

Arguments

Counsel for the Appellant argued that there is no evidence, explicit or implied, demonstrating that Mr Olayinka Aina intended to transfer the property to the 1st Respondent on trust. He posited that at trial, the 1st Respondent produced no documentary title, but relied solely on oral testimony, which was outweighed by the substantial documentary evidence of title presented by the husband. Counsel supported this position with the authorities EZENNAH v ATTA (2004) 17 W.R.N. 1 S.C., MADU v MADU (2008) 2-3 S.C. (PT. II) 109, and FAGBENRO v AROBADI (2006) 19 W.R.N. 1 S.C. He submitted further that the 1st Respondent failed to establish any of the five recognised methods enumerated by the Supreme Court, to prove ownership of the disputed property. Conversely, the husband presented documentary evidence supporting his ownership. The Appellant placed reliance on the documents emanating from the 2nd Respondent, and there is no single document of title registered in the name of “Mrs Aina”, the 1st Respondent. Counsel relied on the authority of OJOH v KAMALU (2006) 6 W.R.N. 110 S.C. and AGBAREH v MIMRA (2008) 1 S.C. (Pt.3) 88, to buttress his submission.

Counsel contended that, Mr Aina had legal authority to transfer title to the Appellant. He argued further that, even if the 1st Respondent’s claim of a resulting trust were to succeed, the Appellant would still qualify as a bona fide purchaser for value without notice—be it actual, constructive, or implied – as the Appellant duly conducted a title search at the 2nd Respondent’s office, which confirmed allocation to the said Mr Aina, with no indication of any trust affecting the property. Lastly, he argued that the 1st Respondent’s evidence regarding payments for mortgage and repairs, does not override the superior title evidence adduced by Mr Aina, and does not support her claim to a resulting trust. Furthermore, these documents are inconsistent with her testimony, where she expressly stated that she had no direct dealings with LSDPC and LBIC.

On the part of the 1st Respondent, Counsel contended that during the trial, the 1st Respondent, through both oral and documentary evidence, successfully established the circumstances giving rise to a presumption of a resulting trust in her favour. This formed the basis for the concurrent findings of the trial Judge and the Court of Appeal Justices, that a resulting trust indeed, existed in favour of the 1st Respondent. It was argued that the 1st Respondent paid the initial fees, contributed significantly to the property’s development, made mortgage repayments, and paid for the mandatory insurance policy on the flat, with her father acting as Guarantor, despite her husband’s father being alive during the relevant period. Counsel clarified further that the 1st Respondent did not dispute that legal title to the property was vested in her husband, as his name appeared on the title documents; however, she maintained that the equitable interest belonged to her, given her financial contributions toward the purchase and related expenses, thereby, creating a resulting trust for which she is the beneficiary.

Counsel submitted that the Appellant’s claim to ownership based solely on the title document bearing the name of Mr Aina was misplaced, as proof of a resulting trust invalidates the title. Counsel argued that the defence of a bona fide purchaser without notice would not succeed, because the Appellant’s father failed to exercise due diligence. The father did not demand the original title documents before the purchase, and admitted he neither inspected the flat nor investigated the tenancy, which would have revealed that the property belonged to the 1st Respondent. It was contended that Mr Aina acted in bad faith, and colluded with the Appellant to deprive the 1st Respondent of her proprietary interest. This argument referenced CLAY INDUSTRIES NIGERIA LTD v AINA (1997) 8 NWLR (PT. 516) P. 208; FASESIN v OYERINDE (1997) 11 NWLR (PT. 530) 552; GBADAMOSI v AKINLOYE (2013) 15 NWLR (PT. 1378) P. 455; ABBA v S.P.D.C.N LTD (2013) 11 NWLR (PT. 1364) P. 86; and ORONTI v ONIGBANJO (2012) 12 NWLR (PT. 1313) P. 23.

Court’s Judgement and Rationale

In resolving the issue of whether, given the circumstances of the case, a trust exists between Mr Olayinka Aina and the 1st Respondent (Mrs. O.A Aina), the Supreme Court distinguished between express trust and implied trust. Their Lordships explained that an express trust is evidenced by a trust deed, which clearly identifies the parties to the trust. In the case of an implied trust, resulting or constructive trust, an implied trust arises when the court infers the existence of a trust from the circumstances surrounding the acquisition of the property. In such cases, the beneficiary of the trust is recognised as the true owner of the property, even though the legal title is held by the trustee. As a result of this, “the trustee must deal with the property in a way that would corrode the interests of the beneficiary.” The Supreme Court relied on its earlier decision in HUBNER v AERONAUTICAL INDUSTRIAL ENGINEERING & PROJECT MANAGEMENT CO. LTD (2017) LPELR 42078(SC) (Pp 10 – 11 Paras D-E) where it was held that “when property has been acquired in such circumstance that the holder of the legal title may not in good conscience retain the beneficial interest, equity converts him into a trustee … Constructive trust is neither granted nor accepted, but it is foisted upon the parties by the operation of law”.

Applying the above principles of trust to the facts of this case, the Supreme Court held that “the circumstances were one in which a trust relationship could be validly read into between the 1st Respondent and her deceased husband, the 2nd Claimant at trial, to the effect that she advanced money to her husband to buy a house on her behalf, so that even though he is the legal owner and his name appeared on all documents of title, her right is superior because she is the ultimate beneficiary and the true owner.”

The court noted further that the Appellant’s argument, relying on the existence of legal title documents and the 1st Respondent’s failure to prove ownership by conventional means, was misplaced. The issue was not about legal ownership of the property, but rather whether the legal owner (the 2nd Claimant at the trial court) held the property in trust for the 1st Respondent. The Supreme Court emphasised that the 1st Respondent’s status as beneficial owner, is supported by the fact that she funded the purchase and made mortgage payments on the property.

The court concluded that the Appellant failed to give concrete grounds, for the Supreme Court to abrogate from the concurrent findings of the lower courts. Consequently, the court dismissed the appeal for lacking in merit.

Appeal Dismissed.

Representation

Oladele Ojogbede for the Appellant.

Micheal A. Aribisala for the 1st Respondent.

Olugbenga Ajala for the 2nd Respondent.

Reported by Optimum Publishers Limited, Publishers of the Nigerian Monthly Law Reports (NMLR)(An affiliate of Babalakin & Co.)

In the Supreme Court of Nigeria Holden at Abuja On Friday, the 14th day of April, 2025 Before Their Lordships Ibrahim Muhammed Musa Saulawa Emmanuel Akomaye Agim Chioma Egondu Nwosu-Iheme

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NSC Boss Promises to Encourage Wushu Chinese Martial Art in Nigeria

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New Era for Niger Rep. Football as FIFA Opens Two Mini-pitches in Niamey

The West African country of Niger Republic witnessed historic moment in their football history after global soccer governing body, FIFA, on Friday inaugurated two mini-pitches as part of the FIFA Arenas project

The two pitches situated at the CES 22 Talladje and CES 9 Harobanda primary school, both in the capital Niamey, ensures Niger becomes one of the 11 Member Associations to benefit from the initiative which has one of key projects under the FIFA Forward programme.

The ultramodern sustainable facilities will provide students with a safe and inspiring space to hone their football skills, giving a ray of hope to about 10,000 youth in communities within the two schools.

The project is expected to impact positively and allowing youth from surrounding communities to play football in ideal conditions, promoting social inclusion, personal growth, and passion for sport.

FIFA President, Gianni Infantino, cited the project as a watershed moment for football development in the West African country.

“Congratulations to the Nigerien Football Federation (FENIFOOT). You are part of our Starting 11—the first 11 countries to officially inaugurate their own FIFA Arena mini-pitches. You are contributing to a project capable of changing the lives of millions of children,” Infantino said.

His declaration was echoed by Issaka Adamou, FENIFOOT President who said the landmark project will mark a new chapter for grassroots football development in the country.

“When football becomes an educational tool, it’s a whole country preparing its youth’s future. Niger is committed to inclusive, dynamic, and civic-minded schooling through the power of sport. Integrating football into schools to strengthen civic education, social inclusion, and youth development through sport allows Niger to take a major step forward with FIFA for grassroots education and football.”

The FIFA Arena project is part of a global initiative to build mini-pitches worldwide, in line with the commitment made by the FIFA President Infantino at the Sustainable Sport Summit in Paris in July 2024. The project supports the United Nations Sustainable Development Goals by offering more play opportunities to children, especially in disadvantaged urban and rural areas.

The Starting Eleven code-named from the 11 players commencing a game has seen Member Associations (MA’s) such as Georgia, Thailand and Paraguay inaugurating similar FIFA Arena mini-pitches. The project is being rolled out globally with the goal of installing at least 1,000 new mini pitches by 2031.

In Africa, Niger is the third Africa country to benefit from the initiative after Algeria and recently, Liberia.

The FIFA Arena comes under the bigger FIFA Forward scheme launched in 2016, and seeks to fairly redistribute FIFA’s revenues to its 211 member associations. Dubbed the world’s largest sports development programme, it is in line with FIFA’s plans to invest a record USD 5 billion in football by the end of 2026.

Similar views were shared by Elkhan Mammadov, FIFA Chief Member Association Officer who remarked “I’m delighted to see Nigerien youth inaugurate these FIFA Arena mini pitches today. These brand-new spaces offer Niamey’s children a safe and inspiring environment to play and grow through football.

Meanwhile, construction of FENIFOOT’s new headquarters, funded by the FIFA Forward programme, is progressing steadily as the six-storey facility will offer a professional and structured environment for football development in the country.

“The FIFA Forward programme is tangibly transforming football in all FIFA member countries. In Niger, the new FENIFOOT headquarters and mini pitches in Niamey illustrate FIFA’s commitment to making football truly global, inclusive, and sustainable by investing in infrastructure that strengthen the football landscape,” highlighted Gelson Fernandes, Deputy FIFA Chief Member Associations Officer and Regional Director for Africa.

The state-of-the-art building aligns with FENIFOOT’s strategy to improve infrastructure, enhance working conditions for staff and regional league personnel, and expand accommodation capacity at the technical center. With a total cost of nearly USD 4.2 million, the project is fully funded by FIFA Forward and will take at least 12 months to complete.

The West African country of Niger Republic witnessed historic moment in their football history after global soccer governing body, FIFA, on Friday inaugurated two mini-pitches as part of the FIFA