A paper presented by Prof. Abiodun Amuda-Kannike, SAN, Provost, College of Law, Kwara State University, Malete, via Ilorin, Kwara State, at the Nigeria Association Of Muslim Law Students (NAMLAS), National Seminar held at, Faculty Of Law, Al-Ikmah University, Ilorin, Kwara State, on Thursday, 25th, July, 2019.
Prof. Abiodun Amuda-Kannike (SAN)
Presenter: Prof. A. Amuda – Kannike (SAN) CIAP
Tel & Email: 08033256756, amudakannikeabiodun@gmail.com
INTRODUCTION
The relationship between ethics and the legal profession is just like that of twins who must survive in the society in such a way that no one can do without the other one. The relationship between ethics and the legal profession for a just society cannot be over emphasized as the lawyers from time to time are expected to follow certain legal standards whether they represent their clients or not.[1]
Before going into the discussion of the above topic, it is better to define the keywords involved herein such as “ethics”, “fulcrum”, legal profession, “crux”, “lawyer” and “just society”.[2]
Ethics referred to the moral principles guiding persons in the society to behave in certain ways in order to avoid misbehaviors and destruction of the expected standards in a society. It guides behaviors and attitudes in such a way as to achieve decency.[3]
Ethics has been described as moral principles that govern a person’s behavior or the act of conducting activity; or activities.[4]
Ethics has been further described as the branch of philosophy that deals with morality. Ethics is concerned with distinguishing between good and evil in the world, between what is right and what is wrong in human actions and activities and between virtuous and non-virtuous characteristics of the persons in the society.[5] Legal ethics is the minimum standards of appropriate conduct within the legal profession. It is the behavioral norms and morals which govern judges and lawyers.
The next question is; “what is Fulcrum?”. Fulcrum means, a thing which plays a central or essential role in an activity, event or situation.[6] The word Fulcrum means bed post in Latin and it derives the verb “fulcire” from Latin which means “to prop”. In the 17th century when the word first appeared in English, the said word, “fulcrum” refers to the point on which a lever or similar devise (such as the oar of a boat) is supported.[7]
Again, it is necessary to define what legal profession entails. Legal profession is a profession where a person works by studying the law, developing the law and applying the law in court, offices and other administrative activities as a daily routine.[8] It is a vocation that is based on expertise in the law and in its applications.
The word “crux” means the decisive or most important point at issue. “crux” means a puzzling or difficult problem: an unsolved question. It also refers to an essential point requiring resolution or resolution of an outcome. For example; “the important point for a successful lawyer”. “the problem of a successful Lawyer”.[9]
Lawyer means a person who practices or studies law, especially, a solicitor or a barrister or a barrister and solicitor. A lawyer has been further defined as a professional who is qualified to offer advice about the law or represent someone in legal matters. A lawyer at the same time is also called;[10]
(i) Attorney
(ii) Solicitor
(iii) Counselor
(iv) Barrister
A just society is a society which is united, they are united because all the citizens of such society will be actively involved in the development of the country where, equality of opportunity will prevail and individuals will be free to fulfill their objectives as par the goals set out for his or herself.[11] A just society which we have in mind here is one which upholds liberty, equality, social justice, tolerance, etc.
It is important to state that in this work, we shall look at the rules of professional conduct for legal practitioners one after the other as it relates to the ethics expected in the legal profession and assess whether or not, the positive ethics of a lawyer bring success to him and the society. This method will lead to doing justice to this work as expected.
GENERAL RESPONSIBILITY OF A LAWYER
The Lawyer is expected to uphold and observe the rule of law, promote and foster the cause of justice, maintain a high standard of professional conduct and shall not engage in any conduct which is unbecoming of a legal practitioner.
The above rule express a general ethical standard a lawyer is expected to exhibit from time to time. It has been said that because the status a legal-practitioner occupies in the eyes of the members of the society as being above board in ethical norms, the legal practitioner must not misbehave.
The above responsibility of a lawyer put the lawyer down as the best in character among the members of every given society, he must watch his conduct in making sure the rule of law is observed and that the cause of justice is not defeated.[12]
It is pertinent to observe that the above duty of a legal practitioner shall include the following;
(i) The duty of a lawyer is not to aid knowingly and unknowingly a person who is not qualified to be admitted into the legal profession.[13]
(ii) The Lawyer must not be involved in aiding a non-lawyer to practice law in any manner whatsoever[14] or to allow his or her name to be use for legal practice.
(iii) There should be avoidance of being controlled through unholy alliance with agents,[15] corporate organizations and persons who may link the legal practitioners with clients, however charitable organizations are not seen as agents and the lawyer must not form partnership with a non lawyer.
(iv) The lawyer who has acted as a Magistrate or as other Judicial officer should not take up matters they have decided or handled as judicial officer earlier.[16] The Magistrates are however not precluded from handling matters in court. Only the retired judges are precluded.
(v) The Lawyer is not expected to do any other business as at the time, he practice as a lawyer except he sought the permission of the Bar council, such businesses includes, buying and selling, commodities, commission agents or such businesses that are not in consonance with the practice of a Lawyer or which is disgraceful to be combined with the standard of a practicing Lawyer. The only exception in terms of business are;
(a) Membership of board of directors, of a company, but must not involve executive, administrative, and (b) Clerical functions, secretary of a company, or (c) Being a share holder of a company.[17]
(vi) Lawyers who are on salaried employment shall not appear as Lawyers in any court of Law for their employer, however Lawyers employed as legal officer in government department can appear in court for their employer.[18]
The Lawyers who failed to pay their practicing fees as at when due are in breach of the professional ethics and such payment are to be made as at 31st day of March, every year. Several Lawyers have been denied being made Senior Advocates of Nigeria (SAN) for failure to pay their practicing fees as at when due[19] and such Lawyers cannot sign nor file any legal document when in default of the payment of filing fees. In order to compliment the issue of payment of practicing fees, Lawyers are expected to affix stamp and seals on all legal documents prepared by them, however no Lawyer will be given stamps and seals except he or she has paid the practicing fee for each year.[20]
(vii) The lawyer is encouraged to succeed in legal practice and to do this all Lawyers are expected to be involved in mandatory continuing professional development (CPD) and these is compulsory as the rule use the word “shall”. This includes, seminars conferences, writing of books or any activity to promote knowledge as approved by the Nigerian Bar Association.[21]
(viii) The Lawyer is entitled to annual practicing certificate[22] which are to be given to those who pay their practicing fees and also attend the mandatory continuing professional development programme and this certificate is mandatory for a Lawyer to practice every year and the courts are entitled to enforce this in court but its unfortunate that the N.B.A itself has breached this rule by not issuing this certificate promptly or at all.
(ix) The Lawyer must notify the branch of the N.B.A if and when he set up an office,[23] he must be dedicated and devoted to the cause of the client,[24] he must represent the client within the bounds of the law,[25] and he must represent the client competently.[26]
(x) The lawyer must not be involve in conflict of interest especially in the cases, he is handling.[27]
(xi) The lawyer cannot insist on representing a client who wish to dispense away with him but the client must fulfill his agreement with the Lawyer including payment of fees.[28] It is however dishonorable conduct for the Lawyer to fail to fulfill performance of contract made with his client whether reduced into writing or not.
(xii) The lawyer owe a high duty to keep the secret of his client whether oral or in writing, he must not use the secret of his client to his advantage or to the advantage of a third party.[29]
(xiii) The lawyer should as far as possible avoid being used as a witness in a case he is handling but there are situations where he may give evidence.[30] The lawyer shall not abandon or withdraw from a case or job once he has taken same but can do so, if he can show good cause to withdraw from such case or job.
(xiv) The lawyer is not expected to go to a client house[31] or office to take brief to avoid lowering his standard. The Lawyer should not do any act whereby he obtain personal benefit or gain by taking advantage of the confidence reposed in him by the client.[32] There have been a lot of Lawyers disrobed by Legal Practitioners Disciplinary Committee for using their position to take the properties of their clients.
(xiv a) When the proper professional fees is offered, it is the duty of the Lawyer to take the job except he declines on good reason or special personal interest.[33]
(xiv b) The Lawyer must not bargain with a witness to give evidence or interview with opposing witness without his Lawyers consent or on contingent fee[34] to give evidence neither should the Lawyer abuse a witness in court or insult the witness.[35]
(xiv c) The Lawyer must relate well with other lawyers and there should be no ill-feelings among each others, he must appreciate seniority.[36] There should be good faith and fairness among Lawyers.[37]
A Lawyer shall make sure that if he is taking over a brief and the other lawyer is debriefed, he is to ensure the fees of the debriefed Lawyer is paid.[38] When a new Lawyer has been briefed, he shall serve on the court and the old Lawyer, the notice of change of counsel.[39]
(xiv d) The Lawyer is expected to have good relationship with the court, and conduct himself well in court, he must be candid and fair, he must relate well with the judge with respect, he must exhibited highest degree of court decorum, no special gain or favour must be shown to have been gained by a Lawyer from a judge he is appearing before nor make statement prejudicial to the case in court and a Lawyer defending a criminal case must exhibit high standard in conducting the case or where he is prosecuting, Lawyers for an indigent accused he shall work for him till the end except there are substantial reason to withdraw.
(xiv e) The Lawyer must not be involve in improper attraction of business but nothing stops him from using note-papers and visiting cards, signs and notices, books and articles can contain the Lawyers name and titles, notice of change of counsel is not prohibited from being filed.[40]
(xiv f) The lawyer must dress well to court in his robes, no advertisement should be done in the Press, Radio and Television, a lawyer must not instigate litigation, a Lawyer fee must be fair and reasonable, he can be on retainer but can enter into a reasonable contingent fee, but must not be contingent fee contract affected by fraud, mistake, undue influence or contrary to public peace, no contingent fee contract on criminal case is allowed to be entered upon. No Lawyer is allowed to enter into agreement to foot litigation fees but it can be done, if it is convenient to do so and subject to re-imbursement. The amount charged by the Lawyer for his services must be reasonable and commensurate to the work done and the fees must not be expensive unreasonably. No Lawyer is all owed to share his fees except with a lawyer with respect to division of services.[41]
(xv) No lawyer is allowed to accept compensation, rebate, commission, gift from or on behalf of opposing party except this is done with the knowledge and consent of his client.[42]
It is to be appreciated that the ethical standards expected of a Lawyer is compulsory and so important that any breach of those ethical standards;[43]
(i) amount to the Lawyer being guilty of professional misconduct and liable to punishment in accordance with the legal practitioners Act which could be punishment of being suspended or derobed[44].
(ii) may not allow such person (Lawyer) to be appointed as a Senior Advocate of Nigeria (SAN) or even as a judge.[45]
(iii) may lead such Lawyer to loose respect and dignity from other lawyers and members of the public which may lead to clients taking their files and withdrawing their services from such Lawyer.
SUCCESSFUL LAWYER
To be able to define the meaning of a “successful Lawyer”, it is important to define what is meant by “success”.
According to Merriam Webster, success[46] is a favourable or desired out come. Now the question is; does winning one case or two qualify you as a successful lawyer? Must the winning of cases be three, four or ten cases within a week, a month, within six months or a year? This is part of the complications in the definition.
Merriam Webster also added another complication to the definition of success when he said, success can also be described as being financially buoyant, being wealthy, being favoured and being eminent in the society. The problem with the definition again is; how rich must you be to be described as being successful? How much must be ones financial standing before being described as successful.
But more difficulty can be seen also because, a person may be wealthy or famous, yet he may not be rich or may not have financial prosperity.
The way people see success varies from circumstance, people to people and societies to societies.
It is however important to state that there are certain attributes which the society in Nigeria including the legal profession look at as being associated with a successful lawyer in Nigeria which are thus;
(i) Being made a Senior Advocate of Nigeria (SAN).
(ii) Being made a member of the Body of Benchers.
(iii) Having a good chambers/law office.
(iv) Being able to act as Mentor to Junior Lawyers who work in your office and taking care of their financial responsibilities whether directly or indirectly and being able to train them well in the practise and appreciation of the law.
(v) Being relatively financially buoyant even if you are not a millionaire.
(vi) Being relatively knowledgeable in law.
(vii) Winning substantially number of cases in court even if it is about fifty percent of the cases being in court.
It has also been said that there are some basic requirements expected of a Lawyer if he must be successful and the followings have been completely listed as follows;[47]
(i) establishment of a professional and personal network.
(ii) development of good communicational skills.
(iii) maintenance of your integrity at all times.
(iv) be innovative.
(v) be persistent
(vi) attitude is everything
(vii) accept failure
(viii) re-access your successes and failures from time to time.
(ix) don’t be static, adjust with the realities of life.
INFLUENCE OF A SUCCESSFUL LAWYER ON A JUST SOCIETY
A successful Lawyer having been defined above owe a sacred duty to make sure that the system of government in the society operate in accordance with the rule of law. There is no doubt that law is difficult to define since it is a relative concept but law is seen as a system of rules which govern a society and part of the system of rules which is law is the lawyers trade. For example, there is the need for separation of power among the organs of the government, and it is the Lawyer who always go to court to challenge the excesses of the government which goes against the interest of the society. Among such notable Lawyers who were successful and are successful in legal practice and has shapen Nigeria towards being a just society are;
(i) Late Chief Gani Fawehinmi (SAN) [48]
(ii) Late Chief Kanmi Ishola Osobu
(iii) Late Chief Rotimi, Williams (SAN)
(iv) Late Chief Sapara Williams. First Nigeria Practicing Lawyer.
(v) Chief Femi Falana (SAN)
A successful Lawyer should not be involved in corruption. In fact, he or she must be in the fore front of the crusade against corruption. He must avoid the temptation of taking bribes or collecting bribes to be given to judges. He must be able to help to fight corruption at all times. A Lawyer who is found to be corrupt will be derobed and cannot be successful in legal practice.[49]
Corruption has been a serious issue in Nigeria, it is also a complex one because the society is also a complex. The legal profession is an honorable one and a Lawyer must conduct himself in line with his callings. The legal practitioner belongs to a noble profession, he needs to conduct himself in such a way as to promote and sustain the larger interests of law, of the society and above all, the people who reposed confidence in the law and the public interest. The Lawyer compliments the operation of the law enforcement agencies. Both the defence and prosecution in a corruption case need to follow laid down procedure in conducting their case/cases to realize a society of our common dream.[50]
Arbitration proceedings are usually arranged and handled by lawyers. The lawyers who are part of the society in order to encourage business and commercial practices including international business transactions, always make sure that arbitration clauses are inserted into commercial agreements/ conceptual documents. A successful lawyer in order to encourage commercial transaction and resolution of dispute does not insist that all matters must be decided by the court. A successful lawyer will always advise his client to seek resolution of disputes through A D R (Alternative Dispute Resolution). This is a very good contribution for a just and descent society.[51]
However, in Nigeria, arbitration proceeding are not too popular as one can see in the Western World. Those who are foreigners coming to invest in business in Nigeria will be interested once they are aware that the A D R system of resolving dispute is more popular and mostly utilized in our country. It is the duty of a successful lawyer to advise the litigants to go through arbitration proceedings especially where;
(i) The arbitration clause is contained in the agreement or contractual agreement as we have seen where some lawyers will file cases straight in court for their clients notwithstanding knowledge that the agreement or contractual documents contained arbitration clause.
(ii) Where a lawyer is aware that his client has a weak case, he can direct his client to approach his opponent to resolve the dispute amicably through A D R, instead of a full blown litigation which may take a very long time in court before judgment is delivered.[52]
With all due respects to some of our colleagues, their clients will always say whether we have good case or not, the case must be prosecuted or defended and our response to such approach by our colleagues is to insist that” they are not successful lawyers”. A successful lawyer will always insist on the mode of prosecuting his case and if his client insist on the case going on after being sure of his advise, then give the case file back to him to find someone else who can do it in order to maintain your integrity and ethics both to the legal profession and to the society.
The erudite scholar, Professor L .C. B. Gower[53] while contributing to the issue dealing with the role of a successful legal practitioner to the society gave a graphic and colourful description which he stated as follow;
“They need commercial, corporation, and property lawyers if they are to achieve an economic take off. They need bilingual, international, comparative and constitutional lawyers if they are to survive as stated and to enter into large unions which pan – African sentiment and economic development demand. They need courageous lawyers with the highest ethical standards if the atrophy of the rule of law and of personal and academic freedom and the corrosive growth of corruption, nepotism elitism are to be arrested and if military and police power is to be kept within bounds. Most of all, perhaps, they need constitutional lawyers sophisticated in other disciplines if they are to find a viable substitute for the West minister parliamentary democracy”.
In Nigeria, our own erudite scholar while contributing to the issues of the influence of a successful lawyer on a just society, Professor Olakunle Orojo,[54] viewed microscopically, what the public perception on the lawyers entails in line with code of conduct, which he stated to be thus;
“In a society founded on respect for the rule of law, the lawyer fulfils a special role. His duties do not begin and end with faithful performance of what he is instructed to do, so far so the law permits. A lawyer must serve the interests of the just as well as those whose rights and liberties he is trusted to assert and defend. It is his duty not only to plead the client’s cause but to be his adviser. A lawyer’s function therefore lays on, a variety of legal and moral obligations (Sometimes appearing to be in conflict with each other) and other authorities before whom the lawyer pleads his client’s cause or acts on his behalf, the legal profession in general and each fellow member of it, in particular, owes a duty to the public for whom the existence of a free and independent profession, bound together by respect for rules made by the profession itself, as an essential means in the face of the power of the state and other interest in society”
From all that we have seen above, from the time a Lawyer is called to Bar and throughout his life as a Lawyer, if he must succeed in the Legal Profession, without finding himself thrown out of the profession, his ethical standard must be at the highest level in or out of the court. His life activities must be in a situation where he must wake up and sleep with discipline, sorry, we do not want to use the words “wine and dine with discipline”.
In FREE ENTERPRISES NIG LTD VS GLOBAL TRANSPORT OCEANICO SA & ANOR,[55] the court described an advocate as a minister of justice with the Judge because his duty is not only to his client. He has a duty to the court which is paramount. He must produce all relevant authorities, even those that are against him and must see that his client discloses, if ordered, the relevant documents, even those that are fatal to his case. He must disregard the most specific instructions of his clients if they conflict with his duty to the court.
Every counsel must conduct his case with decorum and the court also in the case of OKOLO VS UNION BANK OF NIG LTD[56] state that the rules of advocacy dictate that the legal contest between the opposing counsel is conducted with the highest decorum and civility, devoid of rancour and vituperation. The contest does not allow any counsel to unleash personal attack on the trial judge, the province of whose high office until the contrary is proved, is to serve as a neutral and independent arbiter in the determination of the controversy between the parties. For ease of reference, this was what the Appellant counsel stated in his brief of argument;
“As already stated in the introduction of this brief of argument, the judgment delivered by the trial judge was for want of better expression completely devoid of consistency, logic or common sense.[57]”
Flowing from the above, and supporting the above position of the law are the words of Hon. Justice L.H Gummi, Chief Judge of FCT, Rtd, who stated thus;[58]
“Counsel are members of the Bar and as members in the temple of justice, you must conduct yourselves in a dignified manner at all times. You must do all that is necessary to uphold the dignity of the court. You must be punctual to court and if for any reason, you cannot, courtesy demands that you write to inform the court and ask for either a stand down or in extreme cases, adjournment. As counsel you must be prepared to handle matters at every sitting. It does not speak well for counsel to stand up to inform the court that he is not prepared to go on. Frivolous applications for adjournments must be avoided. It is now becoming the norm for some of you to delay trials after filing frivolous cases or if they have no defence. You must be properly attired and maintain proper decorum in court. It is wrong for counsel to be reading newspaper in court. You must also refrain from talking loudly to other colleagues while the court is sitting. You must maintain a respectful attitude to the court both in words, addressing or being addressed by the court. You must not speak while the judge is speaking. You must also inform your clients about the need to maintain proper decorum in court. You must never criticize a judge in the presence your clients. You must remember that the Bar and the Bench are all members of the whole profession. We serve the same mistress only in different ways.”[59]
When a Lawyer breached the rules of professional conduct and his professional ethics is questioned, he definitely will face the Legal Practitioners Disciplinary Committee (LPDC) which is established by the Legal Practitioner Act (LPA).
In the case of USMAN VS STATE[60] the court held that it is unfair and unreasonable for Legal Practitioner in the course of their duties to court to constitute themselves into verbal arsenal on the courts. They should show utmost respect to the court always, for therein lies the dignity of the profession. Unwholesome attitude towards judges should be deprecated.
Also in the case of N.B.A VS OHIOMA[61]several misconducts were traceable to the Defendant through the provisions of the Rules of Professional conducts, it was held that the rules upon which misconducts were tried need not be specifically stated, provided that the allegation discloses all the essential elements sufficient enough.
The LPDC also has the power to choose its rules and procedure when trying a case of misconduct what the Supreme Court only stated in NDUKWE VS LPDC[62] was that such procedure should meet the demand of natural justice and also in accordance with the Evidence Act.
The natural rule with respect to discipline of lawyers is to follow the rules of fair hearing properly, when handling a case of professional misconduct against a Lawyer, otherwise, no matter, how well conducted the case may be, it may be set aside for not being in consonance with fair hearing rule.
In the case of LPDC VS FAWEHINMI[63] the Supreme Court has this to say;
“The principle of natural justice applies in all cases where the preliminary investigation or inquiry is an integral which may terminate in action adverse to the interests of the applicants claiming the right to be heard. It seems inescapable on the facts in the appeal before us that Appellant committee is obliged to observe the rules of natural justice and is therefore bound to be constituted in such a manner as to secure its independence and impartiality.”
The case of OKIKE VS LPDC[64] Shows issues of matter filed on the allegation ofprofessional misconduct in this case, the Respondent/Appellant legally represented a foreigner in respect of a claim against a Nigerian company and realized some money, on behalf of the clients. Only U. S $51,000 was remitted while U .S $121,000 was taken by the lawyer. After repeated demands by the client, he withdrew the brief and took another lawyer to recover the outstanding amount. A petition was sent against the Respondent/Appellant who entered defense challenging the agent authority and competence of the complaint.
The committee after considering the evidence led on allegation of infamous conduct decided that the name of the lawyer be struck off the roll of the registered lawyers enrolled at the Supreme Court.
Also
in the case of ITEOGU VS LDPC,[65] the petitioner was one of the several beneficiaries to a compensation sum of N 47,543,754.75 for compulsory revocation
of property in Akwa – Ibom for public purpose. The Respondent/ Appellant by a
power of Attorney was to recover the compensation sum for land compensation and
shared same among the beneficiaries as agreed upon. The Respondent / Appellant
claimed he recovered N 23,646, 974.53 from
the Ministry of Defence and Works who required the land to build a Naval base.
The Respondent/Appellant gave nothing to the petitioner. The committee of LPDC
decided that the Respondent /Appellant name be struck off the roll and that he
should refund the sum of N9,500,000 to
the petitioner. The Supreme Court dismissed the appeal.
In NDUKWE VS LPDC[66] the fact of the case was that the Respondent/Appellant, a legal – practitioner, was retained by the petitioner, a business woman who resides at Cameroon. The job was the execution of the judgment sum of CFA 20,000,000 against three fellow Nigerians who where;
- Ebi Erne
- Ume Ukpai
- Uka Mbila Philip
The Respondent/ Appellant preceded to execute the
foreign judgment at the High court of Abia State and was only able to recover
the sum of N25,000 out of the total judgment
sum that was due. The Appellant discontinued the case against the 3rd
Defendant, (Uka Mbila Philip) in such circumstance that the 2nd Respondent saw
as controversial. The sum of N25,000
recovered was from fifae and sale of movable property of the judgment debtors.
The petitioner lost confidence in the Appellant
(Lawyer’s conduct) and was debriefed, but the Appellant (Lawyer) refused to pay
the N25,000 to the petitioner which was
the money recovered. After so many demands without payment, the lawyer was
petitioned to the office of the Chief Justice of Nigeria (C.J.N) who forwarded
same to the N.B.A, and the matter was reported on the allegation that the
lawyer was involved in professional misconduct. The Committee found the
Appellant guilty and was suspended from practice for one year. His appeal was
dismissed by the Supreme Court. The LPDC Stated in part of its decision as
follows;[67]
“The Petitioner, frail old woman who is a widow strikes us a (Sic) witness of truth. We accept her testimony which has in fact been confirmed by the evidence of the respondent himself. The respondent did not seriously dispute the fact that he received client’s money which he did not pay to the client for a period of over two years. The money even up till now remains unpaid. We therefore have no hesitation in finding you Mr. Eke Umazi Ndukwe, legal practitioner guilty of infamous conduct in a professional respect pursuant to the provisions of section 11 (1) of the legal practitioners Acts, cap 207 of the laws of the Federation of Nigeria 1990”
Among the yard sticks to measure the success of a lawyer is attaining the highest status in the legal profession that is becoming a Senior Advocate Of Nigeria (SAN).
To achieve this status, which usually makes members of the society and legal – practitioners to accord additional respect to a lawyer and a different kind of dignity via – vis possibility of financial buoyancy, the criterias required to attain this status more or less is completely on ethics, such that any lawyer with very weak ethical status or no ethical status at all cannot be conferred with the prestigious title of a Senior Advocate Of Nigeria (SAN).
The criterias requires for a lawyer to become a senior Advocate of Nigeria (SAN) among other criterias are as follows;
(i) 20 final Judgments of the High court or superior court of records with letter of instruction from the clients as well as letter from the judge confirming that the applicant indeed handled the case / cases.[68]
(ii) 5 Judgments of the court of appeal supported by briefs along with valid notices of appeal duly settled and argued by the Applicant.[69]
(iii) A final judgment of the Supreme Court supported by briefs along with valid notice of appeal duly settled and filed by the Applicant.[70]
(iv) The law office must be of high standard with size and quality library, quality office space, and other facilities, the number of Lawyers in the office, evidence of letters of employment and pension scheme, number and quality of support staffs, and maintenance of proper books of account[71]. With standard text books, statute books, law reports, computers, fax machines, file cabinets, firefighting equipment, generator, television, set, CCTV, fridge, scanners, photocopiers, intercom, motor – vehicle.
(v) For those applying through academics,[72] he must furnish to the committee 15 copies of published works by reputable publisher, there shall be evidence of substantial contributions to legal scholarships and jurisprudence through teachings, research and published works in any Nigerian University, Research Institute, Law School.
(vi) There must be evidence of competence, professional and personal integrity, honesty and straight forwardness, good character and reputation, candidness with clients and professional colleagues, high level of understanding of cultural and social activities, observance of code of conduct and Etiquette at the Bar.[73]
(vii) Any candidate with misleading or false information is to be banned from applying for SAN position for the next 10 years.[74]
(viii) Candidate must have paid consistently and as at when due his practising fees and membership dues to the local branch in the last 10 years preceding the application[75] and at least 3 pro –bono cases must have been handled for clients.[76]
(ix) The candidate must submit themselves for income tax payment as at when due with evidence of income tax receipt / certificate which must be the place of practice domicile for a period not less than 3 years preceding the time of application.[77]
From what we have seen in this work, it is not in doubt that without a strong ethical standard, A WOULD BE LAWYER who is a student may not even become a Lawyer because a Law student must be of high standard in terms of discipline, he must be neat, he must be dedicated to work, he must not be involved in any criminal activities nor must he be convicted for any criminal allegation. Islamic teachings has to do with ethics and morality and this is additional advantage to a Muslim Lawyer. And the basis for this can be traced to the Holy glorious Quran in Chapter 74 verses 4, 5 and Quran Chapter 31 verse 17;
“And thy garments keep free from stain! And all abomination shun!”
“O
my son! Establish regular prayer, enjoin what is just, and forbid what is
wrong: and bear with patient constancy whatever betide thee; for this is
firmness (of purpose) in (the conduct of ) affairs.”
SUMMARY
The above topic, is important not for only the members of the legal profession but it is important for the law students who are aspiring to become Legal-Practitioners because any Lawyer without ethics or low ethical standard will not only be a looser in the legal profession but will not be successful in the said profession.
The work dealt extensively with ethical standards expected from a Lawyer, and we took time to look at most of the rules of professional conduct for Legal Practitioners showing that they are tied down to the Legal profession and without complying with same, it may be difficult for a Lawyer to succeed in the Legal profession or for the society to be a just one.
The issue of the Legal Practitioners Act was also discussed while we defined those key terms, necessary in this regard such as;
i. Ethics
ii. Fulcrum
iii. Legal Profession
iv. Crux
v. Successful Lawyer
vi. Just Society
in addition, we looked at Case Laws decided by Legal Practitioners Disciplinary Committee and the appeals on disciplinary issue up to and including Supreme Court matters on this issue.
The work also focused its attention on the relevance of ethics to the Legal Profession, the definition of who a successful Lawyer his, vis–a–vis the impact of the success of Lawyers in a just society.
We did a summary, recommendations and conclusion. The recommendations are far reaching ones which ought not to be ignored especially because, the issue is;
“Fail to follow the ethics of the Legal Profession, fail to succeed and fail out”
The footnote and bibliography were designed to give opportunity for further reading and appreciation of the topic mentioned above.
RECOMMENDATIONS
1. It is recommended that the Lawyer including the Law students should as a matter of priority be knowledgeable from time to time as to what are the ethical codes and standards required of a Lawyer. To this extent, adequate knowledge of the rules of professional conduct for legal practitioners is important because the breach of this rule can bring immediate failure to a Lawyer who is likely to be derobed or who is likely to be suspended from being a Lawyer any more.
2. It is equally recommended that a Lawyer who intend to achieve success in the Legal Profession should also create time to read the Legal Practitioners Act LFN 2004, and make sure the said Act becomes your companion from day to day. The profession is almost sixty percent (60%) based on ethics and ethics is fundamental for success. It is therefore disheartening to know that most Lawyers, once they pass the examination on ethics at the Law School, immediately abandon going through the Act any longer. No wonder, most cases dealing with disciplinary proceedings have shown that a lot of our Lawyers do not know about the Act nor the rules which led to their indictment. If they are aware that their behaviours are likely going to lead to being derobed or suspended from the Legal Profession, they would have been more cautious.
3. It is recommended that the subject tagged “Ethics of the Legal Profession” be compulsory course from 100 level to 500 level in the university and any student who did not pass the course should not be allowed to graduate because once the student is admitted to the Law School, he must still take similar course. By the time a student is involved in Learning Professional ethics for 5 or 6 years, he is likely to be use to the subject matter and the ethical standards in the Legal Profession will increase.
4. It is further recommended that seminars, conferences and meeting points such as this, should be available where the issue of ethics as fulcrum of the Legal Profession, the crux of a successful Lawyer and just society, will be discussed in order to enlighten the members of the Legal Profession and the society.
5. There should be more books articles in journals and Lawyers should write more on the ethics of the Legal Profession. As at today, the number of books written including articles in journals are very low this does not help the ethics and standards of the Legal Profession.
CONCLUSION
We are glad to conclude just as the topic has shown that ethics is the fulcrum of the Legal Profession, and it is the crux of a successful Lawyer and a just society. This is because without ethics a Lawyer can’t be successful since it is the high level of ethical standards which a Lawyer will use to remain in the Legal Profession without being derobed or suspended and which can make a Lawyer to be appointed as a Senior Advocate Of Nigeria (SAN) or as a Judge and which can allow the rule of law and progress to be achieved in the society.
This
work will not be complete however, without mentioning specifically the great
works, related to this topic such as; those one by Mallam Yusuf Olaolu Ali,
SAN, on attaining excellence in Law Practice, delivered at the 4th Annual
Symposium of Muslim Lawyers Association of Nigeria (MULAN), Lagos Branch, on
8th October, 2016, 1st College Lecture, preparing for a successful career in
the Legal Profession, delivered on the 6th June, 2013. Professor Wahab
Egbewole, SAN, The Effective Management of Law Firm as a Business, Paper
Presented at the Annual Ghalib Chambers in House Lecture Series, 2010 – 2011
series. Aare Afe Babalola, SAN, CON, On Repositioning Legal Education for
National Development, Paper Presented at the Annual Law Teachers, Conference
held at Faculty of Law, University of Ibadan, 2019. My humble self, the
judiciary and legal profession under the present democratic dispensation, paper
presented at NBA Isiokpo Brance, Law Week 2016. The Ethical Challenges and
Economic Survival of the Young Lawyers, Presented at the conference
organization by the Young Lawyers Forum, NBA, Degema Branch, Rivers State on
the December, 2017. Building a Career in the Legal Profession, a paper
presented at the seminar organized by the Young Lawyers Forum, NBA, Kano branch
on the 13th day of December, 2018.
LIST OF AUTHORITIES
A. BOOKS/INTERNET MATERIALS/JOURNALS/PAPER PRESENTATIONS
1. Ethics in Cambridge English dictionary https://dictionary.cambridge.org. Accessed through internet on 11/7/2019 at 11:30pm.
2. Define ethics at dictionary.com htttps://www.dictionary.com accessed through the internet on 11/7/2019 at 11:59pm.
3. Fulcrum meaning; https://www.yourdictionary .com; accessed through the internet on 12/7/2019 at 12:03am
4. Fulcrum; https;//www.merriam.webster.com` accessed through internet on 12/7/2019 at 12:21am.
5. Legal profession; https://en.m.wikipedia.org. Accessed through the internet on 12/7/2019 at 12:57 am.
6. Meaning of crux; https;//www.dictionary.com. Access through the internet on 12/7/2019 at 7pm.
7. Lawyer; https://www.vocabulary.com. Accessed through the internet on 12/7/2019 at 8 pm.
8. Just society; https://www.quora.com. Accessed through the internet on 12/7/2019 at 10:18pm.
9. Cynthia Thomas; Legal keys to becoming a successful Lawyer; https://www.lawpracticetoday.org Accessed through the internet on 15/ 7/2019 1t 12:22am.
10. Prof. L.C.B Gower; Role of Lawyers in developing countries; https://www.jstor.org; accessed through the internet on 14/7/2019 at 10:53 pm
11. Blacks Law Dictionary, 8th Edition by Brian .A. Garner 2004 page 501
12. Mrs. Farida Wasiri; The role of the Bar in the fight against corruption; A template from my experiences; published in the N.B.A Bar perspective, August, 2011 pages 68-69.
13. Prof J.O Orojo; Professional Ethics and the Legal Profession in Nigeria.
14. Epiphany Azinge & Anr; Anatomy of the legal profession; published by Nigeria Institute of Advance Legal Studies; 2013 pages 26-27.
15. Hon. L.H Gummi, Rtd; Professional Ethics, the Bar Bench and Society; Published in Eastern Bar Journal Vol. 2, No2, 2008 page 65.
16. Mallam Yusuf Ola-Olu Ali (SAN); On attaining excellence in law practice delivered at the 4th annual symposium of the Muslim Lawyers Association of Nigeria (Mulan) Lagos Branch, on 8th Octobe, 2016.
17. Mallam Yusuf Ola-Olu Ali (SAN); 1st College Lecture, Preparing for a successful career in the legal profession, delivered on 6th June, 2013.
18. Professor Wahab .O. Egbewole (SAN); The effective management of law firm as a business, paper presented at the annual Ghalib chambers in house lecture series.
19. Aare Afe Babalola (SAN), CON, on repositioning legal education for national development, paper presented at annual law teachers, conference held at faculty of law, University of Ibadan, 2019.
20. Professor Abiodun Amuda-Kannike (SAN); The judiciary and legal profession under the present democratic dispensation, paper presented at NBA Isiokpo branch, law week, 2016.
21. Professor Abiodun Amuda-Kannike (SAN); The ethical challenges economic survival of the young lawyers, presented at the conference organized by the young lawyers forum, NBA Degema Branch Rivers State, on 14th December, 2017.
22. Professor Abiodun Amuda-Kannike (SAN); Building a career in the legals profession, a paper presented at the seminar organized by the young lawyers forum NBA, Kano Branch, on 13th day of December, 2018.
B. CASE LAWS
1. FREE ENTERPRISES NIG. LTD VS GLOBAL TRANSPORT OCEANICO S.A & ANR (1998) 1 NWLR (part 532) page 1
2. OKOLO VS UNION BANK OF NIG. LTD (1998) 2 NWLR (part 539) page 618
3. USMAN VS STATE (2010) 6 NWLR (part 1191) page 454
4. N.B.A VS OHIOMA (2010) 14 NWLR (part 1213) page 461 LPDC
5. NDUKWE VS LPDC (2007) 5 NWLR (part 1026) page 31 Paras. A-B
6. LDPC VS FAWEHINMI (1985) 2 NWLR (part 7) SC page 300 at 381 – 382 Paras H – A
7. OKIKE VS LPDC (2005) 15 NWLR (part 949) page 471
8. ITEOGU VS LPDC (2009) 17 NWLR (part 1171) page 214 SC
9. NDUKW VS LPDC (2007) 5 NWLR (part 1026) SC page 1
C. STATUTES
1. Rule 1 of the rules of professional conduct for legal practitioners pursuant to legal practitioners Act LFN, 2004.
2. Rule 2 of the rules of professional conduct for legal practitioners pursuant to legal practitioners Act LFN, 2004.
3. Rule 3 of the rules of professional conduct for legal practitioners.
4. Rules 4 and 5 of the rules of professional conduct for legal practitioners.
5. Rule 6 of the rules of professional conduct for legal practitioners.
6. Rule 7 of the Rules of professional conduct for legal practitioners Act.
7. Rule 8 of the Rules of professional conduct for legal practitioners Act.
8. Rule 9 of the Rules of professional conduct for legal practitioners Act.
9. Rule 10 of the Rules of professional conduct for legal practitioners Act.
10. Rule 11 of the Rules of professional conduct for legal practitioners Act.
11. Rule 12 of the Rules of professional conduct for legal practitioners Act.
12. Rule 13 of the Rules of professional conduct for legal practitioners Act.
13. Rule 14 of the Rules of professional conduct for legal practitioners Act.
14. Rule 15 of the Rules of professional conduct for legal practitioners Act.
15. Rule 16 of the Rules of professional conduct for legal practitioners Act.
16. Rule 17 of the Rules of professional conduct for legal practitioners Act.
17. Rule 18 of the Rules of professional conduct for legal practitioners Act.
18. Rule 19 of the Rules of professional conduct for legal practitioners Act.
19. Rule 20 of the Rules of professional conduct for legal practitioners Act.
20. Rule 21 of the Rules of professional conduct for legal practitioners Act.
21. Rule 22 of the Rules of professional conduct for legal practitioners Act.
22. Rule 23 of the Rules of professional conduct for legal practitioners Act.
23. Rule 24 of the Rules of professional conduct for legal practitioners Act.
24. Rule 25 of the Rules of professional conduct for legal practitioners Act.
25. Rule 26 of the Rules of professional conduct for legal practitioners Act.
26. Rule 27 of the Rules of professional conduct for legal practitioners Act.
27. Rule 28 of the Rules of professional conduct for legal practitioners Act.
28. Rule 29 of the Rules of professional conduct for legal practitioners Act.
29. Rules 30, 31, 32, 33, 34, 35, 36, 37, 38 and 39 of the Rules of professional conduct for legal practitioner.
30. Rule 40 of the Rules of professional conduct for legal practitioners Act.
31. Rules 41- 44 of the Rules of professional conduct for legal practitioners Act.
32. Rules 45, 46, 47, 48, 49, 50, 51, 52 and 53 of the rules of professional conduct for legal Practitioners Act.
33. Rule 54 of the Rules of professional conduct for legal practitioners Act.
34. Rules 55 and 56 of the Rules of professional conduct for legal practitioners Act.
35. Paragraph 14 (5a) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
36. Paragraph 14 (5b) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
37. Paragraph 14 (5c) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
38. Paragraph 17 (1), (2), (3) and (4) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
39. Paragraph 18 of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
40. Paragraph 23 of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
41. Paragraph 23 (2) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
42. Paragraph 23 (7b) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
43. Paragraph 23 (7c) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
44. Paragraph 15 of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
45. Quran in Chapter 74 verses 4, 5
46. Quran
Chapter 31 verse 17
[1] The lawyers are severally described as the mirror of a just and decent society.
[2] The keywords definition will enable the reader to appreciate the topic as presented.
[3] Blacks Law Dictionary, 8th Edition by Brian .A. Garner 2004 page 501
[4] Ethics in Cambridge English dictionary https://dictionary.cambridge.org. Accessed through internet on 11/7/2019 at 11:30pm.
[5] Define ethics at dictionary.com htttps://www.dictionary.com accessed through the internet on 11/7/2019 at 11:59pm.
[6] Fulcrum meaning; https://www.yourdictionary .com; accessed through the internet on 12/7/2019 at 12:03am
[7] Fulcrum; https;//www.merriam.webster.com` accessed through internet on 12/7/2019 at 12:21am.
[8] Legal profession; https://en.m.wikipedia.org. Accessed through the internet on 12/7/2019 at 12:57 am.
[9] Meaning of crux; https;//www.dictionary.com. Accessed through the internet on 12/7/2019 at 7pm.
[10] Lawyer; https://www.vocabulary.com. Accessed through the internet on 12/7/2019 at 8 pm.
[11] Just society; https://www.quora.com. Accessed through the internet on 12/7/2019 at 10:18pm.
[12] Rule 1 of the rules of professional conduct for legal practitioners pursuant to legal practitioners Act LFN, 2004.
[13] Rule 2 of the rules of professional conduct for legal practitioners pursuant to legal practitioners Act LFN, 2004.
[14] Rule 3 of the rules of professional conduct for legal practitioners.
[15] Rules 4 and 5 of the rules of professional conduct for legal practitioners.
[16] Rule 6 of the rules of professional conduct for legal practitioners.
[17] Rule 7 of the Rules of professional conduct for legal practitioners Act.
[18] Rule 8 of the Rules of professional conduct for legal practitioners Act.
[19] Rule 9 of the Rules of professional conduct for legal practitioners Act.
[20] Rule 10 of the Rules of professional conduct for legal practitioners Act.
[21] Rule 11 of the Rules of professional conduct for legal practitioners Act.
[22] Rule 12 of the Rules of professional conduct for legal practitioners Act.
[23] Rule 13 of the Rules of professional conduct for legal practitioners Act.
[24] Rule 14 of the Rules of professional conduct for legal practitioners Act.
[25] Rule 15 of the Rules of professional conduct for legal practitioners Act.
[26] Rule 16 of the Rules of professional conduct for legal practitioners Act.
[27] Rule 17 of the Rules of professional conduct for legal practitioners Act.
[28] Rule 18 of the Rules of professional conduct for legal practitioners Act.
[29] Rule 19 of the Rules of professional conduct for legal practitioners Act.
[30] Rule 20 of the Rules of professional conduct for legal practitioners Act.
[31] Rule 21 of the Rules of professional conduct for legal practitioners Act.
[32] Rule 22 of the Rules of professional conduct for legal practitioners Act.
[33] Rule 23 of the Rules of professional conduct for legal practitioners Act.
[34] Rule 24 of the Rules of professional conduct for legal practitioners Act.
[35] Rule 25 of the Rules of professional conduct for legal practitioners Act.
[36] Rule 26 of the Rules of professional conduct for legal practitioners Act.
[37] Rule 27 of the Rules of professional conduct for legal practitioners Act.
[38] Rule 28 of the Rules of professional conduct for legal practitioners Act.
[39] Rule 29 of the Rules of professional conduct for legal practitioners Act.
[40] Rules 30, 31, 32, 33, 34, 35, 36, 37, 38 and 39 of the Rules of professional conduct for legal practitioners.
[41] Rule 40 of the Rules of professional conduct for legal practitioners Act.
[42] Rules 41- 44 of the Rules of professional conduct for legal practitioners Act.
[43] Rules 45, 46, 47, 48, 49, 50, 51, 52 and 53 of the rules of professional conduct for legal practitioners Act.
[44] Rule 54 of the Rules of professional conduct for legal practitioners Act.
[45] Rules 55 and 56 of the Rules of professional conduct for legal practitioners Act.
[46] Cynthia Thomas; Legal keys to becoming a successful Lawyer; https://www.lawpracticetoday.org Accessed through the internet on 15/ 7/2019 1t 12:22am.
[47] Ibid: Legal keys to become a successful Lawyer.
[48] Chief Gani Fawehinmi, SAN, (Late) filed so many cases on his own challenging the government on so many activities, he succeeded in most cases, he was detained often and imprisoned, in order to fight for a just society.
[49] No country can be successful if corruption is not tamed. The group at the head of fight against corruption are the Lawyers as expected by the society.
[50] Mrs. Farida Wasiri; The role of the Bar in the fight against corruption; A template from my experiences; published in the N.B.A Bar perspective, August, 2011 pages 68-69.
[51] In fact the CJN not quite long sent practice direction to most of the judges in Nigeria, that one a contract or an agreement contains arbitration clause, the court should allow parties to go for arbitration proceedings first before approaching the court.
[52] There are a lot of litigants who would always insist that even if they have a weak case, their Lawyer must defend the case and file several frivolous preliminary objection..
[53] Prof. L.C.B Gower; Role of Lawyers in developing countries; https://www.jstor.org; accessed through the internet on 14/7/2019 at 10:53 pm
[54] Prof J.O Orojo; Professional Ethics and the Legal Profession in Nigeria.
10 Epiphany Azinge & Anr; Anatomy of the legal profession; published by Nigeria Institute of Advance Legal Studies; 2013 pages 26-27.
[55] (1998) 1 NWLR (part 532) page 1
[56] (1998) 2 NWLR (part 539) page 618
[57] While we do not encourage counsel to disrespect judges or use disrespectful words against judges, we also suggest that judges reciprocally should not abuse Lawyers in their rulings or judgments, because respect is reciprocal and judges must be Lawyers first before being appointed as judges.
[58] Hon. L.H Gummi, Rtd; Professional Ethics, the Bar Bench and Society; Published in Eastern Bar Journal Vol. 2, No2, 2008 page 65.
[59] It is to be noted that the “mistress” of the Lawyers and the judges is “the law”. She is a hard task master. The court is the venue where the mistress resides. We are like worshippers in her temple. We owe each other respect. Respect is the basis of ethical behavior.
[60] (2010) 6 NWLR (part 1191) page 454
[61] (2010) 14 NWLR (part 1213) page 461 LPDC
[62] (2007) 5 NWLR (part 1026) page 31 Paras. A-B
[63] (1985) 2 NWLR (part 7) SC page 300 at 381 – 382 Paras H – A
[64] (2005) 15 NWLR (part 949) page 471
[65] (2009) 17 NWLR (part 1171) page 214 SC
[66] (2007) 5 NWLR (part 1026) SC page 1
[67] Ibid; very sound decision of the LPDC upheld by the supreme court to guide against indiscipline and misconduct.
[68] Paragraph 14 (5a) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
[69] Paragraph 14 (5b) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
[70] Paragraph 14 (5c) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
[71] Paragraph 17 (1), (2), (3) and (4) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
[72] Paragraph 18 of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
[73] Paragraph 23 of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
[74] Paragraph 23 (2) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
[75] Paragraph 23 (7b) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
[76] Paragraph 23 (7c) of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
[77] Paragraph 15 of the 2018 Guidelines for the Conferment of the Rank of Senior Advocate of Nigeria and All Matters pertaining to the Rank, official Gazette No 112 Vol. 105 of 31st August, 2018.
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