Justice Rita Ofili-Ajumogobia Reinstated as Federal High Court Judge

Justice Rita Ofili-Ajumogobia has been reinstated as a Judge of the Federal High Court, by the National Judicial Council (NJC). The reinstatement was announced in a circular signed by the Chief Judge of the Federal High Court, Hon. Justice John Tsoho.

The circular stated that: “Your Lordships are by this Circular letter notified that at the Meeting of the National Judicial Council held on the 1st of December, 2022, the Council reinstated the Hon. Justice R. N. Ofili-Ajumogobia as a Judicial Officer”.

The Chief Judge stated that “the reinstatement takes instant effect, and there shall be consequential posting”.

Justice Ofili-Ajumogobia was prosecuted by the Economic and Financial Crimes Commission, EFCC, on a 15-count charge bordering on money laundering and breach of public trust.

Justice Ambrose Lewis-Allagoa of the Federal High Court however, discharged Ofili-Ajumogobia while granting her application to quash and dismiss the allegations. The application was filed and argued by her counsel, Mr. Olawale Akoni, SAN. Akoni told the Lagos court that the application was sequel to an order of Justice Binta Nyako of Abuja Division of the Federal High Court, which quashed all the recommendations of the NJC.

Akoni also told the court that by virtue of the judgement of Justice Nyako delivered on November 28, 2019 in the suit between Ofili-Ajumogobia and NJC, the Judge had quashed the Council’s report and recommendations, and that Justice Ofili-Ajumogobia had been reinstated.

While ruling on the arguments and submissions by the parties, Justice Allagoa said: “I have looked at the application. I have also looked into the counter-affidavit of the prosecution, it is not indeed, controverting the application. I am satisfied that the application has merit, the prayers sought for are hereby granted as prayed”.

December 2022 Call to Bar Ceremony

Last Tuesday and Wednesday, over 4,500 New Wigs were admitted to the Nigerian Bar with pomp and pageantry at the newly commissioned ultramodern Body of Benchers Complex in Abuja. As the yearly intake into the legal profession increases by the year, some have raised concerns that Nigeria may be producing too many Lawyers, while others argue that with an average of  one Lawyer to about 37,000 people, Nigeria may not have enough Lawyers yet. Onikepo Braithwaite, whose daughter was one of those called to the Bar was present at the occasion, with additional reports by Alex Enumah, This Day Judicia Correspondent in Abuja 

Introduction

At the Call to Bar ceremony of successful Candidates in the September, 2022 final examinations of the Nigerian Law School, which was presided over by the Chairman, Body of Benchers (BoB), Chief Wole Olanipekun CFR, SAN, the Director General of the Nigerian Law School, Professor Isa Chiroma, SAN disclosed that the new Lawyers successfully completed the vocational training at the Nigerian Law School as prescribed by the Legal Education Act of 1962. Chiroma disclosed that out of a total of 5,802 students who participated in the exams, 4,691 emerged successful, representing 80.81%.

A break-down of the results showed that 119 students came out with 1st Class; 789 with 2nd Class Upper; 2,460, 2nd Class Lower; and 1,323 came out with Pass; while some students were from the last exam.

Meanwhile, 20 successful Candidates from last year’s final Bar exam, also participated in the ceremony.

Excerpts of the Address Delivered by Chief Wole Olanipekun, CFR, SAN, Chairman of the Body of Benchers

“It is with great pleasure and excitement that I, on behalf of the Body of Benchers (the Body), welcome you all to this historic occasion of the call of new entrants to the Nigerian Bar. We all rejoice with our new colleagues, who we now address as learned friends, on this new dawn which marks a fulfilment of their dreams to join the noble and honourable profession of law.

“We are enjoined to rejoice with those who are rejoicing and celebrate with those who are celebrating; thus, we join ourselves with you, not just in rejoicing, but also in celebrating the landmark achievement of today, an achievement which has not come in a jiffy, but spanned a period of between five to six years of extensive and in-depth learning and research; the first five years of which were spent in your respective Universities where you were subjected to learning the theories and principles of law on different subjects, including but not limited to Constitutional Law, Torts, Law of Contract, Criminal Law, Law of Evidence, Jurisprudence, Land Law, Administrative Law, Nigerian Legal System, Labour Law, Oil and Gas Law, Environmental Law, International Law, Communication Law, etc; while the last one year has been spent at the Nigerian Law School under the tutelage of highly qualified and experienced legal minds, who took you through the practical and some theoretical aspects of the law; and during which time as well, some leading members of the profession have come to deliver lectures to you on topical issues touching on both adjectival and procedural aspects of law. 

“Through this last one year as well, you have been made to partake in the compulsory dining rites, during which you met with the leaders of the Body of Benchers, who, after each dining session, gave you some pep talks on the hidden secrets and traditions of the profession and proffered ways of success to you.

“The Council of Legal Education conducted your Bar Final Examinations, and adjudged you academically qualified to be called to the Nigerian Bar, thereafter, submitted your names to the Body (being the only body with the prerogative of admitting you to the Bar), for scrupulous screening in order to ensure that each and every one of you is indeed a fit and proper person to be admitted to the Nigerian Bar. The Screening Committee of the Body, under the traditional and statutory chairmanship of the Vice-Chairman met, and painstakingly screened each of you, looked into your certificates and Forms filled by you before recommending you to the Body for consideration for Call to the Bar. Traditionally as well, the Body met on Monday, 5th December, 2022, considered the Report of the Screening Committee and approved same, pursuant to which the final decision was taken that you should all be called to the Bar today. 

“I am not unaware of the fact that all this while, it has been a period of anxiety for you and your parents; first, when you were awaiting your results from the Nigerian Law School, and later, when you were eagerly expecting the outcome of the Report of the Screening Committee and subsequent decisions of the Body of Benchers, as to your being adjudged fit and proper to be called to the Bar. Having gone through these painstaking labyrinths, and immediately before now, having been admitted to the Bar as Barristers and Solicitors and directed to put on your wigs, one could only imagine the depth of your ecstasy, as well as the fulfilment of your parents and guardians on this beautiful day. I extend hearty and most sincere congratulations, and best of wishes to you and your parents, as I formally address you all as my learned friends.”

The Body of Benchers

“Although it is now common knowledge, or should have been taken for granted that the Body of Benchers is a creation of statute, as Section 3 of the Legal Practitioners Act, specifically subsection 1 thereof, provides that: “There shall be a body of legal practitioners of the highest distinction in the legal profession in Nigeria to be known as “the Body of Benchers” which shall be responsible for the formal call to the Bar of persons seeking to become legal practitioners”, it has become necessary, in view of recent misconceptions about what the Body represents, how it is constituted, its jurisdiction and the way and manner it is run and managed, to briefly recap, even for the umpteenth time and for record purposes, what the Body is, what it represents, what it does, what it does not do, as well as its powers and jurisdiction. 

“Statutorily, the Body is made up of the Chief Justice of Nigeria and all Justices of the Supreme Court, the President of the Court of Appeal and all Presiding Justices of the Divisions of the Court of Appeal, the Attorney-General of the Federation and all Attorneys-General of the States, the Chief Judges of the High Courts in the country, the Federal High Court, the High Court of the Federal Capital Territory and the States, the President of the Nigerian Bar Association, the Chairman of the Council of Legal Education, 30 legal practitioners representing the Bar, Life Benchers, and such number of persons, not exceeding 10, who appear to the Body to be eminent members of the legal profession in Nigeria of not less than 15 years post call standing. No less a person than the President and Commander-in-Chief of the Armed Forces of Nigeria, President Muhammadu Buhari, GCFR, graphically summarised the unique nature of the composition of the Body when, in his address at the official commissioning of the Body of Benchers Complex on 29th September, 2022, he enthused thus: 

‘I consider this Body as critical to the legal profession. I say this, because the membership of the Body cuts across all facets of the government and the legal profession, particularly, the Executive, Legislature, Judiciary and the Bar. Furthermore, all Justices of the Supreme Court, retired Chief Justices of Nigeria who are alive, President of the Court of Appeal and presiding Justices, Chief Judges of the High Courts, the Federal and States’ Attorneys-General, Chairmen of the Judiciary Committees in the two Houses of the National Assembly, leading members of the Bar and others constitute this Body. I am unaware of any other institution or organ in the legal profession that draws its membership from all segments of the profession like the Body of Benchers. No wonder, the statute describes it as consisting of men of the highest distinction in the legal profession.’

“From the composition of the Body, it is crystal clear that it is not just a highly disciplined and revered institution, but also a confluence and melting pot of the critical sectors of the legal profession in Nigeria. It is a body corporate with perpetual succession. It has its own seal, and is also imbued with the power and jurisdiction to make regulations for itself and the legal profession. It is very rich in history and antecedents, having been inaugurated on 27th November, 1971, with 16 pioneer members. Since then, it has produced 49 Chairmen, myself, being the 50th one, by the grace of God. Under its Regulations, and which said Regulations were made pursuant to the provisions of the enabling statute, assumption to office of its Chairman is always seamless, not contested, not controversial, not rancorous or uncertain. The term of office of the Chairman is only one year, from March of the preceding year, to March of the following year; and the position of chairmanship of the Body is rotated between the Bar and the Bench, that is, if a member of the Bar is the Chairman, as I am now, the Vice-Chairmanship automatically devolves on the Bench, like the Honourable Justice Mary Peter-Odili, CFR, presently is. At the end of the tenure of the Chairman, the Vice-Chairman automatically transits to the position of Chairman, thus, by the grace of God, come March 31, 2023, Honourable Justice Mary Peter-Odili, CFR shall assume office as Chairman of the Body, while I will transit to join the Committee of Elders as a past Chairman. In the real sense of it as well, the position of Vice-Chairman is also not contested, as precedence is meticulously adhered to. The programme of events of today details the names of Life Benchers according to their seniority and precedence, and succession follows the same precedence, as listed in the programme. It is just a matter of formality that the name of the most senior Life Bencher is introduced by the Bar and seconded by the Bench, at the point of transition. God sparing our respective lives, every Life Bencher from the Bar has an idea of when he/she is likely to assume office as the Vice Chairman of the Body, a prelude to his/her eventually becoming the Chairman. It is a tradition that we met, and has been sustained for years. We are proud to inform the World that our transition is always seamless, and has never been rancorous. Needless to add that, the Body of Benchers is not an appendage of the Federal Government, or any government, institution or agency, howsoever. It is an independent and autonomous body, and its meetings, affairs and decisions are not influenced by any power or authority whatsoever. But, let me quickly make the point that the Body remains the highest Body regulating the Legal Profession in Nigeria.

“As for the jurisdiction of the Body to discipline any Lawyer, such is exercised through the Legal Practitioners Disciplinary Committee (LPDC), which, although is a Committee of the Body, is a juristic personality on its own, independent of the Body, not controlled in any way or manner by either the Body or its Chairman, while its Directions go directly to the Supreme Court on appeal, and the Body exercises no appellate or supervisory jurisdiction over such Directions. Howbeit, may I caution that proceedings before the LPDC should not be politicised, sensationalised, publicised and advertised in advance or while the proceedings are ongoing by complainants for whatever reason howsoever, as so doing, negates the principle of fair hearing, which all Lawyers subscribe to. This is apart from the fact that such steps might pre-empt and prejudice the proceedings and decisions of the LPDC. Efforts are ongoing at amending the Legal Practitioners Act, in order to redress the looming gaps in the existing law relating to both the adjectival and procedural aspects of bringing erring Lawyers to book.”

The Body of Benchers from March 2022 to Date

The New BoB Complex

“….As you are aware, this Complex, that is, the Body of Benchers Complex, was formally commissioned by President Muhammadu Buhari, GCFR, on 29th September, 2022, and in my speech on that day, I stated thus:

“I stand here on behalf of the Body of Benchers to applaud the tenaciousness of purpose, the potency of a mutual allegiance, and an unswerving audacity which dates back to several decades. The Benchers Complex, which has just been commissioned by Mr President, is but a part of a unique blend of aspirations which took roots exactly 30 years ago… So much time, talents and treasures have been invested into this edifice! And, when I recall the varied stretch of sacrifices made to the realisation of this unique facility, my reaction is best captured in the words of the world acclaimed bard, Williams Shakespeare, when he said: “I can no other answer make but thanks, and thanks and ever thanks.”

“Once again, I appreciate the combined efforts of all my predecessors-in-office, and the commendable contributions, both materially and otherwise, of all members of the Body towards the realisation of our dream at completing this magnificent edifice, which it pleased God to be commissioned during my tenure. In like manner, I congratulate most heartily, all new entrants into the legal profession today for being the first set of Lawyers to be called to the Bar within this Complex, after its formal commissioning. Henceforth, all our Call to Bar ceremonies, meetings, seminars and activities shall be held within this grand facility.

Welfare of Judicial Officers

“At our meeting of 21st June, 2022, we inaugurated a Judiciary Advisory Committee, charged, amongst others, with the responsibilities of constantly interfacing with members of the Bench in order to take up their concerns and frustrations with appropriate authorities, and also to put in place, an acceptable package, salary and welfare-wise, for Judges of our superior courts of record, comparing such package with what operates in some similar jurisdictions. The Committee embarked on its mandate in earnest and assiduously, then booked an appointment with the President for 28th July, 2022. At that meeting, I drew the attention of Mr President to the report of a committee which the Federal Government had earlier set up in the following words:

‘The Committee is not unaware of the Report of the Committee on the Review of Judicial Salaries and Conditions of Service, set up by Mr President’s Government as far back as August, 2018; but, that the Report has not been implemented till now. In the interim, the Body of Benchers pleads with Mr President to direct the implementation of the recommendations in the Report in conformity with current economic realities and, in addition, direct the appropriate departments of Government to look into the recent complaints of the Justices of the Supreme Court, with a view to urgently ameliorating the unfavourable conditions under which they perform their sacred constitutional functions.’

“In response to my request, Mr President immediately directed that the 2018 Report be fetched out and brought to him for study and implementation. In my address during the commissioning of the Body of Benchers Complex on 29th September, 2022, I remarked as follows:

‘May I publicly commend Mr President’s immediate response to our plea on behalf of the Judiciary on 28th July, 2022, more particularly, Mr President’s apt response to my address when he enthused thus: that a democratic government like the one we operate, “standing on a tripod comprising the Executive, Legislature and Judiciary, cannot stand where one of its three pillars, the Judiciary, is not properly nurtured, maintained and sustained to deliver on its very pivotal constitutional duties.” Mr President further promised and/or directed that in the interim, the report and recommendations of the 2018 Committee on the Review of Judicial Salaries and Conditions of Service will be implemented. We eagerly anticipate the implementation of the said directive.’

“In Mr. President’s response, he emphatically committed his administration in the following words: 

“…May I restate my commitment towards this ideal. In similar vein, I have been intimated of the engagement of Consultants by the Body, through its Judiciary Advisory Committee, to amongst other things, come up with a peer review of the conditions of service of Judicial Officers in Nigeria with other countries and jurisdictions, within and outside Africa. I earnestly look forward to the completion of this peer review and the submission of recommendation, and this will assist us to review the welfare packages.”

“Without any gainsaying, the initiative and efforts of the Body of Benchers and the commitment of Mr President, formed the foundation and the very basis of the recent development towards the release and implementation of the 2018 Report. However, may I seize this unique opportunity to appreciate and commend, the Honourable Attorney-General of the Federation and Minister of Justice Mr. Abubakar Malami, CON, SAN for his cooperation; for, it was he that Mr President directed to fetch out the 2018 Report and bring to Mr President’s attention when the Body drew the attention of Mr President to the unimplemented Report, which had been seemingly abandoned as at the time of our visit to Mr President on 28th July, 2022. 

“Following up on its mandate, the Committee has engaged the services of the accounting and financial services firm of Ernst & Young (E&Y) to work out the peer review earlier referred to, and by a letter personally signed by me on 26th September, 2022,  to different stakeholders and relevant institutions, including Heads of Courts, Attorney-General of the Federation, Presiding Officers of the National Assembly, Revenue Mobilisation Allocation and Fiscal Commission, President of the Nigerian Bar Association, identified legal practitioners who have shown interest in the subject, etc., I pleaded with each of them to cooperate with the firm in carrying out its assignment. I am happy to note the positive developments arising from the humble initiative of the Body from different angles and quarters, including the office of the Attorney-General of the Federation, the Revenue Mobilisation, Allocation and Fiscal Commission, etc., all informing us, amongst others, that the hitherto shelved 2018 Report has now been released and directed for implementation by Mr President, and that the Government has also directed immediate steps to be taken at reviewing the conditions of service of judicial officers in the country. We expect the Report of E&Y to be submitted soon, and same will be forwarded to the Federal Government for study and implementation, as promised by Mr. President on 29th September, 2022.

Is Nigeria Over-Producing Lawyers?

“This question may seem rhetorical, but it is essential we address and face it at this point in time, or, raise it as a poser, to enable us have an insight into the variables for us to appreciate the issues at hand and proffer solutions to them. In doing that as well, we need to graphically peek into the past six years to refresh our memories as to the number of Lawyers churned out by us on a yearly basis, as against the realities of the labour market. In July 2016, 2,259 Lawyers were called to the Bar, and in November of the same year, 4,169 new entrants were admitted. In July, 2017, 1,469 Lawyers were called, while in November of the same year, we admitted 4,297. In July, 2018, we called 1,561 Lawyers to the Bar, and in November of the same year, 4,779 Lawyers enrolled as Barristers and Solicitors of the Supreme Court of Nigeria. In July 2019, 866 Lawyers were called to the Bar, while 4,459 were enrolled in November of the same year. Only 1,875 new entrants were called in September 2020 as a result of the Covid-19 pandemic. In July 2021, we called 5,215 Lawyers to the Bar. In July 2022, we called 1,504 to the Bar, while this December, we are calling 4,711 to the Bar. In summary, between 2016 and 2022, we have produced 37,164 Lawyers. There is about 1 Lawyer to 37,000 people. For next year, in addition to the swelling number of qualified graduates from Nigerian Universities to be admitted to the Nigerian Law School and subsequently called to the Bar, we already have a backlog of 1,883 students from the National Open University of Nigeria, who have since completed their Remedial Program, and now awaiting the Bar Part II Program.

“Since our common law derives its origin from the United Kingdom, and bearing in mind the fact that our entire legal and judicial system are similar to hers, let us quickly take a look, for the purpose of comparison, at the situation in the United Kingdom from 2017 to 2021. In 2017, the total number of Solicitors and practicing Barristers was 202,335; it increased to 209,464 in 2018, translating to 7,129 of new intakes of Solicitors and Barristers, and a 3.52% increase. The number rose to 216,724 in 2019, demonstrating an increase of 7,260 and a percentage increase of 3.47%; the figure rose to 223,349 in 2020, a numerical increase of 6,625 and a percentage increase of 3.06%. In 2021, the number rose to 230,428, an increase of 7,079, translating to 3.17% increase.

“While it will appear, ex facie, that Nigeria, in comparison with the United Kingdom (and in relation to her population) might not be over-producing Lawyers, and while the population of Nigeria is about four times that of the United Kingdom, empirical insight into the two economies will show that while the United Kingdom churns out Solicitors and Barristers that are systematically proportionate to the growing demands of the economy and population, same cannot be said of the Nigerian situation where Lawyers are produced irrespective of the harsh economic realities being faced and the capacity of the system to cater for them. To my mind, this situation should be of great concern to the leading stakeholders in the legal profession and the justice delivery sector in Nigeria. I have my serious doubt if our labour market absorbs about 20% of the Lawyers being produced annually by us, meaning that about 80% of those new entrants are unabsorbed or unemployed on yearly basis, taking our bearing conservatively from the past six years. During our time and relatively thereafter, the economy was able and ready to absorb all legal practitioners called to the Bar by the Body of Benchers, but the situation has abysmally changed today. Therefore, we should appreciate the realisation that there is a real threat to the profession itself and, indeed, to the entire system. 

“Recently, the National Bureau of Statistics came out with a scary report that 133 million Nigerians (out of an estimation of 216 million) are poor. It is imperative for those of us who are leaders of the profession to find out how many legal practitioners are classified among this 133 million, and work out the percentage of poor Lawyers in the population, based on the number of Lawyers on the Roll. A proper auditing in this wise, will reveal a more escalating report in respect of poor Lawyers in the country. What then do we do? The answer does not lie in the solution proffered by Shakespeare that: “…The first thing we do, let’s kill all the Lawyers”, but for us to now soberly, honestly, diligently, painstakingly, sympathetically and empathetically look into this glooming situation and fashion out ways of addressing them, rather than engaging in very unproductive ventures, utterances, strife and vituperations. 

“Essentially, what we need, and must embark on, is mutual cooperation between all sectors of the profession, and not mutual destruction. For those of us who think that we have made it or that we have arrived, we cannot continue to rest in our comfort zones, thinking that we are safe, if and when these young ones we unleash into the unproductive system are not catered for. To my mind as well, we cannot continue to boast of our success if our successors continue to wallow in penury. May I, therefore, plead with senior Lawyers all over the country to improve, within their respective means, the welfare packages of junior counsel in their chambers. It is not realistic for any counsel, whatever might be the newness or ‘greenness’ of his/her wig to be paid any wage equivalent to the government’s minimum wage of N30,000 per month. Without being immodest, a Youth Corps member  posted to any law office deserves more than that as a supplementary allowance.

“For a start, the Body of Benchers, through its Mentoring Committee, under the able Chairmanship of Chief J-K Gadzama, OFR, SAN, will be commencing a Mentoring Program for new entrants into the profession as from the First Quarter of 2023. The program, which will be both physical and virtual, will spread across all the six geo-political zones, as well as the Federal Capital Territory. This innovation will offer insights into how new entrants to the Bar can make a success out of the profession of law, irrespective of the challenging economy. It is not just tested and experienced Lawyers that will be called upon to address new wigs at the program, but also captains of industry and other relevant professionals will be called upon to offer cognate counselling on how Lawyers can make a headway in life, particularly in Nigeria, notwithstanding the nuances of our economy and politics. I enjoin all of you to take part in the program.”

Proliferation of Law School Campuses

“May we plead with the National Assembly to stop toying with the idea of promulgating laws or amending the Legal Practitioners Act, to pave way for the proliferation of Law School Campuses, particularly, around the neighbourhoods of some lawmakers. It is within the exclusive prerogative of the Council of Legal Education, in consultation with the Body of Benchers, to establish new Law School campuses. While I do not question the jurisdiction of the National Assembly to make laws as appropriate, Law School campuses cannot be established without clearance from the Council of Legal Education. What we need now is the improvement and upgrading of the existing Law School campuses, using the newly commissioned Graham Douglas Law School Campus, Port Harcourt, built and equipped by the Rivers State Government as a model. I dare say that, it is the best in the country for now.”

Admonition

“Irrespective of what the state of the economy, both municipally and globally might be, I admonish you to aim for the best and prepare to soar like the eagle. Look at the array of legal eggheads who have filed in to call you to the Bar today, amongst who are the very best and finest in the legal profession. In your minds’ eyes, stretch your hands to them and make them points of contact for your present and future, praying to God that in the nearest future, you will be like, or outgrow your points of contact. We did that during our time, and God answered our prayers. Our profession boasts of, and parades three key words- noble, honourable and learned. Covet these flagship words in your endeavours, undertakings and relationships with others. Act nobly, in and out of court; behave honourably in all your dealings with your colleagues and clients, as well as with the Bench, for those of you who will end up in legal practice and those who will end up on the Bench. Do not engage in strife, blackmail, mudslinging, campaign of calumny, treachery or any attempt to run or pull anyone down. Flee from envy like a plague, for envy breeds hatred and unjustified contempt for others. Appreciate your colleagues and peers, as well as senior members of the profession who have received God’s benevolence, and pray that your own time will come.

“For those of you who will be plunging into legal practice, I can assure you that it is a very rewarding venture; very entertaining, illuminating, fulfilling, energising and most exciting. Nevertheless, avoid physical and verbal punches. Be resolute and committed in the defence and ventilation of the causes of your clients, whether in civil or criminal proceedings; and do not be swayed or distracted by some colleagues who may come to challenge or accuse you for defending a particular client or taking up any specific cause, which, in their thinking, is ‘notorious’. Display your learning by your robust and forensic submissions, both formal and oral, in the presentation and ventilation of your clients’ causes or through informed essays, papers, articles, in Law Journals and literatures, rather than dissipating energy on the social media to ventilate causes which you know nothing about.…..Show respect to the court, and by so doing, you are also respecting yourselves and the institution of the Judiciary. Avoid being rude, naughty, haughty or tardy in all situations and circumstances. Beware of committing contempt, whether in facie curiae or ex facie curiae.

“To our noble Judges before whom these young ones will start appearing, please, be patient with them, and exercise your awesome power to commit for contempt sparingly. Most humbly, may I draw the attention of our Honourable Judges and Magistrates to the encounter between one Ms Stone, on one hand, and Lord Denning and others on the other. Ms Stone, on refusal of her application, got so angry that she first threw a book case at the Judges, which passed between Justice Diplock and Lord Denning who did not say a word; she threw another which went ‘wide’, but they equally ignored her and she exclaimed: “I am running out of ammunition”, but the Justices ignored her completely, forcing her to walk towards the door, saying to the Justices: “I congratulate your Lordships on your coolness under fire.”  Also, most humbly, I commend to our trial Judges and Magistrates, the very calm example set by the Supreme Court in the celebrated case of ARCON v Fassassi (No. 2) 1987 3 N.W.L.R. Part 59 Page 1 where a foremost and revered counsel asked the court to give an assurance that it would not be biased against his client in the particular appeal, bearing in mind, the court’s earlier interlocutory decision in the proceedings of the previous day. Rather than getting upset, the court simp