Lagos State first introduced the Administration of Criminal Justice Law, 2007 and the Law was reenacted in 2011 (ACJL) to govern criminal proceedings in Lagos State.
This Law brought radical changes into the administration of Criminal Justice in Lagos State with several provisions aimed at improving the administration of Criminal Justice in the state.
In the words of Chief Wole Olanipekun (SAN), one of the best lawyers around these climes in “Promoting a pace-setting and productive judiciary in Lagos State”, a keynote address the doyen of the bar delivered recently on the occasion of the Opening of the 2017/2018 Legal Year of the Lagos State Judiciary:
“The ACJL has introduced several innovations aimed at fast-tracking justice delivery, with a concerted effort at the preservation of rights of accused persons. For instance, under Section 9 of the ACJL, the confessional statement of an accused person must be captured via the use of video technology or video recording. In the absence of such video recording, such confession must be in writing, in the presence of the accused person’s legal practitioner. Failure to comply with the mandatory provision of Section 9 of the ACJL would render any such confession inadmissible in Court. This position has been affirmed by the Court of Appeal in Zhiya V. People of Lagos State. It is, therefore, not surprising that the Federal Government promptly adapted almost word-for-word, the ACJL, and enacted same as the Administration of Criminal Justice Act, although without acknowledging Lagos State as the initiator! A classical display of federal might indeed!!”
If this is so, it accords with common sense to focus primarily on the Lagos Law and draw comparisons with the federal Act (ACJA) wherever necessary in this treatise and I intend to do that.
Administration of Criminal
Justice In Nigeria
Criminal Law is an aspect of Public Law which is a specialised body of rules on treatment of conduct which the statutes seek to punish, prevent and or control. The state, as representative of society acts positively to ensure enforcement. For this purpose, the state employs the police, judges and magistrates, prosecutors and prisons.
Even though the Lagos Law did not specifically state the ACJL the purpose stated in ACJA clearly dovetails with the intention of the ACJL. Section 1 of ACJA made it clear that the purpose of the Act is “to ensure that the system of administration of criminal justice in Nigeria promotes efficient management of criminal justice institutions, speedy dispensation of justice, protection of the society from crime and protection of the rights and interests of the suspect, the defendant and the victim”. See the case of Zubairu v. The State (2015) 16 NWLR (Pt. 1486) at 524 Paras. B; where the Supreme Court noted “Let me start with the two fold aim of criminal justice: that the guilty shall not escape or the innocent suffer. See Berger v. US 1942 cited in US v. Nixon, President of USA 418 US 683.” – PER NGWUTA, J.S.C.
The point to note though is that prior to the enactment of these forward looking legislations, the operations of the Criminal Procedure Act (CPA) and Criminal Procedure Code (CPC) had been fraught with numerous challenges. For example issues like coerced and involuntary confessions, court congestion, delays in trial, detention of awaiting trial suspects and accused persons standing trial without legal representation, inefficient and ineffective prosecutors and corruption of the system gave everyone involved a lot of concern.
Lawyers are also very important in the complicated business of administration of criminal justice as almost everyone in the process were first and foremost Lawyers. It amounts to little that they have become Judges, Magistrates and Prosecutors. The defence counsel is also part of the critical core. The point to take away from this is that if we must have an efficient criminal justice system as the ACJL and ACJA tries to entrench in our polity, the men on the chain all along the line must be men who are willing to birth the dream of the ACJL and ACJA.
Critical provisions of the ACJL/ACJA:
The ACJL deviated from the norm. It made provisions that are alien to the Criminal Procedure Law which hitherto governed the administration of criminal justice in Lagos State. The ACJA which followed later made many similar provisions repealing by the provisions of Section 493 the Criminal Procedure Code and the Criminal Procedure Act which hitherto governed criminal prosecutions in the Southern and Northern States respectively. Any proceeding now commenced under these laws from the date of the commencement of ACJL/ACJA, irrespective of the date of gazetting will be void. See Akingbola v. FRN (2012) 9NWLR (Pt. 1306) 511, C.A. where the Court of Appeal held that any proceeding in Lagos State under the Criminal Procedure Law, repealed by the Administration of Criminal Justice Law of Lagos State 2007 was void.
The ACJL in section 374 repealed the Criminal Procedure Law long before the Federal Government repealed the equivalent federal law in 2015.
We will now proceed to briefly consider some of these salient provisions that should aid speedy and efficient administration of criminal justice in Lagos State in particular and Nigeria in general.
Abolition of Arrest in Lieu:
Section 4 of the ACJL provides that “no person shall be arrested in lieu of another person”. This was a regular practice of law enforcement agents akin to ‘hostage taking’ which has been widely condemned but has now been prohibited. No longer can the Police arrest a spouse or other relation to smoke out a suspect.
Section 7 of ACJA has a similar provision. See African Continental Bank Limited v. Okonkwo (1997) 1 NWLR (Pt. 48) 197 for a judicial reprimand of the police who arrest others in place of a suspect.
Prohibition of Arrest in Civil and Contractual Cases: Section 8 (2) of ACJA makes a very laudable provision to the effect that “a suspect shall not be arrested merely on a civil wrong or breach of contract”. It has become the past time of many Nigerians with the connivance of law enforcement agents to use their powers to harass citizens where contracts fail or loans remain unpaid. The Court held in A.C (O.A.O) Nig Ltd. v. Umanah (2013) 4 NWLR (Pt. 1344) 323 that “the statutory duties of the police under the Police Act is to maintain peace, law and order in the society. Debt collection or loan recovery is not within the purview of the statutory duty and powers of the police”.
Inventory of Properties:
Section 6 of ACJL makes a further provision to protect the interest of the suspect as it mandates the police upon the arrest of a person to take the inventory of all items or properties recovered from the person arrested or about to be arrested. The police officer making such an inventory must sign same and the person arrested, his legal representative or any other person he chooses shall be given a copy of the inventory.
Section 10 ACJA went a bit further than the Lagos Law to provide that the suspect must duly sign the inventory. However, where the suspect refuses to sign, it shall not invalidate the inventory. It permits the police to release such property on bond upon request by either the owner of the property or parties having interest in the property. The Court may decide whether to release the property or any portion of the property in the interest of justice to the safe custody of the owner or person having interest in the property.
This provision is aimed at protecting the property rights of suspects and to make the police or any other law enforcement agency making the arrest transparent and accountable.
The Duty of the Police to Ensure Video Recording of Confessional Statements:
In a radical provision to combat the often reported menace and human rights abuse whereby the police force confessions and torture suspects to confess to crimes they probably did not commit which may lead to conviction and time in jail as the best evidence in criminal proceedings especially in our clime where forensic evidence may not be available is the confessional statements, the Law placed a onerous duty on the police to ensure video recording of confessional statements.
Section 9 (3) of the ACJL provides that “where any person who is arrested with or without a warrant volunteers to make a confessional statement, the police shall ensure that the making and taking of such statement is recorded on video and the said recording and copies thereof may be produced at the trial provided that in the absence of video facility, the said statement shall be in writing in the presence of a legal practitioner of his choice”.
One can only begin to appreciate the great good this provision has done if one has ever been involved in criminal prosecutions where most of the evidence you have is the confessional statement of an accused person who continues to maintain that the statement was not voluntary and yet you have the police who swear that the suspect made a voluntary statement. Trial within trial is not really a pleasant affair for the defence counsel.
The eminent justice of the Supreme Court Rhodes – Vivour, JSC in Owhoruke v. COP 15 NWLR (Pt. 1483) 557 at 570 empathized with defendants and the defence counsel thus: “it must be noted that most crimes are committed by people with little or no education, consequently they are easily led along by the investigating Police Officer to write incriminating statements which legal minds find almost impossible to unravel and resolve. Confessional statements are most times beaten out of suspects, and the courts usually admit such statements as counsel and the accused are unable to prove that the statement was not made voluntarily. A fair trial presupposes that police investigation of the crime for which the accused person stands trial was transparent. In that regard it is time for safeguards to be put in place to guarantee transparency. It is seriously recommended that confessional statements should only be taken from suspect if, and only if his counsel is present, or in the presence of a legal practitioner. Where this is not done such a confessional statement should be rejected by the court”.
ACJA made a similar provision in Section 15 (4) as follows “where a suspect who is arrested with or without warrant volunteers to make a confessional statement, the police officer shall ensure that the making and taking of the statement shall be in writing and may be recorded electronically on a retrieval video compact disc or such other audio visual means.
Note though that Section 8 (1) ACJA already provides that “a suspect shall be accorded humane treatment, having regard to his right to the dignity of his person and not be subjected to any form of torture, cruel, inhuman or degrading treatment”.
It does appear that compared to the provisions of the Lagos Law, ACJA does not make electronic visual recording mandatory. This is why Section 15 (5) is a provision that waters down Section 15 (4) of ACJA. It provides, “notwithstanding the provision of Subsection (4) of this section, an oral confession of arrested suspect shall be admissible in evidence”.
At the time ACJL came into force in Lagos State, many thought this provision offended the rules of evidence over which only the federal legislature superintends as it was clearly incongruous with the provisions of Sections 28 and 29 of the Evidence Act. Thankfully the Federal legislature in enacting ACJA validated the forward looking and pragmatic initiative of Lagos State with ACJL in line with the reasoning of the Court of Appeal in 2010 when it became an issue of whether a lacuna in the Evidence Act can be positively resolved by a judicial pronouncement when it held in FRN v. Fani Kayode (2010) 14 NWLR (Pt. 1214) 481 at 492 “while judges must refrain from attempting to make laws from the bench, they must not shy away from adopting a proactive approach to the interpretation of the law. Judicial officers must not place on themselves, disabilities not imposed by the law.”
The Court proceeded further “I think, it was the veritable Lord Denning MR, who in his notoriously erudite and visionary characteristics aptly remarked thus – ‘What is the argument on the other side? Only this, that no case has been found in which it has been done before. That argument does not appeal to me in the least. If we never do anything which has not been done before, we shall never get anywhere. The law will stand still whilst the rest of the world goes on: and that will be bad for both.’ See Packer v. Packer (1954) 15 at 22″
The Court went on to hold that computer generated documents in keeping with modern times, the great leap and advancement in technology though not envisaged and provided for in the old Evidence Act were none the less admissible so long as they emanate from proper custody and are relevant to the facts in issue.
The Evidence Act was eventually amended in 2011 and in Section 84 (1) provided “in any proceedings, a statement contained in a document produced by a computer shall be admissible as evidence of any fact stated in it of which direct oral evidence would be admissible, if it is shown that the conditions in subsection (2) of this section are satisfied in relation to the statement and the computer in question”.
The only other issue to note here is that the mere requirement that a Lawyer be present when statements are taken needs to be qualified. Mere presence will amount to nothing if the Lawyer cannot guide the suspect especially where direct questions which if answered may amount to self incrimination are thrown at the suspect.
However Section 17 ACJA provides that the legal practitioner present shall not interfere while the suspect is making his statement, except for the purpose of discharging his role as a legal practitioner. One may therefore ask, what is his role as a legal practitioner in the circumstances?
Plea Bargain and Sentence Agreements:
Plea bargaining gained traction in Nigeria with the establishment of the Economic and Financial Crimes Commission even though there was no clear provision for it in Nigeria at the time. The ACJL has now specifically provided for plea bargain in Section 76 thus: “notwithstanding anything in this Law or in any other law, the Attorney-General of the State shall have power to consider and accept a plea bargain from a person charged with any offence where the Attorney-General is of the view that the acceptance of such plea bargain is in the public interest, the interest of justice and the need to prevent the abuse of legal process”.
Simply put, plea bargain means the negotiation of an agreement between the prosecution and the defence whereby the Defendant is allowed to plead guilty to a lesser/reduced offence/charge in exchange for a more lenient sentence or an agreement to drop other charges against the Defendant.
The ACJL also allows the prosecutor and the defendant or his legal practitioner to enter into a plea bargain agreement before the plea is taken subject to the overriding discretion of the judge who will however not participate in the negotiations.
Section 270 of ACJA has similar provisions that will extend to non-custodial sentencing including parole, suspended sentence and community service.
Plea bargain saves time and resources, reduces the trauma to the victims, aid prison decongestion, helps case management, reduces the number of inmates awaiting trial. In the same vein, non-custodial sentencing helps decongest our prisons and allow convicts to contribute to societal good in terms of community service.
Collection, Storage of Data and Record of Arrests:
Section 20 (1) ACJL requires that “officers in charge of Police station shall report to the nearest Magistrate the cases of all persons arrested without warrant within the limits of their respective station whether such persons have been admitted to bail or not and the Chief Magistrate shall notify the Chief Registrar of the High Court of such report who shall forward the report to the Director of Public Prosecutions for necessary actions”.
The ACJL further directs that “the Commissioner of Police shall remit to the Office of the Attorney-General a record of all arrests made with or without a warrant in relation to state offences within one week of the arrest”.
ACJA made similar provisions to the effect that the police takes a full inventory of every arrested person, including the persons physical and biometric data within 48 hours. This is to prevent unreasonable pre-trial detention by the police and other law enforcement agencies. See Section 15 (1) & (2) ACJA.
There is established in Section 16 (1) ACJA a Central Criminal Records Registry at the Police Force where all information of all persons who encounters the criminal justice processes are stored and managed. Section 16 (2) creates Criminal Record Registry in all State commands, where all the data collected of all arrested persons from the police posts and divisions are transmitted to the State Command Registry and then collated and stored at the Central Registry at the force headquarters.
A critical provision is Section 16 (3) ACJA which makes it mandatory for the police to ensure that the decision of the Court in all criminal trials are transmitted to the Central Criminal Records Registry within thirty days of delivery of the judgement.
Imagine what it will mean for the administration of criminal justice in Nigeria if this little effort at registration of criminal convictions or acquittals are made! The prosecution will know who and what they are dealing with from day one. The defence counsel can no longer cast every serial offender as an innocent person making his first and unintended transgression against the Law. Above all, everyone could search the registry as you would at the Corporate Affairs Commission and easily overcome the problem of information asymmetry in the administration of criminal justice in Nigeria.
According to Chino Obiagwu, the Executive Director of Legal Defence and Assistance Project in his piece “ACJ Act 2015: New Face of Federal Criminal Justice Administration”, “this is an innovation that would improve crime prevention and management in the country. It requires strong political will of the police leadership and other federal justice sector institutions leaders to fully implement it. It will be very useful to have strong coordination and increased exchange of data including harmonisation of biometric information among the security and other electronic data sources including telecommunications, banks, customs, passport and immigration offices, etc so that it can be fed into the national identity card programme that would ensure that all residents of Nigeria are captured in a well managed and IT-based data base”.
The ACJA further provided that the Attorney-General of the Federation shall maintain an electronic register of arrests, which will collate reports of all arrested persons from the police state commands and the force headquarters to the Attorney-General’s office.
Section 29 (1) – “the inspector- General of police and the head of every agency recognized by law to make arrests shall remit quarterly to the Attorney-General of the Federation a record of all arrests made with or without warrant in relation to federal offences within Nigeria.
(2) – “the Commissioner of Police in a State and head of every agency authorized by law to make arrests within a State shall remit quarterly to the Attorney-General of that State a record of all arrests made with or without warrant in relation to State offences or arrests within the State.
(3) – “the report shall contain the full particulars of arrested suspects as prescribed by Section 15 of this Act.
(4) – “a register of arrests containing the particulars prescribed in section 15 of this Act shall be kept in the prescribed form at every police station or agency recognized by law to make arrests, whether made with or without warrant, within the local limits of the police station or agency, or within the Federal Capital Territory, Abuja, shall be entered accordingly by the officer in charge of the police station or official in charge of the agency as soon as the arrested suspect is brought to the police station or agency”.
(5) – the Attorney-General of the Federation shall establish an electronic and manual database of all records of arrests at the Federal and State level.
One can only hope that all involved will do what is right to give efficacy to these provisions.
Report to Supervising Magistrate, Chief Magistrate Visit to Police Station, and Returns by Comptroller – General of Prisons:
To further secure the rights of suspects, track everyone who encounter the criminal justice system, prevent human rights abuses and perhaps to prevent undue and prolonged detention of suspects the ACJA made further note worthy provisions.
Section 33 (1) thereof provides that an officer in charge of a police station or an official in charge of an agency authorized to make arrest shall on the last working day of every month report to the nearest Magistrate the cases of all suspects arrested without warrant within the limits of their stations or agency whether the suspects have been admitted to bail or not.
Section 34 of ACJA in the same vein provides that the Chief Magistrate, or where there is no Chief Magistrate within the police division, any Magistrate designated by the Chief Judge for that purpose shall, at least every month, conduct an inspection of police stations or other places of detention within his territorial jurisdiction other the prison.
Section 111 ACJA further provides that the Comptroller – General of Prisons is to make returns every 90 days to the Chief Judges, President of the National Industrial Court and the Attorney – General of the Federation of all persons awaiting trial held in custody for a period beyond 180 days from the date of arraignment.
ACJA makes it mandatory that upon the receipt of such return, the recipient shall take such steps as necessary to address the issues raised in the return in furtherance of the objectives of the Act.
If you are a defence counsel, one of the major causes of frustration and delay in criminal trials is the time spent to obtain the Advice of the Director of Public Prosecution in our various States which has been euphemistically tagged “awaiting DPP’s advice”.
Now the ACJL recognized this as an embarrassment and major cause of delays in criminal trials and therefore directs in Section 74 (1) ACJL that the Commissioner of Police “shall forward all duplicate case files with respect to indictable offences to the Office of the Attorney-General for the purpose of issuance of legal advice”.
However the ACJA took this further by imposing time frames to ensure prompt issuance of legal advice and aid speedy trials. Section 376 (1) imposed an obligation on the police to forward the casefile of investigations in respect of an offence the magistrate has no jurisdiction to try to the Attorney-General of the Federation to issue legal advice within 14 days of the receipt of the case file indicating whether or not there is a prima facie case against the defendant for which he can be prosecuted. Copies of such legal advice must be served on the police, the court and the suspect involved.
The elaborate prescriptions for time limits for the issuance of legal advice by the Attorney-General will greatly help the decongestion of our prisons and facilitate expeditious trials as ACJA also provides that the suspect should be released unconditionally if he is not charged to court after 56 days upon with or without an application by his legal practitioner and no further application for remand shall be entertained in the matter. See Section 296 ACJA.
Simplification of Bail Processes:
The ACJL now makes provisions in Sections 118 (3), 119 and 138 respectively to ease bail burden on suspects which are at times overwhelming and almost impossible to discharge. The provisions are:
- a) No person shall be denied or prevented or restricted from entering into any recognizance or standing as suretry or providing any security on the ground that the person is a woman.
- b) A Judge may, if he thinks fit, admit any person charged before a Magistrate Court to bail although the Court before whom the Charge was made has not thought it fit to do so.
- c) The Chief Judge may, by regulation, register and license individuals or corporate bodies or persons to act as Bondspersons within the jurisdiction of the Court in which they are registered.
See Sections 167 (3) and 187 (1) of ACJA for similar provisions.
We consider these provisions very important as one of the factors which account for prison congestion and long trials is the inability of suspects to meet their bail conditions. Any simplification of the process that the extant law proposes to facilitate the early release of persons in custody is a welcome development. Bondspersons will help all and sundry as it will eliminate the need for every accused person to have personal sureties who will meet the specifications of the conditions of bail.
Section 291 to 296 of ACJA provides for remand proceedings and time limit.
The point to note is that Section 293 of ACJA generally provides that upon an application ex parte by the police in the prescribed form a magistrate may order the remand of a suspect pending the receipt of the Legal advise of the Attorney-General of the Federation.
Section 296 ACJA imposes time limits of 14 days on four different accounts for the prosecution to take steps to prosecute the suspect and where that is not done for a cumulative 56 days, the magistrate is empowered to release the suspect from prison custody unconditionally. See Section 296 (6) (7) and Lufadeju v. Johnson (2007) 8 NWLR (Pt. 1037) 538.
There is the major advantage that this provision will prevent the pre-trial process from dragging on and shortening time spent ‘awaiting DPP’s advice’, promote prompt arraignment before the trial court and help decongest our prisons.
Abolition of Lay Prosecutors:
Constitutionally the Attorney-General of the Federation and of the federating States are vested with the powers to prosecute offenders personally or through the legal officers in the Justice Ministry.
However the prosecutorial powers of the police and other law enforcement agencies like the EFCC, ICPC, NDLEA have been recognized and assured by the enabling Act establishing these agencies albeit subject to the overriding power of the Attorney-General to takeover or discontinue any such proceedings at any time before judgement.
The Supreme Court of Nigeria had held in the two landmark cases of Olusemo v. the Commissioner of Police (1998) II NWLR (pt 575), 547 and Federal Republic of Nigeria v. Osahon (2006) that the power to prosecute is not limited to the Attorney General alone. A police officer and any such other person or body who has been statutorily clothed with the power to prosecute can do so but subject of course to the Attorney General’s power to take over and continue any such criminal proceedings that may have been instituted by any other authority or person; and to discontinue at any stage before judgement is delivered any such criminal proceedings instituted or undertaken by him or any other authority or person. In exercising these powers, the constitution granted the Attorney General the latitude and wide discretion as he shall only have regard to the public interest, the interest of justice and the need to prevent abuse of legal process and the Attorney General alone determines when and in what circumstances to act.
Therefore the fact that the EFCC and ICPC and other such bodies as NAFDAC and NDLEA have the power to prosecute before the enactment of ACJL and ACJA is a moot point. See further Customs and Excise v. Senator Barau (1982) 2 N.C.R. 1 and Unipetrol Plc. v. E.S.B.I.R (2006) Vol. 6 M.J.S.C 114. The Supreme Court even widened the frontiers, pronouncing in Fawehinmi v. Akilu & Togun (1987) 4 NWLR (Pt. 67) 797 that a private citizen had the locus, which is the standing to prosecute or file an information after an application endorsed by the Attorney-General.
However, it now appears that the tables have turned. By the relevant provision of the Lagos Law and ACJA, police lay prosecutors are to be abolished. By the provisions of ACJL trials should be held in the High court on information filed by a Law Officer or Private Prosecutor.
Section 253 ACJL categorically provides that “information shall be signed by a Law Officer”. The implied interpretation of this is that since a criminal trial can only be commenced at the High Court by an information, which can only be signed by a Law Officer, the policeman, even if learned in law, not being a Law Officer is thus excluded from prosecuting at the Lagos High Court.
The ACJA made similar provisions in Section 106 to the effect that the prosecution of all offences in any Court shall be undertaken by the Attorney-General of the Federation or a law officer in his ministry, a legal practitioner authorized by him to prosecute or a legal practitioner authorized by ACJA or any Act of the National Assembly to prosecute.
It should be obvious that by this provision, any police officer or public official who is not a qualified legal practitioner cannot prosecute in the Federal High Court, the High Court and the Magistrate Courts of the Federal Capital Territory.
Ostensibly this provision was made to cure the apparent incapacity of lay prosecutors to respond to vital issues of law raised for determination by legal practitioners appearing for defendants in criminal trials, delay by lay prosecutors who never seem to have their witnesses on hand and the alarming failure of lay prosecutors to secure convictions in many simple cases especially at the magistrate courts.
Section 74 (6) ACJL prescribed a State-run free legal services to a suspect in the form of the Office of the Public Defender (OPD) when it states that “a form indicating a desire to be represented by counsel of his choice or the Office of the Public Defender, Legal Aid Council or any other organization providing legal aid shall be attached to each legal advice for purpose of endorsement by the person in respect of whom legal advice is preferred”.
The OPD has such powers as:
- a) The provision of legal aid services and advice;
- b) To receive complaints from individuals or by referrals from government and private institutions;
- c) Investigate complaints and referrals made to it and to prepare necessary legal documents;
- d) Negotiate settlements or give necessary legal advice in alternative dispute resolutions, etc.
On the other hand Section 17 (2) of ACJA provides for the desirability of recording a suspect’s extra-judicial statement in the presence of a legal practitioner of his choice or an officer of the Legal Aid Council of Nigeria, or an official of a Civil Society Organisation or a Justice of the Peace or any other person of his choice.
Whilst both Laws recognised the traditional role of the Legal Aid Council in providing legal aid services to indigent Nigerians, the Lagos Law took it further by widening the scope and bringing in OPD which operations have enabled the provision of free legal services in respect of criminal and civil matters to indigent residents of Lagos State without regards to tribe, race or religion.
The Government of Lagos State and the Federal Government ought to be commended for the long overdue overhaul of the administration of criminal justice in Nigeria. A few States of the Federation have followed suit and those who have not done so have been urged to adopt and or domesticate the model federal law in their jurisdiction of competence.
A crime free society is a prosperous society where economic and social development is assured so this attempt at galvanizing an efficient and effective administration of criminal justice in Nigeria is one that all stakeholders and every Nigerian must embrace and work assiduously towards the realization of the objectives of the Federal and State Laws.
Stephen Onimisi Obajaja, a Lagos based Legal practitioner is the immediate past Secretary of the Nigerian Bar Association ( NBA) Lagos Branch.
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