Part One – A Backward Glance
For some time now, I have toyed with the idea of writing about the inconclusive Nigerian Bar Association (NBA) Conference held in Port Harcourt, Rivers State in 1992 and its aftermath, but kept postponing it for some inexplicable reason.
However, recent events in the NBA have compelled me to write about this period in the life of the association being a very active participant as a Bar activist and the Secretary of the Committee of Chairmen and Secretaries that helped to midwife the return of the NBA at the national level and successfully handed over to an elected body of officials in August, 1998.
The present intervention is therefore made with a huge sense of responsibility, borne out of the firm conviction that it is imperative to give as accurate an account as possible of those ‘dark days’ before, during and in the aftermath of the Conference which sharply divided the Bar like nothing else before – nor since.
This is more so as some of the active players at the Bar today were not in the profession twenty eight years ago. Calls to dismember the Bar have been growing louder, hence my appeal for caution.
I contested for the Office of Assistant Secretary General of the Nigerian Bar Association (NBA) at the said Conference.
At that time, elections into the Executive Committee of the NBA were conducted annually and an incumbent could re-contest for the same Office for a further term of one year only.
The incumbent President of the Association at the time, Chief Clement Obiora Akpamgbo SAN was elected at the Owerri Conference in 1991 and was to serve till 1992.
However, shortly after his election, he was appointed as the Honourable Attorney-General and Minister of Justice of the Federation (HAGF).
In taking up that appointment, Chief Akpamgbo merely followed the example of Prince Bola Ajibola (as he then was) who became Attorney-General of the Federation in 1985, shortly after his election as NBA President in 1984.
Accordingly, it fell to Mr. Ebele Nwokoye, the then first Vice-President of the NBA, to serve out the term of Prince Bola Ajibola as President of the NBA. Mr. Nwokoye was elected President in his own right and served first from 1985 to 1986, and again – following his re-election – from 1986 to 1987.
In the same vein, Chief (Mrs.) Priscilla Kuye, as the then first Vice-President served out the term of Chief Akpamgbo SAN as President of the NBA following his move to the Government, as aforesaid.
Just like Mr. Nwokoye, she contested for the Presidency, in her own right, at the 1992 Port-Harcourt Conference, which however, was not to be in circumstances that I shall presently outline.
Prior to the Conference, there were serious unresolved issues in the NBA arising from the tenure of Mr. Charles Idehen as President of the Association, and even before then.
Given the previous successive appointments of Prince Judge Bola Ajibola SAN and Chief Clement Obiora Akpamgbo SAN by the Government of General Ibrahim Badamasi Babangida as the Honourable Attorney General of the Federal (HAGF) and Minister of Justice, as well as the then ongoing transition to civilian rule programme which started in 1989 with the appointment of the National Electoral Commission (NEC) headed by Professor Humphrey Nwosu, the stakes for the Office of the President of the NBA were very high.
These issues came to a head at the Port-Harcourt Conference in 1992; the contestants for the Presidency were Chief (Mrs.) Priscilla Kuye – who was the acting President of the NBA, Alhaji Bashir Dalhatu, Mr. Segun Onakoya and Mr. Kanmi Ishola Osobu (Peoples’ Law).
At the Conference rumours were rife that certain groups had entered the Conference venue with hired thugs, disguised as Lawyers, with the alleged aim of achieving a pre-determined outcome at the elections.
In other words, for the first time in the history of the NBA, election into the Office of the President of the NBA had taken a decidedly political hue in the context of the larger Nigerian polity. Accordingly, the ensuing campaign was tenser than ever, to put it mildly.
To start with, accreditation of voters at the election was delayed and the Executive Committee which ought to have been dissolved preparatory to the elections was not dissolved.
When Chief Gani Fawehinmi (as he then was) was recognized to address the Conference, the microphone was seized from him. In the ensuing confusion, Chief (Mrs.) Priscilla Kuye was forced to adjourn the election sine die when she was served with an interim injunction issued by a Port-Harcourt High Court which ordered the suspension of the election.
It marked the first time that an election would be stopped on the Orders of a Court of law – but it would not be the last. It also threw the NBA – at least its national body – into a state of abeyance, which defied all efforts at resuscitating it until the Federal Government interned by promulgating the Legal Practitioners (Amendment) Decree No. 21 of 1993.
This statute a constituted a body – christened the Caretaker Committee of the Body of Benchers under the Chairmanship of Chief Frederick Rotimi Alade Williams SAN; (hereinafter referred to as the Chief FRA Williams’ Committee), mandate was to manage the affairs of the NBA.
The Decree specifically amended the Legal Practitioners Act by introducing a new Section 23A therein; this provision ousted the right of “any person to commence or maintain an action or any legal proceedings whatsoever relating to, connected with or arising from (a) the management of the affairs of the Association; or (b) the exercise or preparation by the Body of Benchers for the exercise of the powers conferred upon it by this Act”.
However, this (ouster clause) did not deter a legal challenge to Chief FRA Williams’ Committee championed by the Ikeja Branch of the Association, which had Chief Samuel Olasupo Morohundiya as its founding Chairman, with Chief Olu Akintunde and 20 others as the arrow-heads.
The suit was heard by Honourable Justice O. O. Obadina (as he then was), who, on Thursday 10th June, 1993, granted an interim injunction restraining the Respondents from interfering with the internal affairs of the NBA, amongst other reliefs.
The appeal by Chief Williams’ Committee (reported as WILLIAMS vs. AKINTUNDE (1995) 3 NWLR 101), was dismissed by the Court of Appeal on Tuesday, 20th September, 1994. In the aftermath of this decision, the Government, once again, amended the Legal Practitioners Act, while Chief FRA Williams SAN retained his position as the Chairman of the said Committee.
In response, the Ikeja Branch of the Association passed yet another Resolution condemning the move. In my capacity as a candidate in the botched 1992 elections, I instituted a legal action – RICHARD OMA AHONARUOGHO vs. CHIEF F.R.A. WILLIAMS SAN AND OTHERS (FOR HIMSELF AND ON BEHALF OF THE BODY OF BENCHERS CARETAKER COMMITTEE OF THE NBA) at the Ikeja Judicial Division of the High Court of Justice, before Honourable Justice Caroline Olufawo.
It was successful, as the court granted an interim injunction against the Defendants, on the ground that there was a subsisting injunction against Chief FRA Williams’ Committee issued in Chief Akintunde’s case as aforesaid. Chief FRA Williams SAN unsuccessfully attempted to upturn the injunction.
During the pendency of the suit, I was elected as the Secretary of the Ikeja Branch of the Association. With the active support of the Branch Chairman, Mr. Oladosu Ogunniyi, a perfect gentleman, the Ikeja Branch championed calls for the resuscitation of the NBA, using the Branches as a springboard.
At great personal cost, I visited virtually all the 88 Branches of the Association, soliciting their support for the project. I recall that this was at a time of severe fuel scarcity.
I sometime got to my destination at 1.00am driving. I often ran out of money and my car broke down numerous times.
I had to remain in far-long locations for days waiting for Mojisola, my wife to get money to me through First Bank money transfer which could take up to 3 days!
At about the same time, the Adamawa Branch of the NBA also passed a resolution championed by Alhaji Murtala Aminu OFR, the Galadima of Adamawa, calling for a resolution of the NBA crisis.
Mr. Oladosu Ogunniyi, Chairman of the NBA Ikeja Branch then wrote letters inviting all the Chairmen and Secretaries of 88 Branches of the NBA, to a meeting at the NBA Ikeja Branch Bar Centre.
The meeting which was held in 1996 was summoned to reflect, discuss, consider, and deliberate on a way to resuscitate the NBA.
In the course of the said meeting (in 1996), Mrs. Yargata Nimpar (as she then was, (now a Honourable Justice of the Court of Appeal), who was then the Chairperson of the Jos Branch of the Association, moved a Motion to convert the meeting into a meeting of the “Committee of Chairmen and Secretaries of the Nigerian Bar Association”.
The motion was carried, upon which Chief Solomon Adegboyega Awomolo SAN, emerged as the Chairman of the newly-formed Committee, with my humble self, Richard Oma Ahonaruogho, as the Committee Secretary. Although we were not given a time-frame, our mandate was clear – to revive the NBA.
The attendance at the funeral, in 1996, of Mr. Kanmi Ishola Osobu (Peoples’ Law) – one of the contestants at the aborted Presidential elections in the Port-Harcourt Conference 4 years earlier – was an early indication that Lawyers, across all the divides and tendencies within the NBA, were tired of the prevailing status quo, and earnestly yearned for a re-united Bar.
However, just as our Committee was getting down to its task, Mr. Charles Idehen, a Past President of the NBA lost his wife, Mrs. Faith Idehen on 21st December, 1996.
Her own funeral, in Benin, on 21st January, 1997, also attracted virtually all the 88 Branch Chairmen of the Association and the two main dramatis personae in the NBA crisis at the time – Chief (Mrs.) Priscilla Kuye and Alhaji Bashir Dalhatu.
However, the ‘battle’ was far from over, as two prominent members of the Lagos Branch of the NBA, Emeka Celestine Nwosu and Fred Agbeyegbe as Plaintiffs instituted an action against “(1) Chief F. R. A. Williams (SAN), (2) Mrs. Hairat Aderinsola Balogun (For themselves and the Body of the Benchers), (3) Chief B. O. Benson, (4) Chief Debo Akande SAN (For themselves and Trustees of the Nigerian Bar Association). (5) Chief (Mrs.) P. O. Kuye, (6) Prince Adesuyi Olateru-Olagbegi (For themselves and the Nigerian Bar Association), (7) Sir Emmanuel Ofulue, (8) Oladosu Ogunniyi. (9) Chief S. A. Awomolo SAN, (10) Richard O. Ahonaruogho and (11) Attorney General of the Federation (For themselves and the Committee of Chairmen and Secretaries of Nigerian Bar Association)”.
Thus, from being a Plaintiff in one suit, I became a Defendant in another in the good company of all those listed therein and was greatly comforted that Chief F.R.A. Williams SAN and I were on the same side as Defendants! Some aspects of the case went up to the Court of Appeal and is reported as CHIEF F. R. A. WILLIAMS SAN & 10 OTHERS vs. EMEKA CELESTINE NWOSU & ANOTHER (2000) 9 NWLR Part 671 Page 215.
In any event, the suit did not affect the work of our Committee, as we were able to visit the Honourable Chief Justice of Nigeria, The Honourable Muhammad Lawal Uwais; The Honourable Justices of the Supreme Court; the President of the Court of Appeal, Honourable Justice Muhammad Mustapha Adebayo Akanbi; other Justices of the Court of Appeal; Heads of Court, and many Senior members of the Bar, including Chief F.R.A. Williams SAN, Mrs. Hairat Aderinsola Balogun, Chief Andrew N. Anyamene SAN, Chief Phillip Green Umeadi SAN and a host of others. These consultations yielded a consensus that our Committee should “test the waters” by organizing a Plenary Conference of the Nigerian Bar Association.
The 1997 Plenary Conference held at the University of Jos was attended by a host of distinguished personalities and addresses were delivered by Honourable Justice Chukwudifu Oputa JSC, Honourable Justice Niki Tobi JCA (as he then was), and other eminent Speakers.
The Conference was as a huge success and fears being entertained before the Conference that the General Sanni Abacha led-Government would disrupt same came to naught. It was unanimously decided that an Election Conference be held the following year, in Abuja.
For ethical reasons, Chief Solomon Adegboyega Awomolo SAN and my humble self disqualified ourselves from standing for any office in the elections (given that we were the ‘midwives’ of the processes).
This decision to hold an election conference was supported by all the Branches of the NBA, including the Lagos Branch.
Chief F.R.A. Williams SAN, who was unwell in the United Kingdom receiving medical attention also throw his weight behind the Committee and was so committed to the resuscitation of the NBA that he led the contribution to the funds required for the hosting of the Conference at the Sheraton Hotel, Abuja.
Chief F.R.A. Williams SAN was emulated by other senior members. To further demonstrate his support, Chief F.R.A. Williams SAN returned from the United Kingdom on time to attend the August 1998 Abuja Conference and witnessed the election of the National Officers of the Association on Friday 28th August, 2008, whereat Chief T. J. Onomigbo Okpoko SAN was elected as President and Mr. Clement Obi I. Okwusogu, Esq. (as he then was), was elected as Secretary General.
The success of the 1998 Conference was due in no small part to the efforts of Chief Anthony Mogboh SAN, who kept prudent management of the finances of our Committee; this ensured that all our activities were entirely self-financed and we had no cause to go “cap-in-hand” to solicit for funds for our activities from Government.
Special mention must also be made of Mr. Oladosu Ogunniyi, the Chairman of the Ikeja Branch who provided the leadership which birthed the Committee in the first place.
While we are at it, it will be remiss of me to fail to mention other eminent legal practitioners who played pivotal roles in assisting the Committee to get the NBA back to her feet. They include Chief Dr. Mudiaga Odje SAN, Chief (Mrs.) Folake Solanke SAN, Chief Andrew N. Anyamene SAN, Chief Phillip Green E. Umeadi SAN (Ozomma), Chief Clement Obiora Akpamgbo SAN, Chief Debo Akande SAN, Chief Afe Babalola SAN, Alhaji Aliyu Salman SAN, Chief T. J. Onomigbo Okpoko SAN, Chief G. A. Graham Douglas SAN, Chief Nathaniel N. Anah SAN, Chief Idowu Sofola SAN, Chief Bamidele Aiku SAN, Chief S. M. Olakunrin, Chief Milton Paul Ohwovoriole SAN, Chief ‘Wole Olanipekun SAN, Chief Babashola Orobiyi Rhodes SAN, Mr. Jonny C. Okonkwo SAN, Chief Mike I. Ahamba SAN, Chief George. N. O. Uwechue SAN, Otunba (Mrs.) C. O. Ajayi-Okunuga, Chief Ladi-Rotimi Williams SAN, Chief Alfred O. Eghobaminen SAN, Mr. O. C. J Okocha SAN, Mr. Joseph Bodurin Daudu SAN, Prince Lateef O. Fagbemi SAN, Chief Tochukwu Onwugbuofor SAN, Chief Chuks Muoma SAN, Chief G. Ofodile Okafor SAN, Mr. Bankole Aluko SAN, Dr. Theo C. Osanakpo SAN, Mr. Yusuf Olaolu Ali SAN, Chief O. B. Onyali SAN, Chief B. M Wifa SAN, Professor Gabriel O. Olawoyin SAN, Chief E. L. Akpofure SAN, Mr. Olisa Agbakoba SAN, HE. Rotimi Akeredolu SAN and Chief Joe Kyari Gadzama SAN.
Other senior Legal Practitioners, all of whom became Senior Advocates of Nigeria that participated in the work of the Committee and efforts at reviving the NBA include Mr. Kola Awodein, Chief Bayo Ojo, Mr. P. O Jimoh-Lasisi, Chief Emmanuel C Ukala, Malam Yunus Ustaz Usman, Dr. Alex Izinyon, Mr. Awa U. Kalu SAN, Chief Chike Chigbue SAN, Chief Anthony I. Idigbe, Chief Charles Uwensuyi-Edosomwan, Mr. Rickey Tarfa, Chief Albert Ojo Akanle, Chief Theodora A. Ezeobi, Mrs. Funke Adekoya, Chief D. Nnamdi A. Ibegbu, Mr. A. B Mahmud, Chief Albert Akpomudje, Prince Adetokunbo Kayode, Chief Adeniyi Akintola, Mr. Damain D Dodo, Professor Taiwo Osipitan, Chief Johan Obika Aghimien, Professor Ignatius Akaayar Ayua, Chief Emeka Ngige, Chief (Mrs.) Anayo Justina Offiah, Chief Chris Uche, Mr. Tayo Oyetibo, Chief Afolabi Fashanu, Chief Mamman Mike Osuman, Chief Victor Ndoma-Egba, Mr. Deji Sasegbon, Chief Dafe Jude Akpedeye, Mr. Mike Igbokwe, Nr. Omoruyi Augustine Omonuwa SAN, Mr. Patrick Ikwueto, Mr. Cyprian Okafor Anah, Chief Nwodibike Nwanodi, Mr. Adebayo O. Adelodun, Mr. Joe Odey Agi, Mr. Nathaniel O. O. Oke, Mr. Duro Adeyele, Mr. Roland Ifoyah Otaru, Mr. Ibrahim Ishaku, Deacon Julius Dele Adesina , Mr. Augustine Oyarekhua Alegeh, Mr. Sunday Ibrahim Ameh, Mr. Paul Erokoro, Mr. Ocholi James, Chief Okey E Wali, Chief Charles Adogah, and Mr. Clement Obi I. Okwusogu,
Other senior Lawyers who later took Silks also deserving of mention are: Donald Chika Denwigwe, Chief Ulasi Raleke Obiefuna, Chief Karina Tunyan, Mr. Lawal Mohammed Pedro, Chief R.A. Lawal-Rabana, Chief (Dr.) Mike A. A. Ozekhome, Mrs. Dorothy Ufot, Mr. Pat Onegbedan, Mr. Kenneth Mozia, Chief Ferdinand Oshioke Orbih, Mr. Samuel Ologunorisa, Alhaji Aliyu Umar, Chief Henry O. Ogbodu, Mr. Femi Falana, Dr. Garba Tetengi mni, Funke Aboyade, Alhaji Olalekan Yusuf, Professor Ernest Ojukwu Mr. Chike Onyemenam, Mr. Samuel Zibiri, Mr. Emmanuel Aguma, Professor Maxwell Gidado, Chief Muyiwa Akinboro, Mr. Abdul Atadoga Ibrahim, Professor Wahab Olasupo Egbewole, Mr. George Chiedu Igbokwe, Chief Oluseun T. Akinbiyi and Mr. Daniel C. Enwelum; all of whom gave invaluable support to the Committee.
This compilation would be grossly defective without including Professor (Mrs.) Jadesola Akande, Chief (Mrs.) Priscilla Kuye, Alhaji Bashir Muhammed Dalhatu, Alhaji Murtala Aminu OFR (the Galadima of Adamawa), Professor Awalu Yaduddu, Mr. Jalal Arabi, Chief David Obasola Ajijola, and Honourable Justice Dolapo Akinsanya. Some Legal Practitioners who later became judicial Officers include: Honourable Justice Yargata Nimpar JCA, Honourable Justice Peter Olawale Ige JCA, Honourable Justice Okechukwu Joseph Okeke (retired), Honourable Justice Adesuyi Olateru-Olagbegi (retired), Honourable Justice Niyi Adebajo (retired), Honourable Justice Oyindamola Deborah Oluwayemi (retired), Honourable Justice Nasiru Ajanah (Chief Judge of Kogi State), Honourable Justice Ngozi Azinge and Honourable Justice Peter Obiora. Also others who became Governors include: HE Aminu Waziri Tambuwal, HE Bala Ngilari, HE M. A. Abubakar and HE Rotimi Akeredolu SAN.
Chief M. A. Ajomale who later became the Chairman of the Body of Benchers and a Life Bencher together with Mr. Christian O. Scott-Emuakpor, Senator Onyeabo Obi, Chief Dr. Lateef Adegbite, Pa. Tunji Gomez (It’s a matter of conscience), Chief Adigun Ogunseitan, Chief Pius J. O. Anigboro, Mr. Goodie M. Ibru, Mr. Funso Fayokun (Afro), Chief (Mrs.) Ndidi Edewor, Chief Folorunso Adebayo Akinbiseyin, Chief Victor O. Odunnaiya, Chief Bisi Adegunle, HRM David Serena Dokubo-Spiff, Prince Lanke Odogiyan, Mr. Philip Ndubusi Umeh, Honourable Obafemi Adewale, Professor M. T. Abdulrazaq, Mr. Dele Oye, Chief Zik Obi, Chief Chibuzo Nduwueze Ziggy Azike, Chief Eddy A. Chukwura, Ambassador (Mrs.) Modupe Akinola, Senator Abubakar Danso Sondangi, Mr. Dixy Odirri, Mr. Ebenezer Obeya, Mr. Oluwole Uzzi, Mr. Emmanuel D, Chukuma, Mr. John I. Igu, Mr. K. O. Obamogie, Dr. Chief Ayuba Giwa, Mr. Adekunle O. Edeki, Sir Chief Emmanuel Ofulue, Chief (Mrs.) Agnes Ofulue, Mr. Noji O. Uloho, Mr. Yinka Fayokun, Hadjia Fatima Kwaku, Alhaji M. U. Ibrahim (alias Jam-Jam), Chief L. M. E. Ejiofor, Chief Sena Anthony, and Lady Debbie Obodokwu played various positive roles during the period.
We must remember the contributions of Senator Gbene Dr. Cyrus Nunieh, Alhaji Danjuma Rindam, Mr. Fred Agbeyegbe, Mr. Abraham Yisa, Mr. Gbenga Oyebode, Mr. Babajide Ogundipe, Chief Tunde Elemide, Chief Emmanuel V. O. Koleosho, Chief Nnadozie Okonta, Chief Dele Edokpayi, Olorogun Kenneth Gbagi, Mr. George Etomi, Mr. Akaraiwe Ikeazor, Mr. Fred Agbaje, Mr. Lai Adegboye, Mrs. Roli Craig, Chief Adewale Gbeleyi, Chief Bayo Jacobs, Dr. Bisi Ademuwagun, Mrs. Abosede Ayodele, Mr. Emeka Nwosu, Mr. Ibrahim Mark, Chief ‘Kunle Uthman, Chief Akuro George, Chief Victor Grant, Mr. Blessing Emonena Ukiri, Mr. Akuzamus Anakwe, Alhaji Buhari Bello, Honourable Dr. Ehiogie West-Idahosa, Alhaji Adamu Audi, Mr. Anozie Obi, mni, Hon. Nimi Walson-Jack mni, Mr. Festus Okoye, Mr. D. D. Azura, Mrs. Philo Agbeyegbe, Mrs. Tola Rotimi, Mrs. Sola Adegbonmire, Chief Oseloka Godwin Osuigwe, Mr. Larry Ovworomoh, Ifeoma Ojemene, Hadjia Hauwa Ibrahim, Ms. Kare Yekwe, Mr. Adetunji Onabawo, Mr. Kunle Aina, Mr. Osahon Idemudia, Mr. Joe Igunbor, Mr. Osahon Ihenyen, Mr. Akin A. Olatunji, Bimbo Olaore, Mrs. Maureen Awobokun, Carol Ajie, Linda Bala, Mr. Richard Ogbeche, Mr. R. N. Godwins, Mr. Opuada Pepple, Mr. Reuben James, Honourable Inuro Wills, Mr. Sunny O. Agwinede, Mr. Okey Owhonda, Chief Uye Ogedengbe, Mr. Uwem Francis Ibiok, Mr. Marc Enamhe, Mr. Folami Fashe, Lady Tina Omiawa, Mr. Kemasuode Wodu, Mr. Paul Agbo, Mr. Innocent Ovagbadia, Mr. Samuel Ogbemudje, Mr. Okey Omezi, Mr. Ilesanmi Ikuomola, Mr. Steve Kuyoro, Mr. Ade Sanusi, Mr. Dele Abina, Professor Aemola Adewale, Professor Ken Nnadozie, Mr. Adewale Doherty, Mr. Emmanuel Ireruke, Mr. Hannibal Uwaifo, Mr. O. J. Folorunso, Bose Akande, Mr. Olajide Babalola, Mr. Olasupo Ojo, Mr. Dennis Ugbong, Mr. Seth Amaefule, Bimpe Odunfa, Mr. Andrew Odum, Mr. Ben O’Kam Iyama, and others too numerous to mention, (for no matter how hard I try, names keeps popping up), to the workings of the Committee of Chairmen and Secretaries of the NBA, which gave the needed impetus.
One of my mentors, Mrs. Hairat Aderinsola Balogun, deserves special mention. Among many trail-blazing achievements which she notched up in the legal profession are the following: the first female Honourable Attorney General of a State in Nigeria (Lagos); the first – and so far, the only – female Secretary General of the NBA and the first female Past Chair of the Body of Benchers and first female Life Bencher. She has been a mother to my better half, Mojisola and I since knowing her in 1987.
Permit me to also acknowledge Mr. Nutifafa Kuenyehia, Mr. Sam Okudzeto and Mr. Joseph Ebow Quashie, all Past Presidents of our sister Bar Association, the Ghana Bar Association (GBA) as well as Mr. J. Ross Harper, CBE and Mr. Desmond Fernando, both Past Presidents of the International Bar Association (IBA) for valuable support.
My decision to mention some of the foregoing names is a duty I owe, even though I know it may get me into some trouble.
I however, believe that the quality of the persons who sacrificed their time, money and ideas in getting the NBA out of the ‘woods’, will assist those clamouring for the dismemberment of Bar Association, to know that getting the Bar Association back after Port Harcourt crises, was herculean.
May the souls of those who have since departed, rest in peace, Amen.
Dr. Richard Oma Ahonaruogho is a Lagos based legal practitioner
The Nation
