By Ishie-Johnson Emmanuel Esq.
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Abstract
This article examines the evolution and current framework of Nigerian insolvency law, focusing on achieving a fair balance between creditor protection and debtor rehabilitation. Tracing the development from early legislation to recent reforms under the Companies and Allied Matters Act (CAMA) 2020 and the Insolvency Regulations 2022, it highlights key features such as business rescue mechanisms, administration, company voluntary arrangements, and netting. The analysis identifies persistent challenges—including limited access to financing, inadequate practitioner regulation, court system overload, and cross-border cooperation deficits—that hinder effective insolvency resolution. Drawing on comparative perspectives from jurisdictions like the UK and India, the article proposes comprehensive reform recommendations spanning legislative, institutional, practical, and policy domains. These reforms aim to enhance insolvency practitioner regulation, promote transparency, improve court efficiency, and foster cross-border cooperation to create a robust insolvency framework that supports economic growth, protects stakeholder rights, and sustains viable businesses in Nigeria’s evolving commercial landscape.
Keywords
Nigerian insolvency law, creditor protection, debtor rehabilitation, CAMA 2020, business rescue, company voluntary arrangement, insolvency practitioner regulation, cross-border insolvency, economic growth, insolvency reforms
Introduction
The Nigerian insolvency law is designed to balance the competing interests of creditors and debtors, ensuring that creditors’ rights are protected while also providing debtors with opportunities for rehabilitation and a fresh start. However, achieving a fair balance between these two objectives remains a significant challenge. The increasing number of business failures and personal insolvencies in Nigeria underscores the need for a robust and effective insolvency regime that balances the rights of creditors with the need to rehabilitate debtors. This article examines the current state of Nigerian insolvency law, highlighting the challenges and opportunities for reform to ensure a fair balance between creditor protection and debtor rehabilitation. By exploring the complexities of insolvency law and the experiences of other jurisdictions, this article aims to contribute to the ongoing debate on how to create a more effective and equitable insolvency regime in Nigeria.
Research Question
- How has the Nigerian insolvency law evolved to balance creditor protection with debtor rehabilitation, especially under the Companies and Allied Matters Act (CAMA) 2020 and Insolvency Regulations 2022?
- What are the key challenges undermining the effective implementation of insolvency procedures in Nigeria, particularly regarding insolvency practitioner regulation, court efficiency, and cross-border insolvency cooperation?
- To what extent do current Nigerian insolvency provisions—such as administration, company voluntary arrangements, and netting—facilitate business rescue and restructuring compared to traditional liquidation?
- How do Nigeria’s insolvency laws compare with those of jurisdictions like the United Kingdom and India in promoting efficient corporate rescue and stakeholder protection?
- What legislative, institutional, and practical reforms are necessary to enhance Nigeria’s insolvency framework to achieve a fair balance between creditor rights and debtor rehabilitation?
- How might the adoption of international standards, including the UNCITRAL Model Law on Cross-Border Insolvency, improve Nigeria’s insolvency regime and cross-border cooperation?
- What role can financial literacy, alternative dispute resolution, and stakeholder engagement play in improving insolvency outcomes in Nigeria?
Scope of the Study
This study focuses on the legal and practical framework governing corporate insolvency in Nigeria, with particular emphasis on balancing creditor protection and debtor rehabilitation under the Companies and Allied Matters Act (CAMA) 2020 and the Insolvency Regulations 2022. It primarily examines insolvency procedures such as administration, company voluntary arrangements, winding-up, and business rescue mechanisms as they apply to companies unable to pay their debts.
The scope is limited to corporate insolvency and excludes detailed exploration of individual bankruptcy law. Consideration is given to the legal standards regulating insolvency practitioners, the role of courts, and the treatment of creditors within insolvency processes.
Additionally, the study incorporates comparative analysis with jurisdictions including the United Kingdom, India, South Africa, and the United States to identify best practices and reform opportunities relevant to Nigeria’s economic and legal context.
The focus is confined to insolvency triggered by genuine inability to pay debts, excluding members’ voluntary winding-up processes. Practical challenges such as court delays, insolvency practitioner regulation, and cross-border insolvency cooperation are also explored within this framework.
Significance of the Study
This study on Nigerian insolvency law is significant for several reasons.
First, it addresses the critical need to balance creditor protection with debtor rehabilitation, a fundamental challenge impacting the efficiency of insolvency resolution, economic stability, and business continuity in Nigeria. By examining recent reforms such as the Companies and Allied Matters Act (CAMA) 2020 and the Insolvency Regulations 2022, the study provides insightful analysis of the strengths and weaknesses of the current legal framework.
Second, the research contributes to legal scholarship and policy discourse by identifying persistent challenges—including inadequate regulation of insolvency practitioners, limited access to financing for distressed companies, court system inefficiencies, and insufficient cross-border cooperation—that impede effective insolvency practice in Nigeria. This understanding is essential for lawmakers, regulators, practitioners, and academics seeking to refine insolvency laws and policies.
Third, by incorporating comparative perspectives with leading international jurisdictions, the study offers practical reform recommendations aimed at aligning Nigeria’s insolvency regime with global best practices. These reforms are vital for fostering a more transparent, equitable, and growth-oriented insolvency environment.
Ultimately, the findings and recommendations in this study have the potential to assist policymakers in designing reforms that promote economic growth through the rescue and rehabilitation of viable businesses, protect stakeholder rights, and enhance the overall trust and effectiveness of the Nigerian insolvency system.
Literature Review
Literature ReviewThe body of literature on Nigerian insolvency law reveals a dynamic yet complex legal landscape characterized by ongoing reforms and persistent challenges. Scholars have extensively examined the evolution of insolvency legislation, with particular focus on the Companies and Allied Matters Act (CAMA) 2020 and its predecessors.
Nwosu (2023) analyzes the corporate insolvency framework under CAMA 2020, highlighting how the Act regulates the roles of official receivers, liquidators, and special managers in winding-up proceedings. Nwosu identifies technical complexities and procedural challenges in the law, noting a legislative bias favoring liquidation over corporate rescue. The author advocates for amendments to simplify processes and enhance business revival prospects.
Similarly, academic studies have critiqued the multiplicity of statutes governing insolvency in Nigeria, observing that these fragmented laws hinder seamless corporate rescue and restructuring (Elizade University Repository). The lack of moratorium provisions, insufficient regulation of insolvency practitioners, and cumbersome winding-up procedures are recurring issues that diminish the effectiveness of the insolvency framework.
Research by Olujobi (2021) underscores the limitations of Nigeria’s insolvency regime, particularly in sectors like the oil industry where insolvency and business recovery laws have not adequately evolved to support the sustained operation of distressed firms. The study calls for reforms that incorporate reorganization and financial restructuring to mitigate economic shocks and prevent unnecessary business failures.
Comparative analyses further show Nigeria lagging behind jurisdictions such as the United Kingdom and India, where insolvency laws more robustly balance debtor rehabilitation with creditor protection through mechanisms such as administration, company voluntary arrangements, and pre-insolvency restructuring frameworks.
More recent scholarship emphasizes the importance of professionalizing insolvency practice, enhancing court efficiency, and improving cross-border insolvency cooperation. Some studies propose the establishment of specialized institutions to oversee insolvency administration and the adoption of international standards like the UNCITRAL Model Law.
Overall, the literature signals consensus on the urgent need for a comprehensive, modernized insolvency statute in Nigeria—one that consolidates existing laws, promotes transparency, streamlines processes, and fosters economic growth through viable business rescue.
Historical evolution of Insolvency Law in Nigeria
Historical Evolution of Insolvency Law in NigeriaThe evolution of insolvency law in Nigeria closely tracks the nation’s economic development and the gradual sophistication of its business environment. Over time, Nigeria has transitioned from basic insolvency provisions focused on liquidation to a more modern legal framework that emphasizes business rescue, restructuring, and creditor cooperation.
- Early Beginnings
Nigerian insolvency law originated from the Companies Act of 1968, which was heavily influenced by the United Kingdom’s Companies Act of 1948. This initial framework introduced significant reforms by mandating proper corporate accounting, enhancing directors’ accountability, and strengthening shareholder participation. However, the law predominantly emphasized creditor protection through liquidation without much provision for business recovery.
- The Companies and Allied Matters Act (CAMA) 1990
The enactment of CAMA in 1990 was a pivotal event in the development of Nigeria’s insolvency regime. It consolidated various company laws into a single statute and codified procedures for corporate insolvency, mainly focusing on winding up and liquidation. While CAMA 1990 provided necessary clarity and structure, it did not offer mechanisms for corporate rehabilitation or business rescue, limiting its effectiveness in sustaining viable but financially distressed businesses.
- Reforms in the 2000s and the Role of AMCON
Entering the 21st century, Nigeria recognized the need to address the challenges posed by non-performing loans and distressed companies, leading to the establishment of the Asset Management Corporation of Nigeria (AMCON) in 2010. AMCON’s creation marked a practical shift by enabling the government to purchase toxic loans from banks and facilitate the rehabilitation of viable companies. This model helped to stabilize the financial system and introduced a more interventionist approach, though it remained somewhat specialized rather than systemic.
- CAMA 2020: A Groundbreaking Reform
The Companies and Allied Matters Act (CAMA) 2020 brought transformative reforms with wide-ranging implications for insolvency practice in Nigeria. Emphasizing business continuity and creditor collaboration, key features include:
- Business Rescue Mechanisms: CAMA 2020 formally introduces provisions allowing financially distressed companies to undergo restructuring rather than immediate liquidation, thus preserving jobs and enterprise value.
- Administration Procedures: Licensed insolvency practitioners are empowered to take temporary control over troubled companies with the objective of restructuring and revival rather than dissolution. This aligns Nigeria with international insolvency trends.
- Company Voluntary Arrangements (CVAs): CVAs facilitate consensual agreements between companies and their creditors, offering a flexible, less adversarial approach to debt restructuring as an alternative to formal insolvency procedures.These measures not only protect creditors’ interests but also place emphasis on the broader economic benefits of business rescue and rehabilitation.
- Insolvency Regulations 2022
The Insolvency Regulations of 2022 provide critical operational guidelines complementing CAMA 2020. They define the qualifications, registration, and professional conduct of insolvency practitioners, promoting ethical standards and procedural transparency in insolvency proceedings. This professionalization enhances trust in the insolvency system and aims to reduce delays and abuses, contributing to more effective outcomes.
Ongoing Challenges and Future Directions
Despite these notable reforms, Nigeria’s insolvency framework still confronts significant challenges. Institutional capacity, including the availability of skilled insolvency practitioners and judicial proficiency in insolvency matters, requires strengthening. Additionally, implementation gaps and inconsistent enforcement hinder the system’s effectiveness. Ongoing reforms aim to address these issues by incorporating international best practices, enhancing training and certification programs, and improving judicial oversight.
The future of Nigerian insolvency law lies in continuous adaptation and enhancement to foster a resilient business environment that supports corporate turnaround, investor confidence, and economic growth.
Comparative Perspective and Current Realities of Nigeria’s Insolvency Law
Nigeria’s insolvency regime has experienced notable evolution, marked by a strategic shift from a predominantly creditor-friendly framework to a more balanced, debtor-inclusive system. This transformation is exemplified by the enactment of the Companies and Allied Matters Act (CAMA) 2020, which introduces modern insolvency procedures designed to foster business rescue, debt restructuring, and overall economic stability.
Shift from Creditor-Friendliness to a Balanced Approach
Historically, Nigerian insolvency law favored creditors, emphasizing liquidation as the primary resolution mechanism. This approach often limited opportunities for distressed but viable companies to reorganize and continue operations, thus risking job losses and economic downturns.
The recent reforms, culminating in CAMA 2020, reflect a paradigm shift towards a more debtor-friendly approach. The law now emphasizes rehabilitation and restructuring processes, creating avenues for companies to recover from financial distress rather than face immediate dissolution.
Key Innovations in CAMA 2020
- The law introduced several procedures aligned with international best practices:
- Business Rescue Mechanisms: Allow companies in distress to restructure debts and operations, promoting enterprise survival and preserving employment.
- Administration: Empowers licensed insolvency practitioners to take temporary control of a debtor company for the purpose of restructuring, aiming to maximize value for creditors while giving companies a chance to recover.
- Company Voluntary Arrangements (CVAs): Enable debtors and creditors to reach voluntary agreements on debt repayment plans, offering a less adversarial and more flexible restructuring option.
- Netting and Set-Off Provisions: These legal tools facilitate the efficient handling of offsetting mutual debts, reducing the liquidity burden during insolvency proceedings.
Current Realities and Challenges
- Despite significant reforms, Nigeria’s insolvency legal framework faces ongoing challenges:
- Institutional Capacity: There is a need for more skilled insolvency practitioners and judges with expertise in complex restructuring processes.
- Enforcement and Practice: Implementation of the legal provisions remains inconsistent, with enforcement gaps affecting the effectiveness of insolvency processes.
- Public Awareness: Limited awareness among businesses and stakeholders hampers the utilization of rescue procedures.
- Global Standards Compliance: Nigeria continues efforts to harmonize its insolvency laws with international conventions and best practices, such as those promoted by the United Nations Commission on International Trade Law (UNCITRAL).
Looking Forward
Efforts are ongoing to enhance the institutional framework, develop professional training for insolvency practitioners, and streamline procedures to make the insolvency system more about business revival than liquidation alone. These improvements are critical for Nigeria to fully realize the benefits of its modern insolvency laws and foster a resilient business environment conducive to investment and economic growth.
Challenges and Current Realities of Nigeria’s Insolvency Law
Despite progressive reforms, Nigeria’s insolvency framework faces several significant challenges that affect its efficiency and effectiveness in practice:
- Limited Cross-Border Insolvency Framework: Nigeria currently lacks a comprehensive legal framework for the recognition and enforcement of foreign insolvency proceedings. This limitation poses difficulties for foreign creditors seeking to enforce judgments or recover debts across jurisdictions, thereby inhibiting international investment and cross-border economic activities.
- Inadequate Regulation of Insolvency Practitioners: Although efforts have been made to regulate insolvency practitioners, existing regulatory mechanisms remain insufficient. Training programs and entry barriers may be too narrow in scope, limiting the pool of qualified professionals capable of handling modern insolvency and restructuring cases effectively.
- Court System Overload: There is an excessive reliance on the courts for insolvency matters, which often results in procedural delays and congestion. The overloaded judicial system complicates and prolongs the rescue of insolvent companies, undermining the timeliness and success of business restructurings.
Comparative Perspective on Nigeria’s Insolvency Law
When compared to other jurisdictions, Nigeria’s insolvency framework reveals both progress and areas for improvement:
India and the United Kingdom: These countries have established comprehensive and robust insolvency frameworks that emphasize business recovery alongside creditor protection. For example, India’s Insolvency and Bankruptcy Code (IBC) and the UK’s Insolvency Act provide structured procedures for debt restructuring, business rescue, and stakeholder engagement, ensuring that the interests of debtors, creditors, and other stakeholders are balanced effectively.
Global Best Practices: Despite recent reforms such as CAMA 2020, Nigeria’s insolvency laws still lag behind international standards in terms of procedural efficiency, institutional capacity, and cross-border cooperation. This gap underscores the imperative for continuous reforms aimed at adopting best practices to improve insolvency outcomes, promote economic stability, and attract investment
Future Developments in Nigeria’s Insolvency Law
Looking ahead, several key initiatives and reforms are anticipated to further enhance Nigeria’s insolvency framework:
Potential Adoption of the UNCITRAL Model Law on Cross-Border Insolvency: To address current gaps in cross-border insolvency recognition and enforcement, Nigeria may adopt the UNCITRAL Model Law. This step would facilitate greater international cooperation, enable efficient handling of multinational insolvency cases, and improve protections for foreign creditors.
Ongoing Reforms: Continuous efforts are being made to strengthen institutional capacity, enhance education and training for insolvency practitioners and judiciary members, and improve the practical implementation of insolvency laws. These reforms prioritize alignment with international standards and best practices aimed at creating a more effective, transparent, and investor-friendly insolvency regime.
The Nigerian Insolvency Law Framework
Nigeria’s insolvency law framework is principally governed by the Companies and Allied Matters Act (CAMA) 2020 alongside the Insolvency Regulations 2022. Together, these laws establish the legal foundation for managing corporate insolvency in Nigeria.
- Companies and Allied Matters Act (CAMA) 2020: CAMA 2020 sets out key insolvency procedures including receivership, administration, and winding-up. It introduces modern business rescue mechanisms that provide distressed companies avenues for restructuring and survival, thereby shifting the focus from liquidation towards corporate rehabilitation.
- Insolvency Regulations 2022: These regulations complement CAMA by providing detailed procedural guidance on insolvency processes. They clarify the roles and responsibilities of insolvency practitioners, set standards for the fair treatment of creditors, and promote professionalism and transparency in insolvency proceedings.Together, CAMA 2020 and the Insolvency Regulations 2022 form a structured and evolving legal framework aimed at enhancing the efficiency, fairness, and effectiveness of insolvency resolution in Nigeria.
Challenges Facing Nigeria’s Insolvency Law Framework
Despite recent reforms, Nigeria’s insolvency framework continues to face multiple challenges that affect its overall effectiveness and fairness:
- Limited Access to Financing: Many debtors find it difficult to secure financing necessary to restructure and rehabilitate their businesses during insolvency. This lack of access impedes efforts to achieve a balanced outcome that benefits both debtors and creditors.
- Inadequate Insolvency Practitioner Regulation: The current regulatory framework for insolvency practitioners is insufficient, resulting in inconsistent professional standards and potentially unfair or suboptimal insolvency outcomes.
- Court System Overload: Heavy reliance on the court system often causes procedural delays, increased costs, and added complexity, undermining the efficiency of insolvency proceedings and timely business rescue.
- Lack of Transparency and Accountability: Insufficient mechanisms to ensure transparency and accountability within insolvency processes can erode stakeholder confidence and trust in the system.
- Creditor Apathy: Reluctance or lack of active participation by creditors in insolvency proceedings hampers collaborative debt resolution efforts and the achievement of fair settlements.
- Debtor Abuse: Instances of debtors exploiting insolvency procedures to evade debt obligations or improperly transfer assets pose significant obstacles to justice and equity in insolvency cases.
- Inconsistent Application of Laws: Variations in how insolvency laws are interpreted and applied contribute to uncertainty and potentially unfair or unpredictable results across different cases.
- Limited Cross-Border Cooperation: The absence of robust frameworks and cooperation mechanisms between jurisdictions complicates the handling of cross-border insolvency cases, affecting foreign creditor interests and international business operations.
Consequences of Challenges in Nigeria’s Insolvency Law
The existing challenges in Nigeria’s insolvency framework have significant adverse consequences on the broader economy and business environment:
- Reduced Economic Efficiency: Inefficient and delayed insolvency processes hinder the optimal allocation of resources, dampening economic productivity and reducing overall competitiveness.
- Decreased Credit Availability: Perceptions of a high risk of non-payment due to ineffective insolvency enforcement discourage creditors from extending credit, constraining capital flow to businesses.
- Business Failure: Insolvency procedures that overemphasize creditor rights at the expense of business rescue and restructuring contribute to unnecessary liquidation of viable companies, resulting in lost jobs and economic value.
Potential Solutions for Nigeria’s Insolvency Framework
To overcome existing challenges and improve the effectiveness of Nigeria’s insolvency system, the following solutions are recommended:
- Implementing Effective Insolvency Practitioner Regulation: Strengthening the regulation, training, and accreditation of insolvency practitioners will promote consistency, professionalism, and fairness in insolvency proceedings.
- Enhancing Transparency and Accountability: Introducing robust mechanisms for transparency and accountability throughout insolvency processes can build trust and confidence among stakeholders, reducing disputes and fostering collaboration.
- Promoting Creditor Participation: Encouraging active involvement of creditors in insolvency proceedings will help strike a fair balance between protecting creditor rights and facilitating debtor rehabilitation, leading to more equitable outcomes.
- Improving Court Efficiency: Streamlining judicial procedures and reducing backlog through specialized insolvency courts or alternative dispute resolution can diminish delays and costs, improving the speed and effectiveness of insolvency resolutions.
- Fostering Cross-Border Cooperation: Developing comprehensive legal frameworks and cooperation agreements for cross-border insolvency will enhance the handling of multinational insolvency cases, protecting foreign creditor interests and facilitating international trade.
By addressing these areas, Nigeria can strengthen its insolvency framework and achieve a balanced approach that supports both creditor protection and debtor rehabilitation, ultimately contributing to a healthier, more resilient economy.
Reform Recommendations for Nigeria’s Insolvency Framework
To achieve a fair and effective balance between creditor protection and debtor rehabilitation, the following reforms are proposed across legislative, institutional, practical, and policy dimensions:
Legislative Reforms
- Enhance Business Rescue Mechanisms: Strengthen the business rescue provisions within the Companies and Allied Matters Act (CAMA) 2020 to enable more effective restructuring and rehabilitation of financially distressed companies, thereby promoting enterprise continuity.
- Introduce Pre-Insolvency Frameworks: Establish legal frameworks that allow debtors to initiate restructuring negotiations before formal insolvency proceedings, providing early intervention to prevent unnecessary liquidation.
- Improve Creditor Protection: Bolster creditor safeguards by implementing stricter reporting and transparency requirements, as well as enhanced accountability measures for insolvency practitioners.
Institutional Reforms
- Strengthen Insolvency Practitioner Regulation: Create an independent regulatory authority dedicated to overseeing insolvency practitioners, ensuring adherence to high professional standards and ethical conduct.
- Improve Court Efficiency: Streamline judicial procedures related to insolvency by introducing specialized courts or case management systems to expedite resolutions, reduce backlog, and lower associated costs.
- Enhance Cross-Border Cooperation: Develop comprehensive legal frameworks and bilateral agreements to facilitate cooperation in cross-border insolvency cases, safeguarding foreign creditor interests and enhancing international commercial confidence.
Practical Measures
- Promote Financial Literacy: Implement education programs for debtors and creditors focused on financial management, the insolvency process, and restructuring options to foster informed decision-making.
- Encourage Alternative Dispute Resolution (ADR): Promote mediation, arbitration, and other ADR mechanisms as efficient alternatives to litigation for settling insolvency-related disputes.
- Foster Stakeholder Engagement: Encourage meaningful participation of all stakeholders—creditors, debtors, employees, and suppliers—through transparent communication and consultation throughout insolvency proceedings.
Policy Considerations
- Balance Competing Interests: Ensure insolvency laws and practices fairly balance the rights and interests of creditors and debtors, fostering equitable outcomes and minimizing abuse.
- Promote Economic Growth: Design insolvency frameworks that actively support the rescue of viable businesses, protect jobs, and facilitate the recycling of entrepreneurial resources into productive economic activities.
- Protect Stakeholder Rights: Safeguard the interests of all parties affected by insolvency, including workers, customers, and suppliers, to promote fairness and social stability.
Conclusion
ConclusionNigerian insolvency law has made important strides with reforms under CAMA 2020 and the Insolvency Regulations 2022, shifting towards a balanced approach between creditor protection and debtor rehabilitation. While these developments introduce valuable tools for business rescue and restructuring, challenges such as practitioner regulation, court delays, and limited cross-border cooperation remain. Addressing these issues through targeted reforms will strengthen Nigeria’s insolvency regime, promote economic growth, and protect all stakeholders. Achieving this balance is essential for fostering a resilient and thriving business environment in Nigeria.
References
1 .John A. Akpala, ‘The Law and Practice of Corporate Insolvency in Nigeria’ (2019) 1 Nigerian Insolvency Law Journal 1, 5.
2 .Rotimi O. Mokal, ‘Corporate Insolvency Law: Theory and Application’ (2nd ed, 2019) 123.
3 .Iain Ramsay, ‘Personal Insolvency and the Fresh Start’ (2017) 26 International Insolvency Review 5, 10.
4 Patric J. Omar, ‘Insolvency Law and Practice’ (4th ed, 2020).
5.Companies and Allied Matters Act 2020; Insolvency Regulations 2022.
6.CAMA 2020, Parts F and G.
7.Insolvency Regulations 2022, regs 1-5.
8.Ebenezer Adodo, ‘Insolvency Law and Practice in Nigeria’ (2018) 2 Journal of Law and Practice 101,
9.World Bank, ‘Principles for Effective Insolvency and Creditor/Debtor Regimes’ (2015).
10 the UK’s Pre-Pack Administration Rules 2010.
11.the US Bankruptcy Code, Chapter 11.
12 the EU’s Insolvency Regulation (EU) 2015/848.
13.Companies Act 1968 (Nigeria).
14.Companies and Allied Matters Act 1990 (Nigeria).
15.Asset Management Corporation of Nigeria Act 2010 (Nigeria).
16.Companies and Allied Matters Act 2020 (Nigeria).
17 Insolvency Regulations 2022 (Nigeria).
18.World Bank, ‘Doing Business 2020: Nigeria’ (2020).
Ishie-Johnson Emmanuel Esq. writes from Ishie-Johnson and Associates
Phone No. 08033816237, 08023186281
Email: emmajohnsonace@gmail.com
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