*Says “State Law Appeals On Tenancy, Chieftaincy, Divorce And Inheritance Should End At Court Of Appeal”
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Ibrahim Gamdeh Adamu, SAN, has delivered the address on behalf of the 68 newly conferred Senior Advocates of Nigeria at the special session of the Supreme Court marking the commencement of the 2026/2027 legal year.
What follows is his address, as delivered.
“My Lord, may I adopt the protocol already established by my Lord.”
“It is with the greatest pleasure and an extreme sense of awesomeness that I stand before you and this august assembly to address the full Court of the Supreme Court on behalf of the 68 awardees who have just been elevated and conferred with the prestigious rank of Senior Advocate of Nigeria, a recognition of their distinction in law practice.”
“For me, this is a rare honour and privilege that most are desirous of but do not have the opportunity. For all of us, this is a remarkable milestone, having reached the zenith as practitioners of law in diverse fields.”
“This historic day will remain memorable and will be cherished by all of us for the rest of our individual lives. We return the honour, glory, majesty and adoration to the Almighty God who made this possible.“
He paid tribute to the Justices of the Supreme Court drawn from his own generation, naming among them the Chief Justice of Nigeria, Hon. Justice Kudirat M. O. Kekere-Ekun, GCON; Hon. Justice Sidi Dauda Bage, CFR; Hon. Justice [Musa Abba Aji], CFR; Hon. Justice Mohammed Lawal Garba, CFR; and, he said, “lastly but by no means the least,” Hon. Justice [Adamu Jauro], CFR.
“It is with an extreme sense of accomplishment that I state that, of the seven Honourable Justices of this apex court mentioned above, the 1981 set has produced amongst them, consecutively and back to back, three Honourable Justices of the Supreme Court, and the current Chairman of the Body of Benchers.”
He noted that one of the Justices he named had “voluntarily retired before the statutory age to become the Emir of Lafia and the Chairman of the [Nasarawa] State Council of Chiefs,” and is also a university chancellor.
“It is my honest view that the Ahmadu Bello University Law Class of 1980 and the Law School Set of 1981 deserve a place in the Guinness Book of Records.“
He then deferred to the speakers who had gone before him.
“The earlier speakers, led by the Honourable Chief Justice of Nigeria, have already covered the field in their various contributions on different topical issues affecting the legal profession and some national issues. If I had the competence, I would simply say I adopt their [submissions], but how dare me.”
“Permit me to speak on one or two issues, though not in order of significance.”
“Firstly, I am of the humble view that the legal profession is mass producing legal practitioners, which has the concomitant effect of lowering the standard of legal practice and affecting the [nobility] of the legal profession itself.”
“In 1981, when I was called to the bar, only 501 of us were enrolled as legal practitioners.“
“When this is compared with the over 13,000 legal practitioners who have so far been enrolled already in the current year, 2026, between February and July, and in less than six months, it will be quite alarming, especially in a dwindling economy such as ours.”
“The explosion can hardly be justified even when compared with the population growth, and has impacted negatively in the lowering standard of legal practice and the [nobility] of the legal profession itself.”
“It is very common these days to find qualified legal practitioners engaging in many, many jobs at odd places. This ought not to be.“
THE PORT HARCOURT CONFERENCE, AND A CRITICISM HE ACCEPTS IN PART
He referred to a controversy arising from the Nigerian Bar Association’s 66th Annual General Conference in Port Harcourt, where, he said, a person who barely had a secondary school certificate had been given a platform to address “the largest gathering of lawyers in Africa.”
He said the speaker was later reported to have described those who criticised his invitation as a “bunch of clowns,” and to have asked whether law is a noble profession, answering his own question:
“Well, lately law has not been a noble profession. I’m sorry to say, I’m not even sorry to say, that it is one of the poorest professions in this country.”
He said the speaker then asked, sarcastically:
“How many lawyers actually go to court?”
And concluded:
“Every year, they say that they have people graduating from the law school, only to end up selling their [certificates].”
Mr. Adamu’s response was not a rebuttal.
“These remarks hurt me as a member of the legal profession, but there is some truth in what he has said, which calls for introspection. We should therefore all look inwards.“
WHAT HE WANTS THE COUNCIL OF LEGAL EDUCATION TO DO
“It is my humble view that the Council of Legal Education should take an urgent step to checkmate the explosion of the number of legal practitioners we produce.“
“Recently, I was shocked to read that even the National Open University of Nigeria has a backlog of over 5,000 law graduates currently waiting for admission into the Nigerian Law School. I didn’t even know that they had a law faculty.“
He made four recommendations:
“I strongly recommend that there should be stricter control on the accreditation of law faculties in the universities, and the enforcement of discipline in their admission of law students.”
“I further suggest that it is time to consider the study of law as a second degree.”
“And also prescribe the passing of an examination as a prerequisite for admission into the Nigerian Law School, in addition to having a law degree.”
“Furthermore, I suggest that there should be at least two years mandatory internship for newly admitted legal practitioners before they are licensed to set up law firms, in order to standardise and upgrade law practice.”
APPEALS ON MIXED LAW AND FACT: “THE COURT OF APPEAL SHOULD BE ITS LAST BUS STOP”
“May I also seek the indulgence of this Honourable Court to comment on the vexed issue of appeals to this Honourable Court on grounds of mixed law and facts.”
“Prior to the constitutional amendment in the Second Alteration of the Constitution in 2010, which deleted section 233(3) of the 1999 Constitution, leave of this Honourable Court was all that was required for a valid ground of appeal on mixed law and facts.”
“This alteration hatched a controversy on whether or not this Honourable Court still had jurisdiction to entertain such appeals.“
He traced the controversy through four decisions:
- It “set sail in what has now been considered to be an obiter dictum” of Hon. Justice [Rhodes-Vivour], JSC, CFR (retired), in his lead judgment in Shitu v. [Pan] Limited (2018). “It has consequently suffered the fate of an obiter dictum.”
- “Although this issue travelled through other judgments of Hon. Justice Amina Augie, JSC, CFR (retired), in Amadi v. [?] (2021).”
- “The judgment of Hon. Justice Ibrahim [Saulawa], JSC, CFR (retired), in Anyanwu v. Emmanuel (2025).”
- “The [ship] of this controversy seems to have finally [berthed] in the judgment of Hon. Justice Emmanuel A. Agim, JSC, CFR, in Federal Republic of Nigeria v. Gidado (2026).”
“While the judgment in Federal Republic of Nigeria v. Gidado (supra) has seemingly rested the issue of the jurisdiction of this Honourable Court to entertain appeals on mixed law and facts with leave of this Honourable Court, my only concern is whether it is still desirable for this apex court to entertain such appeals.“
“I ask the above question on the desirability of this Court entertaining such appeals on mixed law and facts because I am in complete agreement with the saying that public policy demands that there should be an end to litigation.“
“It is my humble view that where the High Court fails is in the evaluation of evidence, of facts and issues of mixed law and facts. Such errors ought to be decided with finality by the Court of Appeal, which should be its last bus stop on such issues, to borrow the words of my noble Lord Hon. Justice [Rhodes-Vivour] in Shitu (supra).”
“This is desirable because most times such grounds of appeal are on concurrent findings of the two lower courts, which are rarely tampered with by this Honourable Court.“
“In complete obeisance and reverence to the decisions of this Honourable Court, it is my view that if appeals on the decisions of the National Industrial Court can end at the Court of Appeal, the same should be applied to appeals to this Court on grounds of mixed law and facts, especially when such appeals are outside section 233 of the Constitution anyway.”
“I am of the humble view that the golden rule of interpretation of statutes, which states that the express mention of one excludes the other, applies to these circumstances, notwithstanding section 27 of the Supreme Court Act and Order 4 Rule 6 of the Supreme Court Rules 2024.”
“In the alternative, section 27(1) of the Supreme Court Act and Order 4 Rule 6 should be amended to align with the amended provisions of section 233 of the Constitution. I lean completely on the supremacy of the Constitution.“
“The impression should not be given that justice can only be obtained from the Supreme Court.“
“Consequently, I most humbly suggest that section 233(3) be reintroduced as a subsection to that section of the 1999 Constitution, which should expressly bar grounds of appeal that are outside those enumerated in section 233(2) of the Constitution.“
STATE MATTERS, AND A NEW INTERMEDIATE COURT
“May I further suggest that all appeals on matters involving state laws which are within the exclusive jurisdiction of the state High Court, such as customary issues, tenancy, chieftaincy matters, recovery of simple debts, divorce and inheritance, should end at the Court of Appeal.“
“We should also consider the creation of an intermediate court to handle appeals on such matters from the High Court with finality. Certainly there are enough decisions of this Honourable Court that can serve as future guides on these subjects.”
“I am of the humble view that if the grievances of most litigants cannot be resolved with finality by the judgment of the Court of Appeal, then something must be inherently wrong with our judicial system.“
THE CASE THAT TOOK 21 YEARS
“In the recent judgment of this Honourable Court in Petroleum Products Marketing Company Limited v. Master Marines Limited (2025), decided on 12 December 2025, it took 21 years for a decision to be made by this Court on a case of recovery of a simple debt of a million dollars, on whether or not the action was statute barred based on the Lagos State limitation law.”
“This has now been sent back to the High Court of Lagos for trial, and there are no guarantees that the judgment will not be appealed against anyway.“
“The question is: what if the claimant took a loan facility for the transaction? Should he wait for 30 years to obtain justice?“
“The citizen must not lose faith in our judicial system.“
“Our judicial system must be reformed to reflect our true federal structure in order to ensure speedy dispensation of justice. This is to prevent the exploitation of the right of appeal in our judicial system to escape genuine liabilities and to delay justice. As it is said, justice delayed is justice denied.“
“My Lords, in conclusion, may I once more, on behalf of this distinguished set of awardees of the rank of Senior Advocate of Nigeria for the year 2026, most heartily congratulate ourselves, and thank members of our beloved families for their love, support and loyalty in our quest to this attainment.”
“May I also thank my Lords and the distinguished audience for their time and the honour of listening to me.”
“May I also wish my Lords, this Honourable Court and members of the legal profession a happy, healthy and prosperous new [legal] year. Thank you, my Lords.”
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