Beacon of Excellence: Dr Sulaiman Usman SAN
Dr Sulaiman Usman SAN, Life Bencher a man whose journey through life is as illustrious as it is inspiring, a man whose name resonates with distinction across the legal and political landscapes of Nigeria and beyond — Dr Sulaiman Usman, SAN, Life Bencher, and Notary Public.
Born on the 27th of September, 1973, Sulaiman’s roots stretch deep into the history of the Sokoto Caliphate. From an early age, it was clear that this young man was destined for greatness. His academic brilliance shone brightly, and his hunger for knowledge knew no bounds. He pursued both Islamic and secular education with remarkable success, ultimately embarking on an educational odyssey that took him across continents.
His credentials are nothing short of impressive. Starting with a Diploma in Law and a Bachelor of Laws degree, Sulaiman went on to earn not one but two Master of Laws degrees, specializing in International Business Law and International Dispute Resolution, from prestigious institutions such as the University of Liverpool and Queen Mary University of London. His academic endeavours did not stop there. He achieved a PhD in International Business Law and acquired advanced certifications in Artificial Intelligence and Machine Learning from the University of Texas at Austin, showing his foresight in adapting to the evolving global landscape.
But Sulaiman is not just a scholar. His foray into the political arena began early. He has served in a variety of roles—councillor, supervisory councillorr, Speaker of Kware Local Government Council, and Special Adviser to the Government of Sokoto State on Legal Matters. In 2005, he was a delegate to the National Political and Constitutional Conference, contributing his wisdom to the country’s political discourse. His most recent role as Attorney General and Commissioner for Justice in Sokoto State reflects the trust and respect he commands in both legal and political circles.
His legal practice, anchored by the Gamzaki Law Chambers, which he co-founded, has soared to incredible heights. With his expertise, knowledge, and extraordinary communication skills, Sulaiman’s career blossomed, leading to his recognition as a Senior Advocate of Nigeria (SAN) and his appointment as a Distinguished Life Bencher — prestigious honours that reflect his towering influence in the legal profession.
Yet, his contribution extends beyond the courtroom. Sulaiman is an avid author and researcher, having written several books and numerous academic papers. He is also deeply involved in various public and professional organizations, reflecting his commitment to societal advancement. His passion for progress is matched only by his impeccable integrity and leadership.
Dr. Sulaiman Usman is not just an accomplished lawyer and public servant; he is a man of many talents. He is fluent in multiple languages, skilled in relationship management, and possesses an extraordinary ability to solve complex problems. His hobbies — reading, writing, and meditation — are further testament to his introspective and thoughtful nature.
In every sense, Sulaiman is a beacon of progressive values, a man of principle, and a leader for our times. His story is one of unwavering dedication, tireless pursuit of knowledge, and an unshakable commitment to justice, integrity, and the betterment of society. He is, without a doubt, a symbol of excellence in Nigeria and a role model for future generations.
CROSSING THE RIVER BY FEELING THE STONE: STRATEGIES FOR SURVIVING THE IMPACT OF NIGERIAN ECONOMIC POLICIES IN 2024 AND BEYOND.
Dr. Sulaiman Usman SAN, FICMC, FIMC, CMC, FNARC, FCIML, FAIET.
(D.L, Ll. B (Hons), PgC (Texas), LL.M (Liverpool), Ll.M (QMUL), PhD, (PNH), B.L
Notary Public and Life Bencher
Founding Partner, Gamzaki Law Chambers
Presented at a “WEBINAR” ZOOM ONLINE on 26TH APRIL 2024 with the theme: Nigeria Economic Crises; Strategies for Survival in 2024 and Beyond by the University of Liverpool Alumni in Nigeria (Abuja- Northern Region)
ABSTRACT:
The Nigerian economy is facing volatility and uncertainty due to evolving policies, which has led to hyperinflation, cost of living crises, and uncertainties. This paper explores strategies for navigating and surviving the impact of Nigerian economic policies in 2024 and beyond. Drawing inspiration from the Chinese proverb “Crossing the river by feeling the stone” thatrequires gradual but pragmatic reform marked by incremental and piecemeal changes.[1]
This paper aims to provide practical advice and insights on how individuals and businesses can adapt to the ever-changing economic landscape in Nigeria. It analyses the challenges posed by economic policies and offers actionable recommendations that individuals and businesses must adopt and resilient strategies to develop to survive and thrive. The paper also discusses the importance of diversifying income streams, staying informed about economic policies, building financial buffers, seeking professional advice, exploring international opportunities.[2], and advocating for change. By employing these strategies, individuals and businesses can better position themselves to withstand the challenges and capitalise on the opportunities presented by Nigerian economic policies.
INTRODUCTION
Navigating the economic landscape can feel like crossing a river with shifting currents. In Nigeria, where economic policies profoundly impact, resilience and strategic planning are crucial. The survival strategies draw parallels to the metaphorical act of feeling stones while crossing a river—navigating carefully, adapting to changes, and ultimately, reaching the other side despite the challenges posed by economic policies in 2024 and beyond.
The current Nigerian economic crisis was the result of the government’s handling of fiscal and monetary policies, especially the botched redesign of the Nigeria currency, the abrupt removal of subsidies, the floating and devaluation of the Naira, as well as the insatiable appetite for foreign currencies among Nigerian elites, the country’s increasing debt profile, the impact of the borrowed funds on economic development, the Government’s unfulfilled promises of job creation, and the hypocrisy and corruption within the system[3].
The economic crises have significantly impacted the population, increasing poverty, inflation, high living costs, and hardship for many people. The socio-economic outlook remains fragile due to policy impacts.[4]. Addressing the root causes of the economic crises will require broader systemic changes and policy interventions; combining fiscal and monetary policies, trade policies, and a stable exchange rate can help governments address economic crises and promote economic stability and growth. Some potential challenges faced by individuals in the Nigerian economic crisis may include:
1. Unemployment and Underemployment: Many individuals are struggling to find stable employment or may be forced to accept jobs that do not fully utilize their skills and education.
2. Inflation and Cost of Living: Rising prices of food, goods, and services have eroded purchasing power, making it difficult for individuals to afford necessities.
3. Limited Access to Credit: Financial institutions have tightened lending criteria, making it harder for individuals to access credit for personal or business needs.
4. Currency Devaluation: Fluctuations in the Nigerian currency’s value and the Naira’s floating can impact the cost of imported goods and affect an individual’s ability to conduct international transactions.
5. Reduced Government Services: Cutbacks in public and social welfare programs have left individuals with fewer support options during challenging times.
6. Business Failures: Small business owners may face increased challenges in sustaining their enterprises, leading to closures and job losses.
7. Mental Health Strain: Economic uncertainty and financial stress can take a toll on individuals’ mental well-being, leading to anxiety, depression, and other mental health issues.
ECONOMIC POLICY MEASURES
During an economic crisis, governments often use a combination of fiscal and monetary policies to stabilize the economy and mitigate business cycle fluctuations. Fiscal policy involves the government’s taxation and spending measures to influence aggregate demand and stimulate economic activity. This can include increased government spending or tax cuts to boost consumption and investment. On the other hand, monetary policy is managed by the central bank. It involves the manipulation of interest rates and the money supply to influence borrowing costs, inflation, and overall economic activity. Lowering interest rates or implementing quantitative easing can encourage borrowing and increase investment and consumption.
In addition to fiscal and monetary policies, governments often implement trade policies to improve trade relations and build safeguards against external shocks. Trade policies can include tariffs, quotas, subsidies, and trade agreements. These policies aim to protect domestic industries, promote exports, attract foreign direct investment, and ensure a stable and balanced trade relationship with other countries.
Stabilising the exchange rate is crucial for maintaining stability in international trade and managing external shocks. A stable exchange rate helps to provide certainty for businesses engaged in international trade, reduces currency volatility, and promotes confidence in the economy. Governments may use foreign exchange interventions or pegging the currency to stabilize the exchange rate.
John Maynard Keynes[5]One of the most influential modern economists, often regarded as the founder of modern macroeconomics, declared, “The political problem of mankind is to combine three things: Economic Efficiency, Social Justice, and Individual Liberty.” [6] I would say that today, we would say Economic Prosperity, Social Justice, and Environmental Sustainability.
Keynes’ statement from 1926 reflects the foundational principles that many still consider crucial in societal development. Economic efficiency ensures that resources are utilized optimally, social justice focuses on fairness and equality, and individual liberty emphasizes personal freedoms.[7]. These ideas remain relevant today, albeit with some updates.
Today, the focus has expanded to include economic prosperity, which encompasses both efficiency and overall well-being and wealth creation for individuals and communities. Social justice has evolved to emphasise equality, inclusivity, and diversity, ensuring everyone has equal opportunities and representation. Environmental sustainability is a critical addition, highlighting the necessity of preserving our planet and its resources for future generations.
The Nigerian government has implemented various measures to address recent economic challenges. Some of the responses include[8]:
1. Economic Reforms: The government has initiated economic reforms to diversify the economy away from its heavy reliance on oil, focusing on sectors such as agriculture, manufacturing, and technology.
2. Social Intervention Programs: The government has introduced social intervention programs targeting vulnerable populations, including the National Social Investment Program (NSIP), which includes initiatives such as the N-Power youth empowerment program, the Conditional Cash Transfer program, the National Home-Grown School Feeding program, and the Government Enterprise and Empowerment Program (GEEP).
3. Infrastructure Development: Efforts have been made to invest in infrastructure development, including road construction, power generation, and transportation, to stimulate economic growth and improve living standards.
4. Monetary Policy Measures: The Central Bank of Nigeria has implemented monetary policy measures to stabilize the economy, manage inflation, and support the stability of the Nigerian naira.
5. Investment in Agriculture: The government has prioritized investment in agriculture to enhance food security, create employment opportunities, and boost rural development.
6. Public-Private Partnerships: Encouraging partnerships between the public and private sectors to drive investment, innovation, and job creation.
7. Fiscal Policy Adjustments: The government has adjusted fiscal policies, including budgetary allocations and tax reforms, to address economic imbalances and promote sustainable growth.
It’s important to note that these measures’ effectiveness and impact on the overall economy and poverty alleviation will require ongoing evaluation and monitoring.
STRATEGIES FOR PEOPLE SURVIVAL
Navigating the impact of Nigerian economic policies can be challenging, but some strategies can help individuals and businesses survive and thrive in the current economic climate. Here are some potential strategies for managing the impact of economic policies in Nigeria[9]:
1. Diversify revenue source: Given the Nigerian economy’s volatility, diversifying income sources can be beneficial to avoid cash flow vulnerability. This could involve exploring new business opportunities, investing in different sectors, or seeking employment in more stable industries[10].
2. Stay informed: Keep abreast of Nigeria’s latest economic policies and developments. Understanding the implications of new policies can help individuals and businesses make informed decisions and adapt their strategies accordingly.
3. Build a financial buffer: Given the uncertainty of economic policies, it’s essential to build up a financial cushion to weather any potential downturns. This could involve setting aside savings, reducing unnecessary expenses, and managing debt carefully.
4. Seek professional advice: Consulting with financial advisors, economists, or legal experts can provide valuable insights into navigating the impact of economic policies. These professionals can offer tailored advice based on individual circumstances and goals.
5. Explore international opportunities: In light of the challenges posed by Nigerian economic policies, exploring opportunities in international markets could provide a buffer against domestic economic volatility. This could involve exporting goods and services, seeking international investment, or relocating business operations.
6. Advocate for change: Engaging with policymakers and industry associations to advocate for more favourable economic policies can help shape the business environment in Nigeria. Individuals and businesses can create a more conducive economic environment by participating in advocacy efforts[11].
ECONOMIC VOLATILITY
Several key factors contribute to the volatility of the Nigerian economy, including:
1. Dependence on oil: Nigeria’s economy relies heavily on oil exports, making it vulnerable to fluctuations in global oil prices. Any disruptions in the global oil market can significantly impact the country’s revenue and foreign exchange earnings.
2. Weak diversification: The Nigerian economy has historically been under-diversified, with overreliance on the oil sector. Limited diversification into other industries and sectors leaves the economy susceptible to external shocks and market fluctuations.
3. Political instability: Nigeria’s political uncertainty and governance challenges can create an unpredictable business environment, deterring investment and economic growth. Inconsistent policy implementation and frequent leadership changes can contribute to economic volatility.
4. Fiscal and monetary policy challenges: Ineffective fiscal management, high government debt, and challenges in monetary policy implementation can contribute to economic instability. Inadequate fiscal discipline and monetary policy coordination can lead to inflation, currency devaluation, and reduced investor confidence.
5. Infrastructure deficiencies: Inadequate infrastructure, including power supply, transportation, and telecommunications, hinders productivity and economic growth. Infrastructure deficiencies can also increase production costs and limit the competitiveness of Nigerian businesses.
6. Security concerns: Persistent security challenges, including insurgency, terrorism, and communal conflicts, can disrupt economic activities, deter investment, and undermine business confidence.
7. External vulnerabilities: Nigeria’s economy is vulnerable to external factors such as global economic conditions, trade dynamics, and foreign exchange rate fluctuations. Dependence on imports for consumer goods and capital equipment exposes the economy to external shocks.
SMALL AND MEDIUM ENTERPRISES
Small and medium-sized enterprises (SMEs) in Nigeria face several challenges amidst economic volatility, including:
1. Access to finance: SMEs often struggle to access affordable financing, as banks may perceive them as high-risk borrowers. Economic volatility can exacerbate this challenge, as lenders may become more cautious in extending credit during uncertain economic conditions.
2. Infrastructure deficiencies: Inadequate infrastructure, including unreliable power supply, poor transportation networks, and limited access to technology, can hinder the productivity and competitiveness of SMEs. Economic volatility may further strain infrastructure and exacerbate operational challenges for SMEs.
3. Regulatory and policy uncertainty: Rapid changes in economic policies, tax regulations, and business laws can create uncertainty for SMEs, making it difficult to plan and invest long-term. Economic volatility can lead to frequent policy changes, further complicating the business environment for SMEs.
4. Limited market access: SMEs may struggle to access domestic and international markets due to limited resources, inefficient distribution networks, and trade barriers. Economic volatility can disrupt market dynamics and consumer behavior, posing additional challenges for SMEs seeking to expand their customer base.
5. Skills and talent development: SMEs often face challenges in recruiting and retaining skilled employees and providing ongoing training and development opportunities. Economic volatility can impact workforce stability and limit SMEs’ ability to invest in human capital.
6. Currency fluctuations and inflation: Economic volatility can lead to currency fluctuations and inflation, affecting the cost of imported inputs, raw materials, and equipment for SMEs. This can squeeze profit margins and increase operational costs for SMEs.
7. Limited access to technology and innovation: SMEs may struggle to adopt and integrate new technologies and innovative practices due to limited resources and expertise. Economic volatility can further constrain SMEs’ ability to invest in technology and innovation.
CONCLUSION
Ultimately, surviving the impact of Nigerian economic policies requires a combination of adaptability, resilience, and strategic decision-making. By staying informed, diversifying income streams, and seeking professional advice, individuals and businesses can better position themselves to navigate the challenges and opportunities presented by economic policies in Nigeria[12]. Addressing these challenges requires a comprehensive approach that includes targeted policies to improve access to finance, infrastructure development, regulatory stability, market access facilitation, skills development, and support for technology adoption. By addressing these challenges, SMEs can be better positioned to withstand economic volatility and contribute to sustainable economic growth in Nigeria[13].
Therefore, balancing economic prosperity, social justice, and environmental sustainability becomes the new political challenge in this context. It requires policies and practices that promote economic growth without compromising fairness, inclusivity, or the health of our planet. Finally, we must stress the importance of self-sufficiency and pride in Nigeria’s local currency, products, and services. Nigeria should be proud of its local currency and products and embark on a crackdown on the hoarding and displaying of foreign currencies.
[1] Li, H.. ‘The Chinese Model of Development and Its Implications’ (2015) World Journal of Social Science Research, 2(2), 128-138. Available at: https://scholarworks.merrimack.edu/pol_facpub/18 accessed: 20th April 2024.
[2] Zainab Usman, Economic Diversification In Nigeria; The Politics of Building a Post-Oil Economy, (Bloomsbury Publishing, London, 2022) 4.
[3] Samuel Alabi, ‘Nigeria: botched economic reforms plunged the country into crisis’, The Conversation (2024) Available at: < https://theconversation.com/nigeria-botched-economic-reforms-plunge-the-country-into-crisis-224545 > Accessed:
[4] ‘ Tayo Adeyaju, Policies and Reforms for Economic Development in Nigeria and Africa’, Economic and Policy Review Journal H1′ 2022, Volume 20: Number 1
[5] John Maynard Keynes’s theories and ideas have significantly impacted policy and thinking, particularly during economic uncertainty and crisis. Keynesian economics emphasizes the role of government intervention in managing the economy, has shaped policies worldwide, and continues to be studied and applied by economists today.
[6] John Maynard Keynes, ‘Liberalism and Labour’ The Nation and Athenæum, (1926) Available at: <https://www.economicsnetwork.ac.uk/archive/keynes_persuasion/Liberalism_and_Labour.htm> Accessed: 20th April, 2024.
[7] Ben Nwabueze, Military Rule and Constitutionalism in Nigeria, Spectrum Law Publishing, 1992.
[8] Ngozi Okonjo Iweala and Philip Osafo Kwaako, ‘ Nigeria Economic Reforms: Progress and Challenges’ Available at https://www.brookings.edu/wp-content/uploads/2016/06/20070323okonjo_iweala.pdf Accessed: 20th April 2024.
[9] Gaston Moonem, ‘Strategies in a Changing World’, EJA, Available at: <https://www.eca.europa.eu/lists/ecadocuments/journal21_01/journal21_01.pdf >accessed: 18th April. 2024.
[10] Andy Hemming, ‘5 Strategies to diversify your income streams and start creatin financial freedom’ Linkedin (2023)
[11] Adeyemi, O. A. (2019). Navigating the challenges of Nigerian economic policies: Insights from successful entrepreneurs. Journal of Entrepreneurship in Emerging Economies, 11(2), 234-248.
[12] Zainab Usman, Economic Diversification In Nigeria; The Politics of Building a Post-Oil Economy, (Bloomsbury Publishing, London, 2022) 5.
[13] Ogunleye, G. A. (2020). The impact of Nigerian economic policies on businesses: A case study of small and medium enterprises. International Journal of Business and Management, 15(4), 112-125.
ETHICS, ETIQUETTE, AND NAVIGATING ETHICAL PRECEPTS IN LEGAL PRACTICE IN NIGERIA
BEING THE TEXT OF A PAPER PRESENTED AT ONE DAY SEMINAR OF THE LITIGATION COMMITTEE OF THE NIGERIAN BAR ASSOCIATION SECTION ON LEGAL PRACTICE ON THE THEME “LEGAL PRACTICE IN NIGERIA – REINFORCING ETHICAL BEHAVIOUR”. HELD ON FRIDAY 22ND MARCH, 2024 AT LAGOS COURT OF ARBITRATION, LEKKI, LAGOS STATE.
ETHICS, ETIQUETTE, AND NAVIGATING ETHICAL PRECEPTS IN LEGAL PRACTICE IN NIGERIA
BY
DR. SULAIMAN USMAN SAN, FICMC, FIMC, CMC, FNARC, FCIML, FAIET.
(D.L, LL. B (HONS), PgC (TEXAS), LL.M (LIVERPOOL), LL.M (QMUL), PhD, (PNH), B.L
NOTARY PUBLIC AND LIFE BENCHER
FOUNDING PARTNER, GAMZAKI LAW CHAMBERS
ABSTRACT:
Ethical considerations are fundamental to the practice of law, serving as guiding principles that shape the conduct of legal professionals and maintain the integrity of the legal profession. The legal profession plays a crucial role in upholding justice and promoting societal well-being, and adherence to ethical guidelines is essential for maintaining the integrity of the profession. However, Nigeria faces unique challenges in ensuring that legal practitioners uphold ethical standards, given the diverse cultural, social, and political landscape of the country. This paper explores the complex intersection of ethics, etiquette, and navigating ethical precepts in legal practice in Nigeria. The paper delves into the intricate landscape of ethics and etiquette in legal practice within the context of Nigeria. It discusses the ethical precepts that govern the conduct of lawyers, examining their role in upholding the rule of law, promoting justice, and fostering public trust in the legal profession[2]. By shedding light on the importance of ethics and etiquette in legal practice in Nigeria, this paper contributes to the ongoing dialogue on professional responsibility and accountability in the Nigerian legal system and the need for legal professionals to uphold ethical standards, navigate complex ethical issues with integrity and professionalism, and contribute to a legal system that fosters justice, fairness, and public trust.
INTRODUCTION
Ethics are foundational to the legal profession because it is a vocation that is essentially for rendering service[3] “when labour sweats for duty, not for need”[4]. They encompass principles of integrity, honesty, fairness, and professionalism that guide the behaviour and conduct of lawyers. Without ethics, the practice of law loses its moral compass and credibility. Ethical conduct is not just a moral imperative but also a professional obligation for lawyers. Upholding ethical standards is essential for maintaining the integrity of the legal profession, ensuring fair and just outcomes in legal proceedings, and upholding the rights and interests of clients. Ethical lapses can lead to legal malpractice, damage to client trust, conflicts of interest, and erosion of public confidence in the legal system. Such conduct undermines the lawyer’s ability to serve clients’ interests and uphold the rule of law.
The road map to reinforcing ethical behaviour in legal practice in Nigeria involves several key steps. Firstly, promoting a culture of integrity and ethical conduct within the legal profession through education and training programs on ethical standards, creating mechanisms for reporting unethical behaviour. Secondly, establishing clear ethical guidelines and codes of conduct. Thirdly, implementing mechanisms for monitoring and enforcing ethical standards, such as ethics committees or regulatory bodies. Finally, creating a supportive environment where lawyers feel comfortable and encouraged to make ethical decisions and report unethical behaviour. By implementing these measures, the legal profession in Nigeria can uphold high ethical standards and promote trust and confidence in the legal system.
DEFINITION OF TERMS
Let us explore the definitions of important concepts of ethics, etiquette, and ethical precepts in the context of legal practice in Nigeria to lay the foundation for proper appreciation of this paper. The term “Ethics” refers to the moral principles and values that guide an individual’s behaviour and decision-making. In the context of legal practice, ethics govern the professional conduct of lawyers and the ethical obligations they owe to their clients, themselves, the court, and the public. “Etiquette” encompasses the customary code of polite behaviour in society or a particular group. In the legal profession, etiquette includes the proper conduct and decorum expected of a legal practitioner. In legal practice, ethics guide lawyers in making decisions and conducting themselves professionally and responsibly.
“Ethical precepts” are fundamental principles or rules that serve as a guide for ethical behaviour and decision-making in a specific context, such as legal practice. These precepts often form the basis of professional codes of conduct and ethical guidelines for lawyers. “Legal practice in Nigeria” refers to the activities and responsibilities of lawyers in Nigeria, including representing clients, providing legal advice, and advocating for justice within the framework of Nigerian laws and regulations.
EVOLUTIONARY ROOTS OF ETHICAL BEHAVIOUR
The origin of ethical behaviour is a complex interplay of evolutionary, cultural, religious, philosophical, educational, legal, and personal factors. These factors collectively contribute to shaping individuals’ understanding of ethics and their ability to engage in ethical behaviour in diverse contexts. At an individual level, ethical behaviour is influenced by personal values, beliefs, and conscience. People make ethical decisions based on their sense of right and wrong, empathy, compassion, and consideration for the well-being of others. Personal integrity and ethical awareness guide behaviour in various personal, social, and professional contexts.
Ethical behaviour is a complex and multifaceted concept that has been explored by philosophers, religious scholars, and social scientists throughout history. While different perspectives exist regarding the origins of ethics, several key factors contribute to shaping ethical behaviour:
Some scholars argue that ethical behaviour has evolutionary roots, stemming from the need for social cohesion and cooperation among early human societies. Evolutionary psychology suggests that certain ethical principles, such as fairness, reciprocity, and altruism, have adaptive value and contribute to survival and group success.
According to other scholars, Ethics are often influenced by cultural norms, values, and religious teachings. Different cultures and religions have their ethical frameworks and moral codes that guide behaviour and shape ethical beliefs. For example, concepts like the Golden Rule (“treat others as you would like to be treated”) are found in various religious and philosophical traditions.
Philosophers throughout history, such as Aristotle, Immanuel Kant, and John Stuart Mill, have contributed to the development of ethical theories and principles. These philosophical inquiries delve into questions of morality, justice, rights, and the nature of good and evil, providing frameworks for understanding and evaluating ethical behaviour.
Ethical behaviour is also influenced by socialization processes and education. Individuals learn ethical norms, values, and moral reasoning skills through family, schools, communities, and other social institutions. Education plays a crucial role in shaping ethical awareness, critical thinking, and decision-making regarding ethical dilemmas.
In professional contexts, ethical behaviour is often governed by legal regulations, professional codes of conduct, and industry standards. These standards outline expectations for ethical conduct, professional integrity, confidentiality, conflicts of interest, and accountability within specific professions and organizations.
THE ROLE OF ETHICS AND ETIQUETTE IN LEGAL PRACTICE
Legal practice in Nigeria is governed by a combination of statutes[5], case law[6], and professional regulations[7]. The Nigerian legal system is a blend of English Common law, Islamic Law, and Customary law. Lawyers typically undergo formal education, including obtaining a law degree, and must be admitted to the Nigerian Bar after completing the Bar Part II program. The legal profession is regulated by the Body of Benchers, the General Council of the Bar, and the Nigerian Bar Association. Therefore, lawyers are expected to adhere to ethical standards outlined in the Rules of Professional Conduct. Legal proceedings occur in various courts, including the Supreme Court, Court of Appeal, and High Courts, with each having its jurisdiction and hierarchy.
The Cardinal principle of ethics, etiquette, and ethical precept in legal practice in Nigeria is encapsulated in Rule 1 of the Rules of Professional Conduct for Legal Practitioners (RPC) which provides in clear and categorical terms as follows;
“A Lawyer shall uphold and observe the rule of law, promote and foster the cause of justice, maintain a high standard of professional conduct, and shall not engage in any conduct which is unbecoming of a legal practitioner[8]“
This foremost rule received judicial approval in the case of Gebi vs Dahiru[9] where the rule was crystallised as follows,
“A Lawyer as an officer in the hallowed chamber of Justice owes a duty to uphold and observe the rule of law, promote and foster the course of justice, and maintain a high standard of professional conduct and etiquette, thus he shall not by any means engage in conduct which is unbecoming of a Legal Practitioner”.
This rule of professional conduct encapsulates the core ethical obligations and responsibilities that lawyers are expected to uphold in their practice. Let’s break down each part of the statement:
- UPHOLD AND OBSERVE THE RULE OF LAW:
Lawyers must respect and uphold the Nigerian Constitution and the laws of the land. They should have a thorough understanding of the legal framework and ensure that their actions, advice, and representation align with the principles and provisions outlined in the Constitution and other laws. Lawyers are officers of the court and are expected to abide by the law themselves while also advocating for their clients within the bounds of the law.[10] Lawyers in Nigeria are expected to comply with all relevant laws, regulations, and professional rules governing their practice. This includes adherence to the Legal Practitioners Act and the Rules of Professional Conduct for Legal Practitioners. This includes respecting and upholding the legal system, following court procedures, and complying with ethical rules and regulations. Upholding the rule of law also requires always maintaining professional integrity. This includes honesty, integrity, and ethical conduct in dealings with clients, colleagues, and the legal system[11].
Lawyers are expected to uphold and promote human rights principles in their practice. This includes advocating for justice, equality, and the protection of fundamental rights and freedoms for all individuals.
- PROMOTE AND FOSTER THE CAUSE OF JUSTICE:
Lawyers play a crucial role in promoting justice and ensuring that all individuals have access to a fair and impartial legal system. This includes advocating for the rights of their clients, working towards a just outcome in legal matters, and upholding the principles of fairness and equality[12]. Lawyers have an ethical obligation to work towards ensuring access to justice for all individuals, regardless of their socio-economic status or background. They should provide legal services to those in need, including those who cannot afford legal representation.
Lawyers have the sacred duty to observe the “cab-rank rule” by accepting cases for which they were duly instructed, and which are within the area of their proficiency in the profession. Lawyers are like taxicab drivers queuing in a taxi rank. A taxicab driver cannot refuse to take a passenger when it is his turn, solely by way of discrimination. A Lawyer should be socially responsible by accepting a brief pro bono, that is without charging any professional fees, and should also engage in mentoring other lawyers, especially the new wig, and engage in community service.
Lawyers must respect the independence and integrity of the judiciary. This involves refraining from actions that could undermine the administration of justice or erode public trust in the legal system. Lawyers must act fairly and impartially in representing their client’s interests. This includes presenting accurate information to the court, avoiding misleading statements, and refraining from engaging in unethical tactics or behaviour.
- MAINTAIN A HIGH STANDARD OF PROFESSIONAL CONDUCT:
Lawyers are expected to conduct themselves with integrity, honesty, and professionalism in all aspects of their practice. This includes providing competent legal representation, maintaining confidentiality, avoiding conflicts of interest, and treating all parties with respect and dignity.
Lawyers must maintain the highest level of integrity and professional conduct. They should avoid any behaviour that could bring the legal profession into disrepute, such as engaging in dishonesty, bribery, or other unethical conduct. Lawyers should strive to be role models in their professional behaviour and adhere to the highest ethical standards. Lawyers must uphold the principles of honesty and candor in their dealings with the court, opposing counsel, clients, and other parties involved in legal proceedings. They should never misrepresent facts, suppress evidence, or engage in any form of dishonesty that could undermine the integrity of the legal process.
- SHALL NOT ENGAGE IN ANY CONDUCT THAT IS UNBECOMING OF A LEGAL PRACTITIONER:
This part of the statement emphasizes that lawyers are held to a high standard of ethical conduct and are expected to refrain from engaging in any behaviour that could bring disrepute to the legal profession. This includes avoiding dishonesty, deceit, or any actions that could undermine the trust and confidence of clients, colleagues, and the public. Lawyers have an ethical duty to refrain from engaging in frivolous or malicious legal proceedings. They should only initiate or defend legal actions that have a legitimate basis and serve the interests of justice.
Lawyers should not misuse the legal system to harass or oppress others, and they should always strive to resolve disputes efficiently and peacefully whenever possible. Lawyers must maintain their independence and act with fairness in their representation of clients. They should not allow personal interests or outside influences to compromise their professional judgment. Lawyers should ensure that their advice and advocacy are objective, unbiased, and aimed at achieving a fair and just outcome[13]. Lawyers must avoid conflicts of interest that could compromise their ability to represent their clients effectively or undermine the rule of law. This includes disclosing any potential conflicts and taking appropriate steps to address them.
ETHICAL PRECEPTS IN LEGAL PRACTICE
To be an ethically compliant lawyer in Nigeria involves following the ethical precepts and codes of conduct set out by regulatory bodies such as the Body of Benchers, General Council of the Bar, and, the Nigerian Bar Association (NBA). This includes maintaining confidentiality, avoiding conflicts of interest, upholding the rule of law, and providing competent and zealous representation for clients. Additionally, lawyers should continue to educate themselves on legal ethics and stay informed about changes in laws and regulations that may affect their practice. By adhering to these principles and staying current on ethical standards, lawyers can ensure they are acting ethically and responsibly in their legal practice in Nigeria
It should be noted that all Legal Practitioners practicing in Nigeria are bound by the Rules of Professional Conduct (RPC)[14], which we have identified to be a codification of the ethics of the legal profession. To further underscore this point, it is important to refer to Rule 74 (1) of the RPC which provides as follows:
A lawyer who acts in contravention of Chapter 1 or any of the rules of these Rules or fails to perform any of the duties imposed by that Chapter, commits professional misconduct and is liable to punishment as provided in the Legal Practitioners Act.
In the case of Iteaogu V. LPDC, it was held thus
.…any conduct that constitutes an infraction of acceptable standard or behaviour or ethics of the legal profession, of any conduct which connotes conduct despicable and morally reprehensible as to bring the legal professional into disrepute if condoned or unpunished, will amount to misconduct.
In the case of Etim V. Obot[15] the Court of Appeal depreciated counsel’s use of the words ‘strange’ and ‘mysterious’ in describing the judgment of the lower court as not only inappropriate but also inconsistent with the high ethical standard of the profession.
Moreover, the duty of a legal practitioner under the RPC does not end at complying with the Rules but also extends to reporting the breach by other legal practitioners. Rule 74 (3) of RPC, which provides as follows, is apt on this point:
“It is the duty of every lawyer to report any breach of any of these rules that comes to his knowledge to the appropriate authorities for necessary disciplinary action.”
The recent Directions issued by the Legal Practitioners Disciplinary Committee (LPDC) indicate an upsurge in the number of violations. These recent Directions have shown that legal practitioners now indulge in questionable professional conduct ranging from conversion of clients’ funds, to lack dedication in handling client’s briefs, conflict of interest, and many others. These were acts which were hitherto considered a grave sacrilege, but which now seem to have become the norm for those who perpetrate them.
The rise in professional misconduct and indiscipline in the legal profession has resulted in an increasing number of petitions written against lawyers regularly. This is very disheartening and puts all of us at risk. We must all rise to the occasion before it is too late. All hands must be on deck to ensure that the trust and high regard that other members of the public have for us as legal practitioners are not completely eroded.
As earlier stated, the Rules of Professional Conduct for legal practitioners and society hold a legal practitioner to an almost stratospheric moral standard. Legal Practitioners always occupy a notable status in society by their membership in the legal profession, whether they are acting in their capacity as legal practitioners or not. The LPDC in NBA V. Lawal Shaq[16], agreed with this assertion when it stated thus”
“A legal practitioner whether acting by office or not is in the eyes of the society an Honourable man with whom a by-stander can leave his valuables and proceed on a journey and return to meet his property intact. Such was how a legal practitioner was highly viewed in those days. Thus, a lawyer possesses the unenviable duty to be civil, honest, and decorous at all times.”
INFAMOUS CONDUCT IN A PROFESSIONAL RESPECT
Lawyers who engage in unethical behaviour may face disciplinary actions, sanctions, or loss of licensure. Beyond the legal consequences, unethical conduct tarnishes the reputation of the individual lawyer, their law firm, and the legal profession. Upholding ethical standards is not just a professional duty but also a prerequisite for being a competent and respected legal practitioner.
Under Rule 1 of the Rules of Professional Conduct for Legal Practitioners, Legal Practitioners have an onerous duty to observe, preserve, and uphold the rule of professional conduct. They must not engage in any conduct that is unbecoming of a Legal Practitioner. In the case of GEBI VS DAHIRU[17], Saulawa JCA stated as follows;
“A Lawyer as an officer in the hallowed chamber of Justice owes a duty to uphold and observe the rule of law, promote and foster the course of justice, and maintain a high standard of professional conduct and etiquette, thus he shall not by any means engage in conduct which is unbecoming of a Legal Practitioner”.
Indeed, authorities are legion that infamous conduct is conduct that brings not only the Legal Practitioner but the entire profession to public ridicule and opprobrium. It is a conduct that belittles, disparages, or reduces the reputation of the profession in the estimation of right-thinking men in society, including members of the profession. It is scandalous and disgraceful conduct unbecoming of a person who belongs to the honorable profession.
The law is settled beyond peradventure that, for the Respondent to be held guilty of infamous conduct in a professional respect, the following two conditions must be met:
- The Respondent must have committed the misconduct while rendering professional services or while working as a lawyer. See RE: G IDOWU – A LEGAL PRACTITIONER[18].
- The misconduct complained of must be one reasonably regarded as disgraceful or dishonourable by his professional colleagues. See ALLISON V. GENERAL COUNCIL OF MEDICAL EDUCATION & REGISTRATION[19]; RE A SOLICITOR[20]; OKIKE V LPDC[21]
We note that not all unprofessional conduct done while acting for a client is “infamous conduct.” Some unprofessional conduct is not “disgraceful nor dishonourable,” but is merely against established norms and legal tradition. An example, LPDC has held that a lawyer using the word, “barrister” as a title honorific before his name is an “unprofessional conduct.” See NBA v. OFOMATA[22]
Although the Legal Practitioners Act did not define what is tantamount to infamous conduct, it is deducible from a community reading of the Act that the conduct must be in a professional respect. other words, the conduct must touch on or be materially related to or pertain to the profession. Thus, in the case of ANOZA V. THE ATTORNEY GENERAL OF LAGOS STATE[23], the court held that:
‘It is trite law that a legal practitioner has an onerous duty to uphold and observe the rule of law, promote and foster the cause of justice, maintain a high standard of professional conduct, and shall not engage in any conduct which is unbecoming of a member of the honourable and highly prestigious legal profession.’
What then amounts to infamous conduct or misconduct in Legal practice? This question was answered by the Apex Court in the case of ITEOGU V. LPDC[24]. where the court held that
“… any conduct that constitutes all infraction of an acceptable standard of behaviour or ethics of the legal profession, or any conduct which connotes conduct despicable and morally reprehensible as to bring the legal profession into disrepute if condoned or unpunished, will amount to misconduct.”
However, examples of Infamous conduct in “Professional Respect” include stealing or converting or misappropriating a client’s money or property, defrauding a client, divulging privileged professional communication, acting despite the existence of a conflict of interest, colluding with a client to commit illegality or fraud or perjury, or forgery, stealing another lawyer’s client, a law lecturer participating or engage in exam malpractice, a prosecuting legal officer colluding with the defence to destroy evidence or otherwise to pervert the course of justice, a lawyer bribing the judge or other court official to have the judgement in his client’s favour, a lawyer communicating privately with the judge in a case he is handling, etc.
Thus, in RE G. IDOWU[25], the Supreme Court held that by Section 7(a) of the Legal Practitioners Act 1962, it is not enough that the Legal Practitioner be guilty of infamous conduct only, but it must be such conduct arising out of or on his profession. In that case, the Supreme Court cited with approval the following definition in the Australian case of EX-PARTE MEEHAN (1994) 1 GB 750;
“….it refers to conduct which being sufficiently related to the pursuit of the profession, is such as would reasonably incur the strong reprobation of professional brethren of good repute and competence,”
Indeed, an “act unbecoming” means conduct that is not appropriate given the nature of the fiduciary duties of a lawyer to his client as well as his duty to society and the legal profession. Rule 1 of the Rules of Professional Conduct for Legal Practitioners, 2023. The Rule provides as follows:
“A lawyer shall uphold and observe the rule of law, promote and foster the cause of justice, maintain a high standard of professional conduct, and shall not engage in any conduct which is unbecoming of a legal practitioner”.
A lawyer must always be a person of the utmost integrity and probity. Both the client and the public must have confidence in their ability to deal with a lawyer with complete frankness and openness and, most importantly, without the least fear or trepidation that they would be taken advantage of or misled in any way. In N.B.A vs MENE-EJEGI[26], it was held that ;
“A legal practitioner should not receive purchase price over any property he cannot transfer its possession to the buyer, where there is a failure of consideration, a legal practitioner who has received the purchase price from the buyer ought to promptly refund the monies he had and received. Delay in refunding buyer’s purchase price must be with a reasonable cause”. By this judgement, BEN MENE-EJEGI ESQ was found liable for infamous conduct by the legal practitioners’ disciplinary Committee & had his name struck off the roll of legal practitioners for a paltry sum of N1,600,000.00 (ONE MILLION, SIX HUNDRED THOUSAND NAIRA) only.
STANDARD OF PROOF OF PROFESSIONAL MISCONDUCT
The standard of proof of professional misconduct in disciplinary proceedings before the Legal Practitioners Disciplinary Committee against legal practitioners is not to satisfy “to be sure” or beyond reasonable doubt. In CHARLES OKIKE V. LPDC [2005] 15 NWLR (PT. 949) 471, the Supreme Court held that Charges or Complaints before the Legal Practitioners Committee are not akin to criminal charges before regular courts but allegations that constitute sufficient particulars of breach of duty by legal Practitioners to their Clients and which if proved will constitute infamous conduct under section 12 of the legal Practitioners Act.
CERTAIN ETHICAL CONDUCT FROM THE DECISIONS OF LPDC
THE NEED TO PUT AGREEMENTS WITH CLIENTS INTO WRITING
On the need for a discerning counsel to put important agreements with the client in writing, the Legal Practitioners Disciplinary Committee of the Body of Benchers (Holden at Abuja) held, among others, in the case of N. B. A. vs Atie[27], thus:
Prudence dictates to any discerning counsel that important agreements between him and his client must be put into writing.
THE NATURE OF PROFESSIONAL SERVICE
Lawyers must ensure that they serve their clients with care, skill, and diligence and the service must be commensurate to the remuneration bargained for. In the case of N.B.A. V. Ojoge-Daniel[28], it was stated as follows:
Whether impecunious or well-to-do, a legal practitioner ought not to deprive his or her client of their hard-earned money without providing commensurate services for their fee and other expenses paid for.
EXERCISE OF RIGHT OF LIEN
On the issue of whether a lawyer can exercise a lien over his client, it was held in the case of N.B.A. vs Gbenoba[29], per Daudu (SAN) as follows:
Mr. Osigwe the complainant has submitted the “legal jurisprudence in Nigeria does not recognize a lawyer’s right of lien in respect of his client’s funds”. For several reasons, we agree with this position. Firstly, the scope of the exercise of a lien does not extend to a legal practitioner. He is not a seller of goods but a provider of statutory regulated services to wit; legal services. Because the provision of legal services is regulated by the Legal Practitioners Act, there are ways and manners through which an aggrieved legal practitioner can seek fees for legal services rendered.
The LPDC in the above-cited case went on to rely on the case of Oyekanmi vs NEPA[30], where the Supreme Court, per Uwaifo, JSC outlined the procedure to be followed by a legal practitioner who intends to recover his fee from a defaulting client.
REINFORCING ETHICAL BEHAVIOURS
Reinforcing ethical behaviours in legal practice in Nigeria is essential for promoting professionalism, ensuring justice, and maintaining public trust in the legal profession[31]. Here are some specific steps that can be taken to reinforce ethical behaviours:
1. Strengthen Regulatory Framework: The regulatory framework governing legal practice should be robust and effectively enforced. Review and update the Legal Practitioners Act and the Rules of Professional Conduct to address emerging ethical issues and provide clear guidelines for lawyers to follow.
2. Ethical Education and Training: Law schools and professional bodies should incorporate comprehensive ethics education and training programs into their curriculum and continuing education requirements. This should cover ethical principles, professional responsibilities, conflicts of interest, confidentiality, and client representation.
3. Enhanced Disciplinary Process: Strengthen the disciplinary process by ensuring complaints against lawyers are promptly and thoroughly investigated. Create an independent disciplinary body that operates transparently and imposes appropriate sanctions for ethical violations, including fines, suspensions, and disbarment[32].
4. Ethical Guidance and Resources: Develop and distribute practical ethical guidelines and resources for legal practitioners, including sample codes of conduct and case studies that highlight ethical dilemmas and how to navigate them. This will help lawyers better understand their ethical obligations and make informed decisions.
5. Peer Review and Mentoring: Establish mentorship programs where experienced lawyers can guide and provide feedback to younger practitioners on ethical issues. Encourage open dialogue and a supportive environment where ethical concerns can be discussed and addressed.
6. Whistleblower Protection: Implement mechanisms to protect lawyers and legal professionals who report ethical violations. Encourage a culture where reporting misconduct is seen as a responsible and ethical act and provide safeguards against retaliation for those who come forward[33].
7. Public Awareness and Education: Conduct public awareness campaigns to educate the public about their rights and the ethical obligations of legal professionals. Encourage individuals to report unethical behaviour and provide accessible channels for complaints to be lodged[34].
8. Collaboration with Professional Associations: Collaborate with professional associations such as the Body of Benchers, General Council of the Bar, and, Nigerian Bar Association (NBA) to develop and implement strategies for promoting ethical behaviours among their members. Support the associations’ efforts to provide ethics training, guidelines, and peer support to their members[35].
9. Continuous Professional Development: Emphasize the importance of ongoing professional development, including ethics training, and make it a requirement for lawyers to maintain their practicing licenses. Offer regular ethics workshops, seminars, and webinars to keep legal practitioners updated on evolving ethical issues.
10. Monitoring and Auditing: Establish a system for monitoring and auditing legal practices to identify potential ethical violations. Conduct random checks and audits to ensure compliance with ethical standards and take appropriate action against those found in breach[36].
THE NEW CHAPTER TWO OF THE RULES OF PROFESSIONAL CONDUCT
The new Rules of Professional Conduct for Legal Practitioners (RPC) introduced in 2023 aim to address the risks associated with the legal profession concerning money laundering and terrorist financing. These rules are aligned with the global standards set out in the Financial Action Task Force (FATF) Recommendations 2023.
1. Risk Assessment:
The RPC requires legal practitioners to conduct an ongoing risk assessment to identify and understand the money laundering and terrorist financing risks that they may face. This includes considering the nature of their clients, the type of services provided, and the geographic areas in which they operate.
2. Customer Due Diligence (CDD):
Legal practitioners are obligated to apply customer due diligence measures when establishing a business relationship with a client or conducting occasional transactions. This includes verifying the identity of their clients, understanding the purpose and intended nature of the business relationship, and conducting ongoing monitoring of the client’s activities.
3. Record Keeping:
The RPC emphasizes the importance of maintaining accurate and up-to-date records of client transactions and providing necessary documentation upon request by competent authorities. Legal practitioners must retain relevant records for a specified period to aid in investigations and audits.
4. Reporting Suspicious Transactions:
Under the RPC, legal practitioners must report suspicious transactions or activities related to money laundering or terrorist financing to the appropriate regulatory authorities. This requirement includes the provision of relevant information and documents to assist in the investigation of such activities.
5. Internal Controls and Training:
To mitigate the risk of money laundering and terrorist financing, legal practitioners are expected to establish and implement internal controls, policies, and procedures. These controls should address risk assessment, customer due diligence, training of staff, record-keeping, and reporting obligations. Regular training programs should be conducted to educate legal practitioners and staff about their AML/CFT responsibilities.
6. Cooperation with Regulatory Authorities:
The RPC highlights the need for legal practitioners to cooperate fully with regulatory authorities and provide necessary information, documentation, and support during investigations related to money laundering or terrorist financing. Legal practitioners should also assist in freezing and seizing assets identified as part of these illicit activities.
7. Supervision and Enforcement:
To ensure compliance with AML/CFT obligations, regulatory bodies are empowered to supervise and enforce the RPC. Sanctions, penalties, and disciplinary actions may be imposed against legal practitioners who fail to comply with these obligations.
The provisions of the new RPC align with the FATF Recommendations 2023, which are internationally recognized standards for combating money laundering and terrorist financing. By including legal practitioners as DNFBPs and imposing AML/CFT obligations on them, the MLPP Act 2022 and the RPC aims to enhance the overall effectiveness of anti-money laundering and counter-terrorist financing measures within the legal profession.
CONCLUSION
In conclusion, lawyers must uphold the ethical standards and professional responsibilities required of them in their practice. A lawyer should not encourage or allow his client to disobedience of a Court judgement and/or order. A lawyer should not do anything while practicing or permit another person to do on his behalf anything that negotiates or endangers any of the following duties:
- The practitioner’s autonomy or honesty
- A person’s freedom to instruct a legal practitioner of his or her choice.
- Practitioner’s duty to act in the best interests of the client.
- The good repute of the lawyer or the legal profession
- The practitioner’s standard of work
- The practitioner’s duty to the Court
By adhering to these principles, lawyers can help maintain the integrity and credibility of the legal profession while promoting justice and upholding the rule of law. Understanding and adhering to ethics, etiquette, and ethical precepts are essential for lawyers to uphold the integrity of the legal profession and ensure the fair and just administration of the law and justice dispensation. Nigeria should reinforce ethical behaviours in legal practice and maintain the highest standards of professionalism, integrity, and public confidence in the legal profession. According to John Berger; “without ethics, man has no future”.
Thank You
[1] Usman, S. (2024). Ethics, Etiquette, and Navigating Ethical Precepts in Legal Practice in Nigeria. Presented at the One Day Seminar of the Litigation Committee of the Nigerian Bar Association Section on Legal Practice on the theme “Legal Practice in Nigeria – Reinforcing Ethical Behaviour” held on Friday 22nd March, 2024 at Lagos Court of Arbitration, Lekki, Lagos State.
[2] M. O. Adeyanju, “Navigating Ethical Dilemmas in Legal Practice: A Nigerian Perspective,” Nigerian Journal of Legal Studies, vol. 6, no. 2, pp. 78-92, 2020.
[3] HW Jessup, “The Ethics of the Legal Profession’, (1922) 101 The Annals of American Academy of Political Science, pp16-29 https://www.jstor.org/stable/1014582 Accessed: 20 March 2024.
[4] Ibid.
[5] The Legal Practitioners Act Cap. L11 Laws of the Federation of Nigeria 2004 1975 as amended, S2(1), 24.
[6] Awojolu v Odeyemi & Ors. (2012) LPELR 1479: Okafor v. Nweke (2007) LPELR 241.
[7] Rules of Professional Conduct for Legal Practitioners, 2030.
[8] Ibid, rule 1.
[9] (2012) 1 NWLR (Pt 1282) 560 at p 610, Saulawa JCA.
[10] W. A. Alade, “The Role of Ethics and Etiquette in Legal Practice in Nigeria,” Nigerian Journal of Commercial Law, vol. 3, no. 2, pp. 12-25, 2019.
[11] R. S. Adeyemi, “Professional Responsibility and Accountability in the Nigerian Legal System,” Journal of Law and Society, vol. 45, no. 4, pp. 567-586, 2020.
[12] M. A. Olajide, “The Concept of Ethics in Legal Practice,” Nigerian Bar Journal, vol. 18, no. 1, pp. 34-49, 2018.
[13] Rules of Professional Conduct for Legal Practitioners, 2023, R17.
[14] The Rules of Professional Conduct for Legal Practitioners, 2023.
[15] [2009] LPELR – 4128 CA
[16] (BB/LPDC/150/14) reported in Directions & Rulings of the LPDC (May 2014 – April 2017) Volume three.
[17] (2012) 1 NWLR (PT 1282) 560 AT P 610.
[18] (1971) 1 ALL NLR 126.
[19] (1894) 1 QB 750.
[20] (1912) 1 KB 302.
[21] (2005) 15 NWLR(PT949)471.
[22] (2017) 5 NWLR (PR 1557) 128 @ 133.
[23] (2010) LPFLR – 3788 PAGE 41-41 Para C.C
[24] (2009) LPELR- 1559 (SC) P. 29, PARA A-B.
[25] (1971) ALL NLR 128.
[26] (2021)7 NWLR (PT 1776) 551 AT 575, C-E.
[27] (2016) 10 NWLR (pt. 1520) L.P.D.C. 394 at 425 paras. F-G.
[28] (2013)12 NWLR (pt. 1369) 625 at pp. 631-632 paras. G-A.
[29] (2015) 15 NWLR (pt. 1483) L.P.D.C. 585 at 620 paras. B-D.
[30] (2000) 15 NWLR (pt. 690) pg. 414 at pp. 431 – 432 paras. F-A.
[31] A. R. Ogidi, “Enforcing Ethical Behaviour among Legal Practitioners in Nigeria,” Journal of Legal Ethics, vol. 32, no. 3, pp. 254-272, 2021.
[32] N. E. Ifediora, “Disciplinary Process for Ethical Violations in Nigerian Legal Practice,” Journal of Legal Ethics, vol. 30, no. 1, pp. 34-49, 2019.
[33] M. D. Akinleye, “Protecting Whistleblowers in Nigerian Legal Practice: A Proposed Framework,” Journal of Ethics and Professional Standards, vol. 47, no. 3, pp. 144-160, 2022.
[34] A. S. Gbadamosi, “Promoting Public Awareness of Legal Ethics in Nigeria,” Nigerian Bar Journal, vol. 22, no. 2, pp. 87-102, 2021.
[35] K. A. Ojo, “Collaboration with Professional Associations for Ethical Behaviours in Legal Practice,” Nigerian Journal of Legal Studies, vol. 8, no. 1, pp. 56-72, 2022.
[36] F. A. Oladejo, “Monitoring and Auditing Ethics in Nigerian Legal Practices,” Journal of Legal Ethics, vol. 31, no. 4, pp. 356-372, 2019.
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