PRINCIPLE STATEMENT

It is both fundamental and elementary principle in the adjudicatory process that where the jurisdiction of the court or judge is in issue in respect of a matter, that issue must first be considered and disposed of; this is because any determination in the absence of jurisdiction is a nullity.

RATIO DECIDENDI (SOURCE)

Per Karibi-Whyte, JSC, in Magaji v. Matari (2000) NLC-1361994(SC) at p. 12; Paras. A–B.
"It is both fundamental and elementary principle in the adjudicatory process that where the jurisdiction of the Court or the Judge is in issue in respect of a matter, that issue must first be considered and disposed of. See Kalio v. Daniel-Kalio (1975) 2 SC. 15. This is because any determination in the absence of jurisdiction is a nullity. See Peenok Ltd. v. Hotel Presidential Ltd. (1982) 12 SC. 1."
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EXPLANATION / SCOPE

This reinforces jurisdictional priority principle. When jurisdiction is challenged: that issue takes precedence, must be determined first, and other issues await jurisdictional resolution. “Fundamental and elementary” means: basic to adjudication, universally recognized, and always applicable. Reason: Determinations without jurisdiction are nullities—void, without legal effect, and incapable of validation. This serves: preventing wasteful proceedings without jurisdiction, ensuring valid determinations, and protecting against void orders. Procedure: When jurisdiction challenged: (1) Court considers jurisdictional objection first; (2) Hears arguments on jurisdiction; (3) Determines jurisdiction; (4) Only if jurisdiction exists, proceeds to merits; (5) If no jurisdiction, declines to proceed further. “Must first be considered” means: priority over merits, precedence over all other issues, and threshold determination. Nullity consequence: Without jurisdiction: proceedings are void ab initio, orders/judgments have no legal effect, and can be set aside at any time (see Principles 549-550). This prevents: courts proceeding without jurisdiction, making void determinations, and wasting parties’ time/resources. Application: Courts must: entertain jurisdictional challenges promptly, determine jurisdiction before merits, and refuse to proceed if lacking jurisdiction. Parties should: raise jurisdictional objections early, insist on preliminary determination, and preserve objection throughout. This fundamental principle ensures jurisdictional validity precedes merits consideration.

CASES APPLYING THIS PRINCIPLE