LEGAL PRINCIPLE: CIVIL PROCEDURE — Res Judicata — Determination of Identity of Issues and Parties
PRINCIPLE STATEMENT
In determining whether the plea of estoppel per rem judicatam or whether the issues, the subject of the two actions and the parties are the same, the court is permitted to study the pleadings, the proceedings and the judgment in the previous proceedings. The court may also examine the reasons for the judgment and other relevant facts to discover what was in issue in the previous case.
RATIO DECIDENDI (SOURCE)
Per Iguh, JSC Oshodi v. Eyifunmi (2000) NLC-531995(SC) at p. 21; Paras. C–D.
"In determining whether the plea of estoppel per rem judicatam or whether the issues, the subject of the two actions and the parties are the same, the court is permitted to study the pleadings, the proceedings and the judgment in the previous proceedings. The court may also examine the reasons for the judgment and other relevant facts to discover what was in issue in the previous case."
EXPLANATION / SCOPE
To determine if res judicata applies, courts may look beyond the mere final order and examine the entire record of prior proceedings—including pleadings, evidence, proceedings, and judgment reasons. This comprehensive review enables the court to ascertain precisely what issues were actually litigated and determined. It is not enough that the subject matter appears similar; the court must identify the specific issues previously resolved. This approach ensures that parties are not unfairly barred by prior decisions that did not actually determine the same questions now raised. The inquiry focuses on substance rather than formal alignment of claims