LEGAL PRINCIPLE: STATUTORY INTERPRETATION – Words and Phrases – “Approve” and “Authorise” – Meaning in Context of Decree No. 17 of 1984
PRINCIPLE STATEMENT
The Oxford Universal Dictionary Illustrated, 3rd edition, Vol. 1 page 125, defines the word 'authorise' as 'to give formal approval to.' I can see no difference between the words 'approve' and 'authorise' in the circumstance of the compulsory retirement of the appellant under Decree 17 of 1984.
RATIO DECIDENDI (SOURCE)
Per Uwaifo, JSC, in Omo v. JSC, Delta State & Ors (2000) NLC-3041990(SC) at pp. 17–18; Paras D–A.
"The Oxford Universal Dictionary Illustrated, 3rd edition, Vol. 1 page 125, defines the word 'authorise' as 'to give formal approval to.' I can see no difference between the words 'approve' and 'authorise' in the circumstance of the compulsory retirement of the appellant under Decree 17 of 1984."
EXPLANATION / SCOPE
In the context of Decree No. 17 of 1984, “approve” and “authorise” carry substantially the same meaning—giving formal sanction or permission. The words are used interchangeably in the decree and should be construed accordingly. No technical distinction is required where the context indicates synonymous usage. This pragmatic approach avoids artificial distinctions that would defeat legislative intent. Where a statute uses similar terms without differentiation, courts should treat them as having equivalent effect unless context demands otherwise. Plain dictionary meaning guides interpretation.