PRINCIPLE STATEMENT

Where a statute prescribes a remedy, an aggrieved party must first exhaust that remedy before recourse to the court. Where he fails to exhaust the remedies statutorily available to him, his action is premature and does not give rise to a cognisable cause of action. ... where the relevant statute has given exclusive jurisdiction to another tribunal or hierarchy of tribunals to determine a matter, the jurisdiction of the court to grant a declaration on the same matter would appear to be ousted; its jurisdiction is only limited to supervisory power over the inferior tribunal.

RATIO DECIDENDI (SOURCE)

Per Ogundare, JSC, in Odugbo v. Abu & Ors (2001) NLC-1121996(SC) at p. 53; Paras A–C.
"Where a statute prescribes a remedy, an aggrieved party must first exhaust that remedy before recourse to the court. Where he fails to exhaust the remedies statutorily available to him, his action is premature and does not give rise to a cognisable cause of action. ... where the relevant statute has given exclusive jurisdiction to another tribunal or hierarchy of tribunals to determine a matter, the jurisdiction of the court to grant a declaration on the same matter would appear to be ousted; its jurisdiction is only limited to supervisory power over the inferior tribunal."
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EXPLANATION / SCOPE

Where a statute prescribes a remedy, an aggrieved party must exhaust that remedy before approaching the court. Failure to do so renders the action premature—no cognisable cause of action arises. If the statute grants exclusive jurisdiction to another tribunal or hierarchy, the court’s jurisdiction to grant declaratory relief is ousted. The court’s role is limited to supervisory jurisdiction over the inferior tribunal (e.g., judicial review). The principle promotes the rule of law and respects statutory dispute resolution mechanisms. The court will not interfere until statutory remedies are exhausted. The exhaustion rule applies to administrative remedies, internal appeals, and specialist tribunals. The court retains supervisory jurisdiction to prevent excess of jurisdiction or error of law.

CASES APPLYING THIS PRINCIPLE