Principle Statement

Where there is a conflict between a previous enactment and a later one, the former is deemed impliedly repealed, and the later one prevails.

Ratio Decidendi (Source)

Per Ayoola, JSC, in Salubi v. Nwariaku & Ors (2003) NLC-1201997(SC) at p. 7; Paras C–D.

"Where there is a conflict between such previous enactment and the later one, the former should be deemed impliedly repealed and the later one should prevail."

Explanation / Scope

Later statutes impliedly repeal earlier inconsistent provisions. The principle applies to statutory interpretation. The court will give effect to the later enactment. The rule promotes legislative supremacy. The later law expresses the current legislative will. The principle is well-established.

Cases Applying This Principle