ADMIRALTY LAW — Admiralty Jurisdiction — Banking or Letter of Credit Transaction — Requirement for Involvement of Ship or Aircraft
Ratio Decidendi
Per Tobi, JSC, in Integrated Timber and Plywood Products Ltd. v. Union Bank Nigeria Plc (2006) NLC-123-342-2001(SC) at pp. 17–18; Paras E–A:
"Section 1(1)(h) talks about banking or letter of credit transaction involving the importation or exportation of goods. Does the letter of credit… qualify as goods within the meaning of section 1(1)(h) of the Decree?… How can a mere act of confirmation of the authenticity of a letter of credit suddenly ripen or metamorphose into an admiralty matter?"
Explanation / Scope
Admiralty jurisdiction requires involvement of ships or aircraft; mere letter of credit confirmation does not suffice. The principle applies to admiralty law.