APPELLATE PRACTICE — Grounds of Appeal — Formulation of Issues — Proliferation of Issues from a Single Ground
Ratio Decidendi
Per Onnoghen, JSC, in Okonobor & Ors v. D. Edegbe & Sons Transport Co. Ltd & Anor (2010) NLC-123-187-2003(SC) at p. 4; Paras A–B:
"It is settled law that proliferation of issues is unacceptable in our appellate courts. While counsel is permitted to formulate an issue out of a ground or grounds of appeal, he cannot formulate two issues out of a ground of appeal as in the instant appeal."
Explanation / Scope
This principle establishes that proliferation of issues is unacceptable. Counsel cannot formulate two issues from a single ground of appeal. The principle applies in appellate practice. It ensures that issues are properly limited. The principle reflects the need for focus in appeals. It prevents unnecessary proliferation of issues. The court must strike out excess issues. The principle provides guidance on the number of issues permissible.