PRINCIPLE STATEMENT

It is trite law that an appeal court must consider all issues for determination raised before it except where it is of the view that a consideration of one issue is enough to dispose of the appeal.

RATIO DECIDENDI (SOURCE)

Per Kalgo, JSC, in Tunbi v. Opawole (2000) NLC-921993(SC) at pp. 10–11; Paras. E–A.
"It is trite law that an appeal court must consider all issues for determination raised before it except where it is of the view that a consideration of one issue is enough to dispose of the appeal."
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EXPLANATION / SCOPE

Appellate courts have discretion regarding issue consideration: General rule: Courts must consider all issues raised by parties. Exception: Court may decide based on single issue if that issue disposes of entire appeal. This serves: judicial efficiency (avoiding unnecessary issue analysis), focusing on determinative matters, and preventing redundant determinations. “Enough to dispose of appeal” means: issue is dispositive, deciding it resolves appeal completely, and considering other issues is unnecessary. Examples: jurisdictional issue (if court lacks jurisdiction, other issues irrelevant), threshold procedural issue (if appeal is incompetent, merits irrelevant), or fundamental substantive issue (if plaintiff has no cause of action, other claims irrelevant). Courts exercise this discretion when: one issue clearly determines outcome, deciding other issues would be academic, and judicial economy favors focused determination. However, courts should: explain why one issue is dispositive, show how it renders other issues moot, and avoid arbitrarily ignoring raised issues. This principle balances: parties’ right to have issues considered against judicial efficiency in avoiding unnecessary determinations. The discretion must be exercised judicially—not ignoring issues arbitrarily but legitimately finding one issue dispositive of entire appeal.

CASES APPLYING THIS PRINCIPLE