PRINCIPLE STATEMENT

That in respect of relief No. (d) the court does not grant an injunction in respect of a completed act.

RATIO DECIDENDI (SOURCE)

Per Karibi-Whyte, JSC (adopting ground of objection), in Adenuga & Ors v. Odumeru & Ors (2001) NLC-432000(SC) at p. 3; Paras A–B. See also Achike, JSC, at p. 13; Paras A–B.
"That in respect of relief No. (d) the court does not grant an injunction in respect of a completed act."
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EXPLANATION / SCOPE

Courts do not grant injunctions against completed acts. Injunction is a preventive, not curative, remedy. It restrains future or continuing acts, not acts already done. Once an act is completed, there is nothing to restrain. The appropriate remedy for a completed wrong is damages or other relief, not injunction. The principle prevents misuse of injunctive relief. The applicant must show an ongoing or threatened violation. A completed act cannot be undone by injunction. The court will not issue a futile order. If the act is complete and cannot be undone, injunction serves no purpose. The remedy must match the nature of the wrong. Injunction looks forward, not backward.

CASES APPLYING THIS PRINCIPLE