LEGAL PRINCIPLE: CIVIL PROCEDURE – Injunctions – Completed Acts – Court Does Not Grant Injunctions in Respect of Completed Acts
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."
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.