LIMITATION LAW — Interpretation of Statute — Pari Materia — Duty to Follow Earlier Construction
Principle Statement
When a court is faced with the construction of a statutory provision that is in pari materia (on the same subject matter) with a provision previously construed by the Supreme Court, it is bound to follow the interpretation laid down in the earlier decision.
Ratio Decidendi (Source)
Per Chukwuma-Eneh, JSC, in Bakare v. NRC (2007) NLC-123-51-2002(SC) at p. 17; Para C.
"It is also the case that this court faced with the construction of a statutory provision in pari materia with one that has been previously construed by this court, it has to follow the principle laid down in the earlier case see Mobil Oil Plc v. IAL 32 INC (2000) FWLR (pt.10) 1632 at 1640. In this regard, I have to advert to the decision in NBC's case in so far as the principle of interpretation enunciated in that case applies here."
Explanation / Scope
The principle applies to statutory interpretation. Where statutes share similar language and purpose, courts interpret them consistently to avoid conflicting outcomes. The duty to follow earlier construction promotes uniformity, certainty, and coherence in the legal system. It prevents a lower court or even the same court from adopting a divergent interpretation of identical or analogous provisions. The rule is an aspect of judicial comity and stare decisis. It does not apply if the earlier decision is clearly wrong or has been overruled. The principle ensures that the law remains stable and predictable across different statutes governing similar subject matter.
