LEGAL PRINCIPLE: SUCCESSION LAW – Administration of Estate – Obiter Dicta – Pronouncements on Beneficial Entitlement Outside Scope of Proceedings
PRINCIPLE STATEMENT
The pronouncements made by the two courts below on who is or is not entitled as beneficiary to the estate is completely outside the purview of the question before the courts and are, therefore, of no consequence.
RATIO DECIDENDI (SOURCE)
Per Ogundare, JSC, in Dejonwo & Anor v. Dejonwo & Ors (2000) NLC-591994(SC) at p. 4; Paras B–C.
"The pronouncements made by the two courts below on who is or is not entitled as beneficiary to the estate is completely outside the purview of the question before the courts and are, therefore, of no consequence."
EXPLANATION / SCOPE
Judicial pronouncements on matters outside the scope of proceedings constitute obiter dicta—they are not binding and carry no legal consequence. In administration proceedings, statements about beneficial entitlement are extraneous because such issues were not properly before the court. Courts must confine decisions to questions raised. Extraneous pronouncements should be disregarded by subsequent courts. This prevents courts from inadvertently determining rights in proceedings not designed for that purpose. Parties cannot rely on obiter dicta from administration proceedings as binding determinations of beneficial interests.