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ATTORNEY GENERAL OF THE FEDERATION V. UGO (2018)

case summary

Court of Appeal (Port Harcourt Division)

Before Their Lordships:

  • Ejembi Eko JCA
  • Theresa Ngolika Orji-Abadua JCA
  • Bitrus Gyarazama Sanga JCA

Parties:

Appellant:

  • Attorney General of the Federation

Respondents:

  • Mrs. Binafeigha Ugo
  • Miss Taremobere Ugo
  • Mr. Thomas Moses Ugo
  • Mrs. Mary Ugo
  • Mr. Nemi Iwo
  • Mr. Donkera Karigbani
  • Mr. Augustine Ugwuanyi
  • Comm. of Police, Bayelsa State Command
  • Inspector General of Police
  • Minister of Police Affairs
Suit number: CA/PH/560/2013

Background

The case centered on the unlawful death of Mr. Erezidor Ugo, after an altercation involving personnel from the Nigerian Police and Nigeria Prisons. The deceased's family sought damages from the Attorney General and others, alleging negligence that led to his death.

Issues

The appeals primarily revolved around two critical issues:

  1. Whether the lower court had jurisdiction over the case given that it involved federal government employees.
  2. Whether the claim of the appellant regarding the second limb of their preliminary objection constituted a demurrer.

Ratio Decidendi

The Court held that:

  1. The lower court rightly asserted its jurisdiction, stating that the suit’s claims did not engage the exclusive jurisdiction of the Federal High Court.
  2. Points of law raised regarding lack of reasonable cause of action constituted a demurrer, which had been abolished under the Bayelsa State High Court Rules.

Court Findings

It was found that:

  1. The claims brought forward by the 1st to 4th respondents were valid under the Torts Law of Bayelsa State, thereby granting the state court jurisdiction.
  2. The distinction between objections to jurisdiction and demurrers was made clear, emphasizing that the latter cannot exist if other parties have not filed their pleadings.

Conclusion

The appeal was dismissed with the acknowledgment that the claims did not pertain to administrative decision-making by federal agencies but rather accounted for tortious claims based on negligence resulting in wrongful death.

Significance

This ruling is significant in clarifying the jurisdictional boundaries between Federal and State Courts in cases involving federal personnel accused of tortious acts. It reinforces that simply being a federal employee does not automatically confer jurisdiction to federal courts.

"} This case sets a strong precedent regarding the handling of tort claims involving federal employees, asserting the right for state courts to adjudicate cases rooted in tort law regardless of the defendants' affiliations with federal agencies.

Counsel:

  • G. O. Bright Esq. - for the Appellant
  • A. M. Ekadi Esq. - for the 1st - 4th Respondents
  • G. I. Abibo SAN - for the 5th - 7th Respondents