BABA ALKALI BA'ABA, J.C.A. (Delivering the Leading Judgment): The respondent in this appeal was the plaintiff before the lower court, in the writ of summon, dated the 28th day of March, 2001, filed on the 14th day of May, 2001, he claimed as follows:-
"(1) A declaration that the purported deed of personal guarantee allegedly by the plaintiff for the full repayment of the full amount of N20,000,000.00 plus the accrued interest thereon, granted to Abdulhassan Sulaiman and Sons Limited is fictitious, fraudulent, nonexistent and therefore null and void.
(2) A declaration that the plaintiff is not indebted or liable to the defendant to the tune of N20,000,000.00 plus the accrued interest thereon or in any other sum at all, based on the purported deed of personal guarantee dated 12-01-96.
(3) A declaration that the contents of the defendant's letter addressed to the plaintiff and dated 10th March, 1999 are frivolous, malicious and defamatory of the plaintiff.
(4) Damages in the sum of N50,…