MADUKOLU & ORS.
V.
NKEMDILIM

(1962) JELR 40917 (SC)

Supreme Court 12 Nov 1962 Nigeria
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- The Supreme Court (majority) held that the previous judgment dismissing the plaintiffs’ claim for rent, based on disputed land title, constituted res judicata and barred a fresh action for declaration of title, as the issue of ownership w

Case Details

Suit Number:F.S.C.344/1960
Judges:SIR LIONEL BRETT JSC JOHN IDOWU CONRAD TAYLOR JSC VAHE BAIRAMIAN JSC
Counsel:Shyngle Onyekwuluje For Appellant Sofola For Respondent
Other Citations:(1962) 2 SCNLR 342

VAHE BAIRAMIAN, FJ. (Delivering the Leading Judgment): This appeal from the High Court of the Eastern Region (Betuel, J. at Onitsha on 23 November, 1959) raises the questions of res judicata and turns on the application of Section 53 of the Evidence Act, which provides that

Every judgment is conclusive proof, as against parties and privies, of facts directly in issue in the case, actually decided by the court, and appearing from the judgment itself to be the ground on which it was based; unless evidence was admitted in the action in which the judgment was delivered which is excluded in the action it is intended to be proved.

The questions raised in this appeal are:

(1) whether title to land was a fact directly in issue in the previous case between the parties;

(2) whether the title was actually decided by the court;

(3) whether the title appears from the judgment itself to be the ground on which it was based.

In the previous case (No. 33/56) before the Native Court of Mbatechete, th…

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