March 2, 2024

Corruption, Society and the Legal Profession: Whither the Bar?

Dr. M.N.O. Olopade, SAN* FCArb

Protocol

1. I am delighted to be invited by the NIGERIAN BAR ASSOCIATION, OGBOMOSO BRANCH to deliver this speech as part of the series of lectures for the 3rd edition of the Nigerian Bar Association, Ogbomoso Branch Law week and the maiden edition of the Hon. Justice Atilade Ojo RTD. Annual Lecture.

2. Let me congratulate the Nigerian Bar Association, Ogbomoso Branch for its thoughtfulness in instituting this lecture in honour of Hon. Justice Atilade Ojo during his lifetime and not waiting for posthumous lectures and events after the departure of the legal giant and a trail blazer in legal practice in the land of the valiants and great achievers.

3. I met the Hon. Justice Atilade Ojo RTD then ATILADE OJO ESQ, in July, 1996 for the first time during the wedding of his “son in law”, AYOOLA AJAYI ESQ. my bosom friend and my short interaction with him reveal that he is a man of high intellect, highly disciplined and uncompromising believer in truth and honesty.

4. Upon the elevation of my Lord to the bench, I watched with keen interest my Lord’s performance on the bench and it was a sterling performance and very befitting of a judge with integrity, honor and a believer in the rule of law.

5. I equally use this medium to congratulate my Lord for God’s grace on him to witness a day like this which is a public recognition of his Lordship’s achievements in life and an icing of the cake as it were.

6. Let me also commend the leadership of the Association for the well-put-together event culminating in today’s programme. In this regard, I must specifically pay special tribute to our learned colleague, Mrs. Omotayo Olatubosun, who has successfully written her name in our own Guinness Book of Records as the youngest female to emerge as the Chairperson of this Branch. By this achievement, I am certain that the proverbial glass ceiling has been shattered for good, and I am certain that the Ogbomoso Bar is going to be better for it.

7. One reason I have singled out Mrs. Omotayo Olatubosun and her team for commendation is something that struck me whilst I was preparing this address. I observed that one of the programmes her administration is determined to achieve during their tenure is what she described in her inaugural address in July as ‘timely and frequent Bar-Bench forum.’

8. Distinguished Ladies and Gentlemen, if there is indeed a programme that we all need at this time in the legal profession, it is none other than an improved, dynamic, and interactive relationship between the Bench and the Bar. The reality of the legal profession is that both the Bench and the Bar are like the two wings of an eagle. As it is not possible for an eagle, of even any bird for that matter, to fly with one wing, it is also not possible for the Bar to function without the Bench, and vice versa. Or is it possible to clap with one hand? It is therefore imperative that we should place on the front burner any issues affecting the Bar and the Bench.

9. One issue that needs to be urgently addressed is the question of perception of corruption in the country in general and in the legal profession, in particular. It should be noted that I did not say ‘question of corruption’. I said question of ‘perception of corruption’. There is a world of difference between the two expressions, and they are not to be taken as synonymous. By perception of corruption, we are talking about a subjective approach about how the public perceive the legal profession. 

10. There is no doubt that corruption is a cancer that is injurious to our collective existence as a nation. This is perhaps the reason the drafters of the Constitution of the Federal Republic of Nigeria 1999 expressly provided in section 15(f) that 

“The State shall abolish all corrupt practices and abuse of power.” 

11. The Supreme Court – the apex Court in the land – has underscored the implication of corruption in the country when it was observed by Ogwuegbu JSC in the case of Attorney General of Ondo State v. Attorney General of the Federation that: 

“Corrupt practices and abuse of power can, if not checked threaten the peace, order and good government of the Federation or any part thereof… The deadly threat is the effect on the economy of the country with the attendant inflation and lack of control on the monetary and fiscal policies of the Government.”

12. In the same vein, in the leading judgment of Uwais CJN in the same case, His Lordship opined that:

“Corruption is not a disease which afflicts public officers alone but society as a whole. If it is therefore to be eradicated effectively, the solution to it must be pervasive to cover every segment of the society.”

13. It should be noted, contrary to general perception, that corruption is not peculiar to Nigeria. It is a global phenomenon and a worldwide virus which afflicts many countries of the world. It is such an international issue that exactly 20 years ago, the United Nations in 2003 declared December 9 of every year the International Anti-Corruption Day. It is a day set aside for the world to re-affirm our collective commitment to eradicate corruption in all aspects of professional life and national affairs.

14. For the whole world to have dedicated a day to the scourge of corruption underscores the fact that it is indeed a global virus which is not limited by race, tongue, or tribe. The truth is that if we are going to be sincere with ourselves, many of the challenges we are facing in the world today could not be divorced from corruption and corrupt practices.

15. Corruption may be defined as a form of dishonesty or a criminal offence which is undertaken by a person or an organization which is entrusted in a position of authority, in order to acquire illicit benefit or abuse power for one’s personal gain.

16.  Corruption has also been defined by the Transparency International as the abuse of entrusted power for private gain. It is asserted that corruption erodes trust, weakens democracy, hampers economic development, further exacerbates inequality, poverty, social division and the environmental crisis as well as judicial corruption.

17. Distinguished Ladies and Gentlemen, do you know what is 

         however strange? It is my position, and I stand to be corrected, particularly as we are in Ogbomoso, one of the most ancient towns that symbolises Yoruba civilization, that corruption is alien to our culture as Africans. I want anyone to stand up to tell us the exact Yoruba word for the word ‘corruption’. From my elementary research, it does not appear that Yoruba and most Nigerian ethnic languages have a word that is directly equivalent to ‘corruption’. It follows, by parity of logical reasoning, that corruption is in fact an imported phenomenon, a foreign element in our country.

18. As young as I am, I grew up to hear vivid stories about traders leaving their wares unattended by the roadsides and people would purchase the goods and leave money without the fear of anyone taking it! I am more than certain that we have all heard similar stories while we were growing up. Whilst I was preparing this address, I came across the Colonial Report on Nigeria in 1951. A section of the report detailed “statistics of common or serious types of crime” recorded from the period of 1st January to 30th September 1951. I can tell you, Respected Members of the Nigerian Bar, that there was no single case of corruption reported in 1951. In case you are thinking that that was an isolated instance, the same thing happened in the year 1955. No single case of corruption or corrupt practice. Today, it is hardly impossible to pick a weekly law report without coming across one reported case of corrupt   practices or another.

19. As I mentioned above, many of the societal ills afflicting our country cannot be divorced from the virus of corruption. The ills are so pervasive that there is hardly any sector that is free from the plague. From education, to administration, to public service, to law enforcement, to even traditional institution, and of course to our own legal profession. The cankerworm has eaten deep into our very existence.

20. What I have just said in the preceding paragraph had been echoed more than a decade ago by our revered jurist, Justice Kayode Eso, JSC of blessed memory who observed that:

“Is it not getting to a stage now that the present generation, that is, those who were, at the time of the prediction, of voting age, hardly know what democracy is, having regard to lack of transparency and corruption in practically every sector and wanton acceptance thereof, as a normal way of life? It has come to a stage in this country that every sector is presumed to be corrupt. The onus for the proof of transparency now lies on individuals. Thuggery is an accepted norm. Men in police uniform takes bribes openly and with slinging guns in their hands, they have turned themselves in the highways to legalized armed robbers. Only recently, Jesse Jackson, from the United States of America, talking about corruption in Africa said – For Africa to move forward corruption must be seen as a crime against humanity as we are rich to be poor”

21. His Lordship was not alone in this regard. In the case of Akingbola v. Chairman, EFCC, my Lord Justice Saulawa JCA [as he then was] hit the nail on the head when His Lordship stated that:

“I  think it would be apt for me to observe, at this point in time that corruption is the hydra headed monster that has for several decades bedevilled the corporate existence of this beloved country, Nigeria, in particular, and the entire African continent,in general. The pandemic of corruption has undoubtedly shamed and diminished us all. As the root of all evils known to man, the Pandemic of corruption has virtually brought the country to its knees. Indeed, it’s a truism, that corruption is antithetic to the well cherished democratic ideals and rule of law.”

Causes of Corruption

22. With the unanimity of opinions about the unsavoury effect of corruption, the question that I know is agitating your mind is what is the root cause of corruption? In other words, how did we get to this point that we have seemingly normalised corruption and corrupt practices. I want to believe that a fundamental factor in this regard is what I can describe as our misplaced cultural values. I have noted above that corruption was alien to our society and culture. It was a taboo in our society where we placed premium on honesty, hard work, and fidelity. 

23. Let me share a story credited to my noble Lord, Hon Justice Olayinka Ayoola, the former Chairman of the Independent Corrupt Practices Commission, with you. You might not know it but His Lordship was a former bank clerk before proceeding to read Law. According to His Lordship, they used to move money [cash] in those days without armed guards, and whenever they wanted to eat whilst in transit, they would pack the car with the money in it in a market place and went to a restaurant to eat, and the market, people would be peeping into the vehicle to behold the currency whilst praying that they would be successful in life. Can you imagine such a scenario today?

24. The reality of our existence is that we have totally misplaced our cultural values. Today, a teenager is interested in riding the latest automobile in town without following due process. Today, parents do not raise any eyebrow about their children’s sources of income. Today, we do not know our neighbours and we do not interact with them. Our children cannot be disciplined by our neighbours. As a result, there is no longer what I can call ‘itiju’ in our society. The social stigma that attaches to being morally bankrupt is no longer there. You only need to check the social media to observe the abysmal level of the values in our society.

25. It is now becoming normal to wake up to read stories of young men killing their girlfriends for the so-called money ritual or yahoo plus? These are all effects of corruption in the society. In a society where no one questions your choice of wealth but people are only interested in the fact that you have made it, there is a fundamental problem in such a society.

26. It may not be out of place to aver that moral decadence and absence of good moral values have been our bane for a long time. In a 1988 Supreme Court case, my noble lord Hon. Justice Chukwudifu Oputa in Atano v. A.G (Bendel) had this to say: 

“I will pause to observe that the facts of this case offer yet another solid example of the moral decay in our society. That a Bank Manager appointed to manage, and entrusted with the bank’s money, should steal the very money entrusted to him shows how deep the “get rich quick” virus has eaten into our social fabric. 

That an Accountant appointed and paid to keep the books of his bank, will bunt those books in order to destroy all evidence of his theft, looks grossly Machiavellian. And yet this is what one sees every day. It is the recurring decimal of theft followed by arson. This raises a social question – Are we not now paying very dearly for the wrong emphasis we have placed on the mere acquisition of wealth no minding how it is acquired? After all the view of Criminology is that society prepares the crime and the criminal merely commits it. Do we not need urgently a reorientation and a transvaluation of our value system especially our view on money? That is the question for our society”.

27. Another factor that is responsible for corruption is what I can describe as politics without principles. I am sure that you all know that I borrowed the expression from Mahatma Ghandi, the famous Indian leader. Today, our politics is bereft of principles and ideologies. It is no longer about service but about self. It is no longer about social infrastructure but about stomach infrastructure. It is no longer about the common people but about the personal purse. In the first Republic, how many of us remember that being a parliamentarian was not a full-time occupation. All the parliamentarians had their professions. The parliament sat in the afternoon. But today, politics is a full-time profession.

28. An important factor we cannot gloss over is the fact that our religion appears to be without morals. It appears to me that the more religious centres we have, the less morality we espouse. Many of us today are product of missionary schools -both Christians and Muslims. I am glad that we are having this event in Ogbomoso. We are not strangers to the role the Baptist Missionaries played in the educational development of this ancient towns. Same thing for the Ansar-Ud-Deen and the Ahmadiyya. In those days, you could count the number of churches and mosques in a town. Now, it is impossible to count the number of religious houses in a single street. Why are we not asking questions? Why is it that the more religious centres we have, the less morality we have in the country? Why is that people who swear with the Holy Books at the time of taking oath of office fail to abide by the principles of these sacred books? Why is it that the opening and closing prayers which have become the norm at our every gathering have no effect on our morality? I will leave you to ponder over these questions.

29. Our educational system also played a less than salutary role in the current corruption quagmire we find ourselves. At independence, the emphasis was on character development as well as on educational qualification. They both go together. That’s the reason you will find that the motto of many schools of that time has elements of character and hard work embedded in it. For instance, the motto of the first secondary school in this town, Ogbomoso Grammar School which was established in 1952 was per adua ad astra which is Latin for Through struggles to the Stars. It is evident that the founding fathers of the institutions understood the fact that it was through hard work and struggles that we could be successful. 

30. In a book recently published to commemorate the 60th Anniversary of Aare Afe Babalola’s Call to the Bar, Chief Olusegun Obasanjo also identified education without character as a bane of our society. According to the former president: 

“At every stage, character matters in our interactions within the community…When we were growing up, a recurrent theme that was drummed into us was that ‘education without character is like tea without sugar’. In effect, your education amounts to nothing if you do not have values and virtues that the society cherishes and that uplifts the society in which you live.”

31. Distinguished Ladies and Gentlemen, now, it is time for chicken to come home to roost. If we are not going to mince words, we must admit that the legal profession is perceived as a corruption enabler in the country. That’s the truth, unless we don’t want to be sincere with ourselves. It is believed, rightly or wrongly, that the legal profession is a contributor to the challenges confronting us a nation. I am certain that we have all heard insinuations and innuendos about justice being for sale to the highest bidders. 

32. It might not be out of place, at this point, for all of us to take a moment to reflect about the case of Ugochukwu Uba v. C.N. Ukachukwu. It is a case that has been described as the story of corruption in the temple of justice. It has also been described by Chief Gani Fawehinmi as a case that struck at the very heart of the integrity of the Nigerian judiciary. Without belabouring you with the facts of the case which I am sure you are very familiar with, it was established that out of the three justices of the Court of Appeal that heard the case, two of them compromised their oath of office. 

33. In its report to the National Judicial Commission, the panel set up to hear the allegation against the judges concluded that: 

“The allegations against the two Court of Appeal Justices are very serious and sad. The evidence against the two Justices is so overwhelming. They put their integrity as Judicial Officers in great dispute. The three Justices of the Court of Appeal sat to hear appeals in Enugu; only one of them, the youngest, did the Judiciary proud. He is Justice K.B. Akaahs.” 

The two compromised judges, Justice Opene and Justice Adeniji were unceremoniously removed from office. Justice K.B. Akaahs – the incorruptible judge – ended up as a Justice of the Supreme Court.

34. I decided to use this case as an example of the fact that no matter how pervasive the issue of corruption is, we still have shining stars like my Lord Akaahs who would refuse to allow the sacred cloak of justice to be tainted with the tar of corruption. I am proud to identify with my Noble Lords present here this morning as people of indisputable integrity and unblemished records. 

35. It is of fundamental importance for all of us as members of the legal profession to bear in mind that our livelihood is dependent on the public perception of the utility of the service we render to the society. The reason we are able to earn a living is as a result of the fact that the society considers us relevant and useful. The singular reason every society places premium on the legal profession is because of the importance attached to the concept of justice. It follows that if justice disappears in a society, there will not be any need for legal practitioners again. Ladies and Gentlemen, I ask you, if there is no legal profession again, what are we going to do with our wigs and gowns?

36. It is becoming the trend, and a worrisome trend at that, for litigants and their lawyers to openly castigate the judiciary once a decision is not in their favour. We see our colleagues granting interviews on daily basis trying to cast aspersion on judicial officers. This is wrong and we must all be bold to condemn it. Who is going to speak for the judiciary? Are we not the one as members of the Bar who is expected to champion the cause of the judiciary? The truth is that castigating the judiciary in the media is going to do us more harm than good. We are all familiar with the Yoruba proverb that “obe n wole ara e, o ni ohun n ba ako je”. The judiciary, literally speaking, is our home. May God forbid that we should destroy our own home.

37. As officers in the temple of justice, it is our responsibility and obligation to always speak out for the Bench. When we speak up to defend the judiciary, what we are doing is that we are encouraging the Bench to be more forthright and more proactive in the discharge of their duty. We should eschew the practice of throwing our judges under the bus once a decision is not in the favour of our clients. In the words of my Lord Justice Dahiru Musdapher: 

“Public confidence in the judge and the judicial system reinforces conviction for the attainment of justice and thereby enhances the willingness of the populace to subjugate themselves before the land.”

38. Distinguished Ladies and Gentlemen, I hope I am not being understood to be saying that we should be docile and keep quiet in the face of established corruption in the profession. No, that’s not what I am saying. The point I am articulating is that we should follow established procedure in ventilating our grievances against perceived injustice in respect of our case. Addressing the social media is certainly not one of the appropriate procedures that I am aware of. 

39. We must also ensure that the allegations, if any, are not baseless. We are professionals and we must ensure that we do not allow our clients to push us to lose our wigs and gowns for their own selfish purpose. That’s exactly what happened in the case of NBA v. Moses Odiri and Chief Andrew Oru. In that case, the LPDC found that: 

“the press statement of the respondents published in the media, the letter written to the President, Commander-in-Chief, and the letter to the Inspector-General of Police, accusing the Chief Justice ofNigeria and Justices of the Supreme Court of bribery of N5 billion and £3.5 million as improper way of addressing   their grievances if any. They cannot claim ignorance of the appropriate authority to whom such complaint ought to go. Indeed, the 2nd respondent admitted before us that complaint against judicial officers no matter the office occupied by the officer, is the National Judicial Council.”

40. In recommending that the names of the counsel be struck off the roll, the LPDC stated that: 

“To accuse a judge of corruption is a very grave allegation; an allegation which goes to the foundation of justice, and   justice, they say is rooted in confidence. An accusation of corruption against the Chief Justice of Nigeria and Justice of the Supreme Court in national newspapers have the effect of exposing the judiciary in Nigeria to the whole world and it all goes to public perception of Nigerian judiciary and the confidence of the common man in the system. It was Justice Frank that opined that the courts’ authority– possessed of neither the purse nor the sword – ultimately rest on sustained public confidence in its moral sanction.”

41. However, we should note that some of our judicial officers too have lost decorum of their offices. They have desecrated our judicial temples with their unbecoming attitudes. It is not uncommon these days to meet judges at loud parties. It has also been said that some judges are marrying accused persons standing trials before them and some are hobnobbing openly with politicians. The good news is that the National Judicial Council is resolved to deal with this menace and embarrassment to keep the sanctity of our judicial temples in order to sanitize and save the judiciary.

The Way Forward

42. A common saying in this part of the world is ‘to whom much is given, much is expected’. I believe that we have not really given much to the judicial sector for us to be expecting much from the judiciary. Over the years, the judiciary has continued to be treated as a mere appendage of the government. When we talk of government, the tendency is for us to synonymise government with the executive. In other words, the judiciary is treated as an afterthought. This, in my view, is contrary to the vision of the drafters of the Constitution of the Federal Republic of Nigeria.

43. We are all familiar with the provision of section 17(2)(e) of the Constitution which provides that: “the independence, impartiality and integrity of courts of law, and easy accessibility thereto shall be secured and maintained.” The fundamental question is: what are we doing to secure and maintain the independence, impartiality and integrity of our courts of law? In my view, the starting point in this regard is the welfare of our judges. If we truly want to insulate our judiciary from corruption and from corrupt practices, we must strive to raise the bar of the welfare of our judicial officers and administrative members of staff of the judiciary. 

44.   The welfare of the administrative members of staff is equally important. What is good for the goose is equally good for the gander. If the administrative staff are also well taken care of in terms of remuneration, housing, health and fantastic allowances, they may not be lured into corruptive tendencies by unscrupulous litigants. This in turn, would assist the administration of justice in the country.

45. In the past few months, we have heard many instances of our revered Lordships dying prematurely in office. The truth is that our judges work hard under inclement conditions. The job of a judge is a thankless job. They sit for long hours listening to parties in the court. After the day’s proceedings, they retire to their chambers to continue sitting to write rulings and judgments. In effect, our judges spend hours after hours in their courts and in their chambers. The least we can do for them is to ensure that they are able to work in reasonable comfort. We must therefore stop playing lip services to the issue of welfare of judges. Their health, their mobility, their accommodation, and their comfort must be a matter of priority. 

46. For us legal practitioners, we must uphold the ethics of our profession. We must ensure that anti-corruption becomes a code of conduct we all subscribe to and a badge of honour we are all proud to wear. As ministers in the temple of Justice, the professional conducts of our members must be above board at all times in line with our aim and objective that the NBA shall maintain the highest standards of professional conduct, etiquette and discipline.  In all we do, we should be guided by our professional and ethical commitment to ensure that Nigeria becomes a model nation in enthroning anti-corruption architecture we are all proud of. 

47. It is my view that if there is a profession that is poised to play a fundamental role in our quest for good governance, it is the legal profession to which all of us belong to as members of the Bar and the Bench. We must bear in mind the timeless words of the pioneer of the Nigerian Bar, Christopher Sapara Williams to the effect that: 

The legal practitioner lives for the direction of his people and the advancement of the cause of his country.”

48. Ladies and Gentlemen, I must again challenge the Mrs. Olatubosun-led administration to ensure that the Bench and the Bar Forum is invigorated. The Bar must work with the Bench because we are both Siamese twins. We must remember the words of the former Chief Judge of Kogi State, my Lord Justice Umari Eri to the effect that:

“Legal practitioners in particular constitute a very vital pillar upon which the judiciary is built. They constitute in many cases, the eyes, hands and mouth that speak for judiciary. Lawyers constitute the first point of contact and   the link between the members of the public and the judiciary. Their public utterances, on the judges, the judiciary and the administration of justice have deep impact on the psyche of the ordinary person.”

49. It also needs to be pointed out that the war against corruption is not a solo effort. If we are going to eradicate corruption, it is going to require a synergy of all of us working together to decimate corruption and its tentacles. The responsibility for its annihilation is therefore not limited to anti-corruption agencies or the judiciary alone. The cornerstone of the anti-corruption architecture is a functional legal framework which ensures that corrupt practices are not only prohibited but are discouraged and penalised. It is therefore our joint responsibility and we all have a role to play in this regard. NBA Ogbomoso Branch should be able to work with your Senator and your Members of the House of Representatives to develop legislative bills that will further enhance the war against corruption. 

50. I must not conclude this address without advocating for mentorship of the younger ones. One of the challenges confronting our youths today is absence of role models. The only available mentors for them are the yahoo-yahoo boys, the reality stars, and social media celebrities. What has happened is that we have vacated our leadership roles in the society, and we have therefore created a vacuum. As you are aware, nature abhors vacuum. We need to work with the relevant educational departments to introduce mentorship scheme in our schools and institutions of higher learning. We must ensure that these young people see us as veritable role models they can aspire to follow. It is important to change their mentality from ‘education na scam’ to ‘education no be scam’.

Conclusion

51. Distinguished Ladies and Gentlemen, I need to restate the fact that it appears to me that annual law week being organised yearly by branches of the Nigerian Bar Association is fast turning to just another routine programme. If care is not taken, it could become but another avenue to waste scarce resources of the association, year in, year out. It is my hope that the Ogbomoso Bar will ensure that its Law Week is not just another week but a veritable platform to uphold the rule of law, improve citizens access to justice, enhance the welfare of the Bench, and generally advance the prosperity of the members of the Association.

52. Before I conclude this address, I consider it relevant to mention, even briefly, one interesting case of corruption handled by my Lord, Justice Atilade Ojo more than 20 years ago. I am bringing up the case to illustrate the fact that these trending cases of what is popularly known as ‘yahoo yahoo’ did not start today. Corruption is also not limited to public service alone. It is my view that every incident of false pretences is an act of corruption.

53. In that case, a civil servant was sent to deposit money into the government’s bank account [That was before the era of electronic money transfer]. On the way, she met some people who told her that they needed to get some chemical to develop some films [photographs] of Jesus Christ. In a nutshell, the young lady was swindled of the money in her possession.

54. I am mentioning the case because of the many lessons inherent in it. In the first place, it shows His Lordship as a very brilliant and painstaking jurist. His Lordship discovered that one of the charges against the accused persons was defective, it was therefore struck out. This underscores the need for legal practitioners to be diligent in the preparation of their cases. Often times, when the public castigates the judiciary for not giving judgment in a particular direction, what they do not know is that a judge can only decide cases based on the facts placed before the Court. 

55. The case is also illustrative of the fact that people appointed to the Bench must be brilliant and have cognate litigation experience. The Defendant’s counsel, in that case, tendered a document through a Prosecution witness which was then admitted in evidence. Strangely, the same Counsel turned around to argue that the document was inadmissible and should be rejected! Justice Atilade Ojo saw through the legal gimmick and held, rightly in my view that: “It is trite that where a document or evidence is admitted at the instance of a party, it is not proper to allow the party to challenge its admission.” I enjoin all of us to find time to read the judgment which can be found online.

56. The judgment, once again, confirms my Lord as a cerebral jurist. I hope that efforts have been made to compile all judgments delivered by my Lord whilst on the Bench. It is a task that will greatly enrich our jurisprudence and for which posterity will forever be grateful. If we have done it, kudos to us. However, if we are yet to do it, the NBA Ogbomoso Branch must take it as an urgent assignment. I am willing to be part of the editorial team.

57. In peroration, Ladies and Gentlemen, we have our tasks cut out for us. As legal practitioners, we have a calling to ensure that we do not drop the baton in our fight against corruption. The challenge is daunting, the battle is fierce, and the resources available are limited, but one thing is certain, we cannot afford not to win the war against corruption. 

Thank you.

Dr. M.N.O. Olopade, SAN, FCArb


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