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A Comparative Analysis Of The Enforcement Of Foreign Judgment In Nigeria And United Kingdom: A Case For Cyber Jurisdiction
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A COMPARATIVE ANALYSIS OF THE ENFORCEMENT OF FOREIGN JUDGMENT IN NIGERIA AND UNITED KINGDOM: A CASE FOR CYBER JURISDICTION
1.1 BACKGROUND OF THE STUDY
A wise saying has it that, no man is an island, hence human interaction becomes necessary. The dynamic nature of this social interaction being what is occasionally brings about disputes or disagreements. To mend these disputes or disagreements, civilized societies in a bid to make life meaningful put some instruments in place. One of such instruments is law. By the instrumentality of law, an aggrieved party normally goes to court of competent jurisdiction2 seeking for redress. One of the duties of court in this circumstance is to make order or declaration as per the rights and the duties of the parties involved.
The matter does not however end with the court pronouncing its judgment, recognition and enforcement of the court‟s judgment are the next procedures. Apart from declaratory judgments that are not enforceable, other forms of judgment8 may need some form of compliance or the other in order to be realized. Otherwise, the successful litigant, called the judgment creditor, may have secured a pyrrhic victory.
If the party against whom judgment is given, called the judgment debtor willingly complies with the terms of the judgment, there will be no problem. But more often than not, the judgment debtor does not willingly comply with the terms of the judgment. Thus, there arises the need to compel him to do so through execution or enforcement procedure. This conforms to the general principle of law that judgment or order of the court must as far as possible be obeyed or complied with. Otherwise the authority of the court would be diminished and the legal order would suffer a breakdown.
Again, if the enforcement or execution is to be carried out, in the jurisdiction or country in which the judgment is given, no much problem would arise. But a much more challenging circumstance showcases itself where the judgment creditor only after his success in the case realizes that, the fruit of his labour has to be satisfied abroad.
The question is, can judgment given by the court of one country be enforced by the court of another? This necessitates the study of feasibility of enforcing foreign judgment. Enforcement of foreign judgment is not a new phenomenon. It has long existed as a topic in the sphere of private international law. Besides the Rule of Common law, it is regulated by bilateral treaties or multilateral international conventions. This area of the law has gained prominence, at least of late, because of the advent of the internet and the age of globalization. Increase in cross border business transactions would naturally cause an upshot in litigation. This in turn would require national or municipal courts to decide whether a judgment or order obtained in a foreign country should be recognized or allowed to be enforced in their own country.
In Nigeria and the United Kingdom, it is well settled under both the common law and statutes that the foreign judgment sought to be enforced must satisfy certain requirements as precondition to its enforcement or recognition. The most essential of all the requirements for recognizing or enforcing foreign judgment is that the foreign court which rendered the judgment sought to be enforced is one of competent jurisdiction in the international sense.
Underscoring the importance of jurisdiction as a condition precedent to recognition and enforcement procedure, a writer states thus:
“In general, recognition or enforcement of foreign judgments may not be allowed if the foreign court acted without competent jurisdiction or if the defendant can avail himself of any of the limited number of defenses available”
1.2 STATEMENT OF RESEARCH PROBLEM
Enforcement of foreign judgment has significant relevance in this era of increased international trade and foreign investment. Businessmen are more comfortable doing business with foreign partners knowing that if they obtain judgment from superior court in their home country; it can be enforced against the judgment debtor across borders.
This is what actually gave rise to conflict of laws as a course or private international law which is aim at making case for the enforcement of judgments obtain from one country in t another. The two counties that are the case study of this research work (Nigeria and the United Kingdom) have conditions or requirements a judgment must satisfy before its enforcement and the procedure of so doing which fall on all fours.
It has been well settled that by international laws of the two countries that a judgment given by a court of one country may not be capable of recognition or enforcement in another, except if the court that gave the judgment is one of competent jurisdiction in international sense. Once jurisdiction is lacking, the judgment becomes nullity
Today the bulk of transactions are conducted online and breaches are occasioned from these transactions which may necessitates going to court. Hence, the concept of cyber – jurisdiction emerges. Cyber – jurisdiction unlike the ordinary territorial jurisdiction is placeless.
The above facts made the two scenarios fall apart, such that what suits one cannot certainly suit the other. Consequently, some scholars see the regime of online transaction as an end to recognition and enforcement of foreign judgment. This skepticism is thought provoking that makes one to wonder whether these online transactions are not regulated by law such that breaches there from cannot be enforced.
The statement of problem of this research work is that, the traditional jurisdictional principle in Nigeria and the United Kingdom that is geographically based cannot suit the cyberspace scenario which is placeless and disrespects geographical boundaries. Thus, there is no agreement on when can a foreign court be of competent jurisdiction to entertain an online matter capable of recognition and enforcement in another country.
1.3 AIM AND OBJECTIVES OF THE RESEARCH
The aim of this research work is to discuss the extant laws regulating recognition and enforcement of foreign judgments in Nigeria and the United Kingdom and since jurisdiction is the most important requirement for the recognition and enforcement of foreign judgment the research work looks at the relationship between recognition and enforcement of foreign judgment and cyber – jurisdiction as well as exploring the possible ways of addressing the challenge that cyber jurisdiction poses to recognition and enforcement. In particular, the research work aims at achieving the following objectives:
- To make a comparative analysis of the requirements and procedure for recognition and enforcement of foreign judgment in Nigeria and United Kingdom.
- To critically explore how the challenge that the cyberspace poses to enforcement of foreign judgments could best be addressed so that internet users can transact with peace of mind.
- To explore the possible relationship between the requirement for enforcement of foreign judgment and cyber-space.
1.4 JUSTIFICATION OF RESEARCH
As rightly pointed out above, no man can happily live in isolation. Therefore, interaction among people both at national and international level becomes inevitable. Today, technology has made this interaction easier, sometimes by a mere click of a computer mouse.
Sadly as it may sound, disputes are bound to arise from time to time owing to the dynamic nature of life. Absence of any mechanism to address the likely disputes may extinct online international transaction for the fear of likely beach of commercial relationship and other civil wrongs which may go unenforced.
This research work is therefore justified, because is targeted at ascertaining the competence of one of these redressing mechanisms that is, the court to decide over these disputes involving foreign elements (foreign element means foreign law or a foreigner) from online transactions, as well as the procedure to be followed in realizing the fruits of the litigant‟s labour and the likely defenses that can be raised thereto.
This will infuse life into this dying area of the law and instills confidence in the minds of foreigners (Nigeria and British citizens) to transact online freely knowing that for every breach there is a corresponding remedy.
1.5 SCOPE OF THE RESEARCH
The scope of this research work is basically Nigeria and the United Kingdom. Attention is placed particularly on the common law principles as they apply to these countries on the topic under consideration. The respective statutes of these two countries that is, Foreign Judgment (Reciprocal Enforcement) Acts of each and other related statutes are also examined with respect to the conditions and procedures of enforcement of foreign judgments as well as the position of cyber-jurisdiction.
1.6 RESEARCH METHODOLOGY
In carrying out this research, information were collected for an in depth analysis through doctrinal method of research that is through reading of books and other written materials such as statutes, cases, articles among others. Recourse was also be made to information stored online (the use of internet facility).
Information is collated form these sources for in-depth analysis with a view to finding out the present position of the law and possible contribution to expand the frontier of knowledge in this regard.
1.7 LITERATURE REVIEW
Recognition and enforcement of judgment is an aspect of private international law that attracted the attention of virtually all the renowned authors on the subject. Some authors have despite sporadic reference to recognition and enforcement of foreign judgment in various chapters also devoted a full chapter to it in their respective books. Perhaps because it is a prime topic, the whole mark of all private international proceedings. Under this head, a number of these books and other available literatures were reviewed to see especially their contributions on the aspect and the need for improvements.
Dicey and Morris, in their book, discussed extensively the requirements and procedure of recognition and enforcement of judgment involving foreign element both under the common law and statutes as they apply to cases in or out of England and the rest of the world. However, the book did not make any attempt to address the recent issue of cyber-jurisdiction and the challenge it poses to recognition and enforcement of foreign judgments. They did not discuss post registration procedure and their discussion on defenses was scanty. Again, the work has not specifically related to the situation obtained in Nigeria.
Amba Myss is an English writer. Although he discussed synoptically the applicable laws regulating jurisdiction, recognition and enforcement of judgment, he did not however dwell on defenses. Cyber-jurisdiction also falls outside the scope of his work.
Cheshire and North, took pain to discuss extensively the principles of jurisdiction as prerequisite to a valid judgment capable of recognition or enforcement under different heads namely, jurisdiction in personam22 and jurisdiction in rem under both common law and statutes. They further discussed limitations to those jurisdictional principles, and the defenses that can be raised against recognition or enforcement of foreign judgment. Like other writers, they did not discuss cyber-jurisdiction. Their work did not equally capture the recent trends on recognition or enforcement procedures, both forming the basis of this work.
Agbede is one of the renowned authors in this area of law in Nigeria. His work substantially reflects the relevant laws applicable in Nigeria. He discussed choice of jurisdiction or inter-state situation, as well as jurisdiction in rem and in personam.
His discussion on the topic under consideration that is recognition and enforcement was minimal as he discussed only jurisdiction under the common law and statutes as a basis of recognition and enforcement of judgment. He did not have cyber-jurisdiction in contemplation, neither did he discussed defences against enforcement.
Kera, F. A.,25 this is a work that substantially goes close to the topic under study. The writer dealt with the issue of jurisdiction and recognition as well as the enforcement requirements. The writer recommends for further study on cyber jurisdiction. This forms the  basis of this research work. This research is going to make immense contribution on this recent aspect thereby upgrading the frontier of knowledge in this regard.
Linus, A. H. highlighted the threats that e-commerce is facing as a result of inadequate checkmating mechanisms such as inadequate regulatory framework that is legislations, equipped courts that are properly manned by Judges vast in the workings of computer technology or the internet. As the title of his articles says, the writer addresses only the crimes militating the flourishing of e-commerce especially in Nigeria and the United Kingdom and the need for proactive measures to curb this menace.
Oba, C. O. devoted her article to two aspects of enforcement of foreign judgments only in Nigeria. The first is the powers conferred on the Attorney General and Minister of Justice to make an order stating the countries with which Nigeria has reciprocal arrangements. The second is with the conditions for the registration of a foreign judgment particularly on the conferment of jurisdiction on the original court by the voluntary appearance of the defendant.
The writer urged for pro-activeness by the Minister to exercise the powers vested on him by S.3 of the Foreign Judgment (Reciprocal Enforcement) Act.28 And the need for amending the provision of S.6(2)(a)(ii) both with a view to laying a good ground for promoting foreign investments in Nigeria.
Ekpeyong, E.  commences his discussion on the subject by stressing the importance of foreign judgment in an era of increase trade and foreign investment. Businessmen are more comfortable doing business with foreigners knowing that if they obtain judgment from a superior court in their home country; it can be enforced against the judgment debtor across borders.
He called for pro activeness on the part of the minister to give effect to the provision of section 3 of the Foreign Judgment (Reciprocal Enforcement) Act mandating him to extend the provisions of the Act to certain countries as a condition to the applicability of the Act. He submits the failure of the minister so act throws uncertainty in trans-border businesses in Nigeria.
He also called for the review of the section of the Act prohibiting the enforcement of judgments on taxes or other penalties of a like nature. Insisting that review the provision highlights the importance of cross border tax collection. Nigeria will gain more if it offers herself and other states the opportunity to recover fines, taxes and penalties against evading offenders by either amending her foreign judgment statutes to accord foreign judgment on fines, taxes and penalties the same status with monetary judgments or enter into bilateral multilateral treaties with other states to assist themselves on cross border fines, taxes and penalties.
Globe, S. in his article discussed the procedure for registration of foreign judgment in England. By English law, judgments coming into England from any of the European country is enforced on a particular rule of procedure called European Judgment – Regulation (EU) 12/5/12 of the European Parliament and of the Council of 12, December,2012 on Jurisdiction, Recognition and Enforcement of Judgments in Civil and Commercial Matters (Brussels Regulation).
While judgments of Commonwealth states and states with which England has a bilateral treaty are enforced through different sets of laws. He went further to discuss requirements of enforcing these judgments both under those statutes and common law.
Olaniyan, A. H. reviewed the judicial and legislative approaches of Nigeria to discretionary jurisdiction over foreign causes. He criticized the writ rule which permits suits to be maintained against person who has no other connection with Nigerian forum apart from their transient present here. He submits that, the rule makes it easy for a vindictive plaintiff to seek justice mixed with embracement against a helpless defendant. He discussed the three grounds upon which a court may decline to assume jurisdiction at common law under the writ rule which is otherwise mandatory. The grounds could be any of the followings; the ground of a successful plea of forum non-convenience, the ground of a contractual ouster of court jurisdiction and upon a successful plea of lis alibi pendes.
His discussion on the topic is limited to only personal jurisdiction as a basis to recognition and enforcement of foreign judgments leaving out other requirements to recognition and enforcement of foreign judgments which is intended to be covered by this research work.
Omoaka, G. wrote on the legal regime for the enforcement of foreign judgments in Nigeria. Therein, he noted the fact that in Nigeria there are two legislations regulating the foreign judgments that are meant to be enforced in Nigeria. He also noted the fact that, there is confusion as to which of these legislations is applicable or the two legislations are applicable at the same time.
He discussed the conditions that a foreign judgment seeking enforcement in Nigeria must satisfy. Such conditions include the fact that, the judgment must be final and conclusive between the parties thereto, it must be a judgment for a definite sum of money in favour of a successful party and the judgment was delivered by a court of competent jurisdiction. He made emphasis on the importance of jurisdictional requirement. He discussed the requirements of assuming personal jurisdiction over a foreign defendant. He also stated the requirements of assuming jurisdiction on foreign properties, both movables and immovable.
He rounded up his discussion on the subject by discussing the defences a defendant can raise against enforcement of a foreign judgment. If such defence is successful no enforcement can be executed against him and the judgment becomes a nullity.
Wallace, P. titled his article, the Enforcement of Foreign Judgment under Nigerian Laws. While discussing this tittle, the author focuses on his attention on the following major subheads: Enforcement of Foreign Judgments under the Ordinance wherein the author stated the countries or colonies to which the Nigerian Ordinance on the subject applies. In the next subhead, the author noted that in the Ordinance the period within which an application for registration should be made is 12 months after the date of the judgment or such longer period as the court may permit. The succeeding sub-head is about the fact that the Ordinance comes into play only when the judgment seeking enforcement is a monetary judgment on a definite sum.
The author discussed g rounds of refusing to enforce the judgment under the Ordinance. He stated the provisions of section 3(2)35 which provides for such grounds. He concluded his discussion under the Ordinance by highlighting the unfortunate consequences of section 3 (2),(b) as demonstrated by the case of Grosvenor Casinos Ltd vs. GhassanHoloui.
The second part of his discussion was on the 1961 Act and its provision as another legislation regulating the subject matter in Nigeria. The discussion of this part is in the same order the author discusses the provisions of the Ordinance above. The author did not however make the English provision equivalent to what is obtained in both the Ordinance and the Act the scope of his work.
Gbenga, B. centers his discussion on the uncertain features of the Nigerian legislation on foreign judgment enforcement procedure that require utmost caution (ex abundaticautela) whenever a foreign judgment is sought to be enforced in Nigeria. He argued that, the uncertainty stems from the failure or negligence of the Attorney General and Minister of Justice to give effect to the provision of section 3 of the Foreign Judgment (Reciprocal Enforcement) Act39 that mandates him to designate countries to which part one of the Act applies. This failure or negligence of the Hon. Minister to so act leads to contradictory and conflicting decisions even by the Supreme Court hence the need for serious caution by any person seeking to register foreign judgment for enforcement in Nigeria.
His discussion centers squarely on the statutory provisions on enforcing foreign judgment in Nigeria without making reference to the provision of common law on the matter. He did not equally consider the provisions of other countries like the United Kingdom on the matter.
Paige, B.R. undertook comparative study on foreign judgment enforcement procedure between the England and the United States of America. He commenced by examining the applicable laws in this regard. He noted the fact that unlike the United States, the England has up to five legislations regulating the enforcement foreign judgment procedure defending on which part of the world the judgment is coming from. The United States has no federal legislation on the subject leaving each state to enact its own. However there is an ongoing effort in the United States to produce a federal legislation applicable across the whole of the country. In addition to the use of legislations, the two countries also use common law rules though differently. He submitted that, the procedure is more simple and comprehensive in England than in the United States.
The author‟s comparison was between the England and the United States which does not include Nigeria. Determination of jurisdiction in the cyberspace as a condition to producing a valid judgment cable of enforcement abroad was not part his discussion.
Tony, A.I. authored book titled, Recognition and Enforcement of Foreign Judgments in Nigeria. The book consist of ten chapters wherein he discussed the theories of recognition and enforcement of foreign judgments and the conditions thereto both under common law and statutes. While discussing the statutory provisions applicable in Nigeria, he took pain to look at the relationship between the Foreign Judgment (Reciprocal Enforcement) Acts of 1958 and 1961 . He discussed the defences that a judgment debtor can raise against judgment sought to be enforced upon him before finally addressing the issue of enforcing arbitral awards.
Brook, C. devotes attention to discussing the enforcement of foreign judgments in the United Kingdom. In so doing, her book looks at the eight ways a foreign judgment creditor can follow to enforce his victory in England depending on which part of the world he is coming from. The first is when the judgment to be enforced is coming into England and Wales from another part of the United Kingdom. The second is when the judgment to be enforced is coming into England and Wales from another part of the European Union. The third is when the judgment to be enforced is coming into England and Wales from another country with which England and Wales have a reciprocal treaty. The fourth is when the judgment to be enforced is coming into England and Wales from another country with which England and Wales have no reciprocal treaty. The fifth is when the judgment to be enforced is an outgoing judgment from England and Wales to another part of the United Kingdom. The sixth is when the judgment to be enforced is an outgoing judgment from England and Wales to another country within the European Union. The seventh is when the judgment to be enforced is an outgoing judgment from England and Wales to another with which England and Wales have reciprocal treaty. The eighth is when the judgment to be enforced is an outgoing judgment from England and Wales to another country with which England and Wales have no reciprocal treaty.
Graveson, R. H. is one of the early authors on the subject. In his book, he discussed virtually all the major topics of private international law or the conflict of laws. The other authors, enforcement of foreign judgments and arbitral awards form the last part of his book. While discussing enforcement of foreign judgment, the author submitted that, judgment can be enforced in two ways to wit, by action and registration. He went ahead to discuss the requirements and procedure of going about each of them.
Like virtually all other write his book did not discuss cyber jurisdiction as a condition precedent to enforcing judgments emanating from online transactions. It may be because the book free dates the use of internet.
This research work intends to carry further the mission of the above writers with a view to promoting foreign investment which today forms substantial portion of commerce and investment globally. This is only possible when the international business community feel safe to use the cyberspace in addition to or as an alternative to the physical space by addressing the need for recognizing and enforcing online transactions.
1.8 ORGANIZATIONAL LAYOUT
Chapter one of this work, introduces generally the topic of the research, the problem that the research wishes to address which are not largely taken care of by other authors. The works of those authors were reviewed to find out the areas they were silent on or no much emphasis was made. The methodology of conducting this research work is also stated.
Chapter two makes effort to clarify the key terms that make up the topic of this research work in order to aid the reader to appreciate what the topic stands for and what it seeks to achieve. Terms like the concept of foreign judgments, enforcement of foreign judgments and concept of jurisdiction as well as cyber-jurisdiction of court are clarified. In making these clarifications, the chapter makes reference to the provisions of the common law, the statutes of the two countries that are the case study of this research work and respective courts pronouncements.
Chapter three is all about the conditions and procedures to recognition and enforcement of foreign judgments coming from United Kingdom to Nigeria or out of Nigeria to the United Kingdom both under the common law and statutes (reciprocal treaties). It draws a distinction between what recognition of foreign judgment is from its enforcement. What is effect of the registering a judgment for enforcement under statutes and the post registration procedures are all examined. The chapter concludes by reviewing the limited number of defences available to the judgment debtor against enforcement of a foreign judgment. If the defense succeeds, the judgment becomes unenforceable.
Chapter four examines the models develop on determining when can a court be competent to preside over matters coming from online transactions. The models are considered under heads like, the use of long arm statutes, and the use of case law for personal jurisdiction. A review of the cases decided using the models so far was also made.
Chapter five concludes the research work. Here, a summary of the whole work is made and thereafter findings are stated and recommendationsare put forward.
 Law is defined as “the whole prescriptive and authoritative rules of human conduct regarded as binding and made or consented to by the state, the breach of which sanction is imposed”. See Suleiman, I. N. (1996) TheNigerian Law Dictionary 1st ed. p. 193 2
Jurisdiction is defined as “a power of a court to judge a particular case”. See Azinge, E. (2005) Jurisdiction And Cyber Law Practice. In: Azinge E. (Ed.) Jurisprudence of JurisdictionOliz Publisher, Abuja, Nigeria p.562
 SS. 6(6)(b), 36(1) of the Constitution of the Federal Republic of Nigeria 1999 ( as Amended)
 The Supreme Court of Nigeria defined judgment in Saraki vs. Katoye (1992) 9 NWLR (Pt. 264) 156 as a binding, authentic, official and judicial determination of the court in respect of claims and in an action before it.
 Recognition means confirmation that on act done by another person was authorized and it is also formal admission that a person, entity or thing has a particular status. See Tony, A.I. (2011) Recognition and Enforcement of Foreign Judgments in Nigeria, Innovative Communication Lagos, p.16.
 Means, the act of giving effect to the court’s judgment or orders. See Olojede vs. Olaleye (2010) 4 NWLR (Pt. 1183) 18 C. A.
 Ibid 8
For example, Executory judgments. Executory judgment simply means, the judgment that declares the respective rights and obligations of the parties and then proceeds to order the defendant to act or omit to act. Ibid
 Babalola, Afe (2003) Enforcement of Judgment, 1sted, Inter Printers Ltd, p. 1
 For example, Foreign Judgment (Reciprocal Enforcement) Act Cap F35 L.F.N. 2004 and Foreign Judgment (Reciprocal Enforcement) Act 1933 of the United Kingdom.
 European Union Convention on Jurisdiction and Enforcement of Judgments in Civil and Commercial Matters 1968 (Brussels Convention)
 Foreign Judgment (Reciprocal Enforcement) Act Cap F35 L.F.N. 2004 and the Foreign Judgment (Reciprocal Enforcement) Act 1933
 Jurisdiction as a fundamental requirement to recognition and enforcement of foreign judgment is fully discussed in the whole of chapter three infra
 AmbaMyss (1997) Conflict of Laws, (Lecture Notes). Butterworth, London p. 98
 Discussion on such other defenses to is in Chapter three
 Teleglob America Inc. vs. Century, (2008) 17 NWLR (pt 1115) at p.116
 Dicey and Moris, (2000) The Conflict of Laws. Sweet and Maxwell Ltd, London, preface ph.3
 It is a term used to describe the power of the court to entertain legal issues relating to the use of communication, particularly “cyberspace” i.e., the internet. See Scout, B. C. (2010) Law in the Cyberspace.
Accessed on 02 April, 2011 from http://slideshow.net/ihsh/cyberlow
 Op.cit p.
 Cheshire, G. C. and North, P. M. (1999) Private International Law. Oxford University Press, U.K. 22 Discussed in chapter two infra
 Discussed in chapter two infra
 Agbede, I. O. (1989) Themes on Conflict of Laws, Sheneson Ltd Lagos
 Farida, A. K. (2009) Recognition and Enforcement of Foreign Judgment under Private International Law.
Unpublished LL.M. Thesis Faculty of Law, ABU Zaria
 Linus, A. H. (2006/2007) “Business Alert: Cybernetic Crimes, A Threat to Global Commercial Transactions”.
Ahmadu Bello University Journal of Commercial Law, Faith Printers, Zaria
 Oba, C. O. (2011)” The Legal Regime for the Enforcement of Foreign Judgments in Nigeria: A Promotion or
Impediment to Foreign Investments”? In: Adoke, M. B. (Ed) The Justice Journal, Federal Ministry of Justice, Abuja 28 Cap F35 L.F.N. 2004
 Ekpeyong, E. (2014) Nigeria: An Appraisal of Challenges of Enforcing Foreign Judgments in Nigeria. Retrieved July
 ,2015fromwww.mondaq.com/Nigeria/x/322886/international+trade+investment/an+appraisal+of+challenge+of +foreign+judgments+in+Nigeria. At 2:00pm
 Olaniyan, A. H. (2012) A Review Of Judicial And Legislative Approaches Of Nigeria To Discretionary Jurisdiction
Over Foreign Causes. International Jouranal of Business and Social Sciences. Vol. 3 N0.12 pp. 204-217
 Omoaka, G. (2004) Nigeria: Legal Regime for the Enforcement of Foreign Judgments in Nigeria. Retrieved July 26, 2015 from www.templar-law.com/media/publications/enforcementofforeignjudgment.
 Wallace, PS. (2014) Enforcement of Foreign Judgment Under Nigerian Law. Retrieved from www.elexica.com/servicse/ceratesinglepdf.ashx?url=/en/legal-topics/dispute-resolution-commercial/25enforcement-of-foreign-judgments-under-nigeria-law&name=enforcement-of-foreign-judgment-under-nigerialaw. At 3:0pm
 Cap. 175 Laws of the Federation and Lagos, 1958.
 (2009) 10 NWLR (pt 1149) 309 26.
 Cap. F35 L.F.N. 2004.
 Gbenga, B. (2014) Enforcing Foreign Judgments in Nigeria: Truly ‘ex-abundaticautela’. Retrieved July 26, 2015 from www.nigerianvillegesquire.com/articles/enforcing_foreign_judgment_in_nigeria_ex-abundati _cautela.html 39 Cap. F35 L.F.N. 2004.
 Paige, B.R. Foreign Judgment In America and England Courts: Comparative Analysis. Retrieved July 26,2015 from www.digitalscommons.law.seattleu.edu/cgi/viewcontent.cgi/articles=1757&content=sulr.
 Tony, A.I. Op.cit
 Cap. 175 Laws of the Federation and Lagos 1958; Cap.F35 L.F.N. 2004
 Brook, C. (2007) Enforcement of a Judgment. Thomas Sweet and Maxwell Ltd. London.
 Graveson, R. H. (1969) The Conflict of Laws London, Sweet and Maxwell.