Onagoruwa v. IGP [1991] 5 NWLR (Pt. 193) 593 at 650-651, per Tobi, JCA (as he then was, and now of blessed memory):

“In these days of racing inflation where the buying and purchasing power of the Naira falls drastically (and painfully so) every day and therefore not commensurate to the quality and quantity of goods bought, a Judge should in the assessment of damages consider the current market situation. It will be most unrealistic to ignore this fundamental aspect and merely theorise with principles of law and facts and figures presented to him in court by counsel and witnesses. While the Judge is not expected to play the role of a housewife of Sangross Market, Lagos, Kasuwa Kurimi Market of Kano or the Ogbete Market of Enugu by sampling prices of goods randomly,  he must always remind himself that market prices escalate by leaps and bounds and they affect the purchasing power of the Naira.”


This is a good observation and represents good and forward thinking. The Court is commended.

Relying on the above pronouncement, the Court of Appeal, per Salami, JCA, in Usman v. Abubakar [2001] 12 NWLR (Pt. 728) at 710, paras. D-E, remarked:

“The economic reality of today is that the Naira is a ghost or shadow of its old self. The value of the Naira in 1993 when the property was destroyed was about N5.00 to a Dollar. Today the Naira has so badly shrunk or slumped to one Dollar changing for about N110.00. Its purchasing power should constitute relevant factor in the appropriate cases especially so when evidence is led as to the deplorable decline in the exchange rate or purchasing power of the Naira.”

The Court also relied on the Supreme Court case of Allied Bank v. Akubueze [1997] 6 NWLR (Pt. 509) 374.

Sadly, the Naira has known nothing but consistent drop in value. Tobi, JCA (later JSC and of blessed memory) in Onagoruwa’s case described the condition of the Naira as far back as the early 90s thus:

“The Naira is no longer a stable and enduring currency.  It floats in the money market adversely. It also floats in the Nigerian wind not because of its physical lightness but because of its loss of monetary value. After all, the Naira is now one heavy coin.”

Our courts should of necessity always be mindful of the value of the Naira in awarding damages. This however does not imply that a successful party in a suit should be awarded a windfall. See Emirate Airline v. Ngonadi (No. 2) [2014] 9 NWLR (Pt. 1413) 506 also cited in our previous post.

Introducing Law Practice as a Business

Dear friends, I’m happy to announce the publication of my latest book, Law Practice as a Business

Law Practice as a Business discusses a critical aspect of law-practice business—the business of making money in legal practice. It shares some of the vital business strategies and distinct ideas peculiar to the legal industry. The ideas are presented with clarity of thought and simplicity of language. Hopefully, this keeps you relaxed while activating your logical and innovative mind. 

In addition to my knowledge and personal experience, the fundamental business aspects of legal practice discussed in this book also draws from the ideas of well-accomplished legal practitioners and scholars, locally and internationally. Therefore, some of the opinions expressed in the book are authoritative. The ideas are not only authoritative but realistic, with proven degrees of success. 

This book is meant to be a source of information, inspiration, and motivation for all categories of lawyers—especially young lawyers—as well as the lay in law, including law students and people in service-based businesses.


Book Price and How to Get a Copy

Law Practice as a Business is N7,000 (Seven Thousand Naira) only per copy, excluding delivery cost. To grab a copy or more for yourself and your learned friends, kindly make payment to any of the following account details: 


Azubuike Stephen Ifeanyi 




Azubuike Stephen Ifeanyi 


You can share evidence of payment via email (siazubuike@gmail.com) or WhatsApp (+2348063868497) and provide your delivery address. 

You can also purchase the book at my online store, https://stephensbooks.net/.

NB: For law firms, legal departments, and other organisations, Law Practice as a Business is also available for bulk purchase and is deliverable to all locations. To place requests, please email siazubuike@gmail.com. You can also reach me via call/WhatsApp on +2348063868497.

The book is also available in Lagos and Abuja at the following locations:

1. Ikeja Bar Centre, Lagos High Court, Ikeja Division. 

2. Udom Emmanuel Book stand, Federal High Court, Ikoyi. 

3. Infusion Lawyers, Vibranium Valley, 42, Local Airport Road, Ikeja. 

4.  Mr. Alex, Federal High Court, Abuja, 08035991379. 


Stephen Azubuike
Author: Stephen Azubuike
Stephen is a lawyer with expertise in Commercial Dispute Resolution and Technology Law practice. He is a Partner at Infusion Lawyers. He has successfully argued cases from the High Courts of various jurisdictions to the Appellate Courts on behalf of financial institutions, other corporate bodies and multinationals. He has advised a number of both established and startup tech companies. He tweets @siazubuike.
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