Introduction

This article will not and does not address the mechanics and intricacies of preparing briefs of argument which is actually very different from preparing a final written address. For an exposition on how to write briefs of argument, this piece on Nigerian guru website is most apposite. Also, a number of other reading resources are mentioned at the end of this piece.

The narration below is to act as a mere guide to Counsel and might need some adjustment to suit the peculiar situation of the specific appeal concerned.

Making Oral Submissions on the Day of Hearing of the Appeal

When representing the Appellant (Appellant’s Oral adoption of brief of argument)

My Lords, this is an appeal against the judgment of Okeke J. delivered on the 5th of July 2022. The judgment can be found at page 364 of the record of appeal. The Appellant’s notice of appeal was filed on the 8th of July 2022 and can be found at pages 366 to 367 of the record of appeal.

By leave of Court granted on the 5th of January 2023, the Appellant filed an amended notice of appeal. The amended notice of appeal was filed on the 12th of January 2023. The Appellant’s brief was filed on the 15th of January 2023 but deemed properly filed on the 17 of February 2023. We respectfully adopt same (Adumbrate if permitted by the Justices of the Court or if necessary, at all).

See also  HTKYOB Episode 1 - Destruction is cheap.

The Appellant also filed an appellant’s reply brief and it was deemed properly filed today. We also adopt same. In reliance on both briefs, we urge this Court to allow the appeal.

Respondent’s Oral Adoption of Brief of Argument

My Lords, we have a notice of preliminary objection filed on the 18th of February 2023. We argued the preliminary objection at pages 2 to 8 of the Respondent’s brief of argument.

Consequent upon our arguments in the preliminary objection, we urge this Court to dismiss the Appellant’s appeal in its entirety.

In response to the Appellant’s substantive appeal and issues, we canvassed arguments at pages 9 to 14 of our Respondent’s brief. We adopt our arguments contained in the said brief filed on the ___________. We urge this Court to dismiss the appeal of the Appellant and uphold the judgment of the lower Court.

Additional Resources

PRAGMATIC PRINCIPLES OF BRIEF WRITING IN APPELLATE COURTS IN NIGERIA