Introduction:
Understanding the characteristics of a valid judgment is crucial for lawyers, judges, and anyone seeking justice through the legal system. This article aims to explore the essential features of a valid judgment, the legal principles governing judgments, and the significance of understanding them in the Nigerian legal system.
We will examine the different types of judgments, the legal requirements for a valid judgment, and the consequences of an invalid judgment. Overall, this article will provide a comprehensive overview of the characteristics and requirements of a valid judgment, highlighting its importance in the Nigerian legal system.
Understanding the Characteristics and Requirements of a Valid Judgment
A valid judgment is an essential aspect of any judicial system, and it is crucial that it meets the necessary characteristics and requirements. A judgment is the final decision reached by a court in a legal dispute, and it is binding on all parties involved. It is a legal decision made by a court on a matter before it. It is a binding decision that stipulates the rights of the parties involved. For a judgment to be valid, certain characteristics and requirements must be met. In this article, we will explore these characteristics and requirements to give you a better understanding of what constitutes a valid judgment.
See Also: Admissibility Of Computer Generated Evidence In Nigeria.
Characteristics of a Valid Judgment
Firstly, a valid judgment must be in writing, as stipulated by Section 294(1) of the Constitution of the Federal Republic of Nigeria (CFRN). This means that even if a judge delivers an oral judgment and later reduces it to writing, the judgment is still considered invalid. Secondly, a valid judgment must be written, dated, and signed/sealed by the judge who heard the matter.
Thirdly, a judgment must contain a dispassionate consideration/evaluation of the issues properly raised and heard. This means that the judge must evaluate the issues without bias or emotional attachment. Fourthly, reasons must be given for the judgment, except in cases where the court is the final appellate jurisdiction, such as the Supreme Court.
Fifthly, a judgment must be delivered in an open court unless the trial was conducted in chambers or for reasons of public morality, public security, or the protection of a minor. Section 36(4) of the CFRN stipulates this requirement. Sixthly, a judgment must be delivered within 90 days after the final addresses, as stated in Section 294(1) of the 1999 Constitution as amended.
Seventhly, a valid judgment must show a clear resolution of all the issues that arise for decision in the case. This means that the judgment must address all the issues raised during the trial. Eighthly, the judgment should show clearly that the court considered the evidence presented during the trial. Finally, witnesses must be expressly or impliedly believed or disbelieved, as stated in cases such as Mogaji v. Odofin, Adeyeye v. Ajiboye, and Oro v. Falade.
Types Of Judgments
1. Interlocutory Judgment
An interlocutory judgment disposes of only one issue raised during the pendency of the suit. It does not dispose of the rights of the parties finally e.g. injunctions
2. Final Judgment
A final judgment is one that disposes of the rights and liabilities of the parties finally in a suit. It comes at the end of the matter. At the end of the trial, the judge may either give judgment for the plaintiff or dismiss his case thereby giving judgment for the defendant.
3. Consent Judgment
A consent judgment is judgment entered pursuant to an agreement between the parties. The agreement may either be made out of court; then brought for court to pronounce it as judgment; or may be entered in the face of court pursuant to parties agreement. It is binding on the parties but a third party can apply to set it aside for fraud; mutual mistake A consent judgment is a final judgment and leave of Court is required to appeal against it S. 241(2) (c) CFRN; Afegbai v. AG Edo State.
4. Declaratory Judgment
A declaratory judgment is a judgment of a court which determines the rights of parties without ordering anything to be done or awarding damages. Not an executory judgment – e.g. might be declaring the rights of the parties.
5. Default Judgment
This is a judgment given due to default or failure of a part in the proceedings to take any steps, which he ought to have taken e.g. default to enter appearance e.g. Default to file pleadings. A default judgment is not a judgment on the merit.
6. Non-Suit
This is an order, which terminates the plaintiff’s case without a decision on the merits. Where this order is made, it means that the plaintiff’s claim is neither allowed nor dismissed. Circumstances of the case are such that the court does not think it should enter judgment against the plaintiff or for the defendant. Kaura v. UBA PLC; Order 34 Rule 1 Lagos
Form and Time Limit of Delivery of Judgment
A judgment must be delivered in writing not later than 90 days after the conclusion of evidence and final addresses, as stipulated by Section 294(1) of the CFRN. Failure to do so does not necessarily invalidate the judgment. However, the delay must not have occasioned a miscarriage of justice, as stated in Section 294(5) of the CFRN.
All parties must be furnished with duly authenticated copies of the judgment within the 90-day period as well, as stated in Section 294(2) of the CFRN. The court may recall the parties for a further address before the expiration of the 90-day period, and such subsequent address shall be deemed the final address.
Review and Amendment of Judgments
A court’s judgment is final once it has been pronounced /delivered. It can only be set-aside on appeal. Therefore, the court has no power to review its own decision. This is because once the court enters its judgment, it become functus officio.
Exceptions to This Rule:
A court may revisit its judgment or vary it in any of the following instance:
- Clerical mistakes or accidental errors or omissions in judgments may at any time be corrected by the judge in chambers on a motion or summons.
- Where the decision was given without jurisdiction/such a judgment is a nullity and the court has powers to set it aside.
- Where the judgment was obtained as a result of fraud perpetrated by one of the parties–Alaka v. Adekunle.
- Where the judgment is a complete nullity ab initio.
- Where the judgment was entered on the mistaken belief that the parties consented to it when in fact they did not–Agobade v. Okonuga
Recall of Parties for Further Address
The court may re-open a case for further argument after it has reserved judgment, provided it acts within the 90-day limit. However, if the 90-day period has elapsed, the court cannot recall the parties for further address. This was stated in the case of Odi v. Osafile.
Days for Delivery of Judgment and Its Effect
A judgment may be delivered on juridical days, but it cannot be vitiated by the mere fact that it was delivered on a public holiday, provided that the parties were not compelled to attend, as stated in Anie v. Uzorka. In the case of Veritas v. Citi Trust (Nig.) Ltd, a judgment of a court delivered on Christmas day was held to be valid.
See Also: Mode of Tendering Documents through a Witness in a Nigerian Court: A Guide
Conclusion
In conclusion, understanding the characteristics and requirements of a valid judgment is crucial for all legal practitioners, litigants, and the general public. A valid judgment is one that has been properly delivered, clearly stated, and founded on sound legal principles and evidence. The judgment must also contain adequate reasons to enable the parties to understand the basis for the decision.
The requirements for a valid judgment may vary depending on the jurisdiction and the type of case involved, but the underlying principles remain the same. Failure to comply with the requirements of a valid judgment may render the judgment null and void.
Finally, it is, therefore, imperative for all stakeholders in the legal system to ensure that judgments meet the necessary standards to uphold the integrity and credibility of the justice system. In light of the challenges facing the Nigerian judicial system, it is crucial for reforms to be implemented to improve the efficiency and effectiveness of the system.
