EVIDENCE – ESTOPPEL PER REM JUDICATAM/RES JUDICATA – Meaning of parties in relation to estoppel per rem judicatam

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“For the purpose of the application of the doctrine of estoppel per rem judicata, this Court consistently held that parties are defined not only in terms of those on record but also as including privies to the parties on record, those who may be interested in the outcome of the case and those who ought to have been made parties to the action but were not joined. In AYENI V. ELEPO (2007) ALL FWLR (PT.383) 71, it was stated thus: “For the purpose of estoppel per rem judicata, party means not only a person named in the previous action but includes those who ought to have been made parties. It equally includes “privies” and those who mentioned.”  Per MARY UKAEGO PETER-ODILI, JSC in ADALMA TANKERS BUNKERING SERVICES LTD & ANOR v. CBN & ORS (2022-LCER-46528-SC) (Pp 44 – 44; Paras A – E)

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