EVIDENCE – ESTOPPEL PER REM JUDICATAM/RES JUDICATA – Meaning of privy (ies)

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“The word ‘privy’ has also been defined to include all those who are privy to the parties on record in blood, tittle or interest and estoppel per rem-judicatam operates against all of them. See MUSA IYAJI v. SULE EYI GEBE (1987) LPELR- 1571 SC 1 AT 22-23 G-A per OPUTA, JSC where this Court held thus: “Who is a Privy? Are the parties to this appeal privies of the parties in Exhibit D1? In Carlzein-Stiftung v. Rayner 4 Kueler Ltd (No. 2) (1996) 2 All E.R. 536 H.L. at p. 550, Lord Reld held that privies include all those who are privies to the parties, in blood or title or interest and estoppel per rem judicatam operates for or against, not only parties but also those privies above mentioned.” Per MARY UKAEGO PETER-ODILI, JSC in ADALMA TANKERS BUNKERING SERVICES LTD & ANOR v. CBN & ORS (2022-LCER-46528-SC) (Pp 44 – 45; Paras E – B)

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