“As a general principle there must be a prayer for judicial separation and if it is sought after hearing has commenced then there ought to be an amendment. It is only in exceptional cases that a judicial separation can be substituted for a decree nisi already granted…”

Per IAN LEWIS, JSC in OBAYEMI V. OBAYEMI (1967) LCER-435(SC) (P. 7, Paras B – C)
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