MONEY LAUNDERING ACT 2011 AS AMENDED – A LEGAL REVIEW

INTRODUCTION:

The money Laundering Act is a statute enacted to check the rising incidence of crimes relating to laundering of money via banks and other financial institutions by individuals and Body corporate. Most often than not, the money so laundered are looted from the coffers of government, or from the sale of hard and dangerous drugs, weapons and in other instances defrauded from unsuspecting members of the public.

The effects of such financial crimes in the country cannot be over-emphasized as it destabilizes the economy, leaves the masses impoverished and in most cases, the illicit monies are used in the sponsorship of terrorist and other agents of political instability. The Act was first passed in 2004 as The Money Laundering (Prohibition) Act, 2004

The National Assembly under its statutory powers repealed the Money Laundering (Prohibition) Act, 2004 and replaced it with the Money Laundering (Prohibition) Act, 2011, hence the need for this review.

REVIEW OF THE RELEVANT SECTIONS TO THE BANK

Part 1.            PROHIBITION OF MONEY LAUNDERING

Section 1 (a) and (b) of this Act limit the amount of money to be paid or accepted as cash payment. For an individual it is now N5 million while a body Corporate it is N10 million. Anything in the excess of that must be made through a Financial Institution.

REPORTS ON INTERNATIONAL TRANSFER EXCEEDING USD 10,000 (Section 2)

Section 2 (1) (2) (3) made it mandatory for Banks and other Money Services Business to the CBN, SEC and the EFCC to make a report of any international transfer of funds, securities by a person, body corporate, where such transfer is in excess of USD 1000 within 7 days of such transfer.

Such reports shall indicate the nature of the transfer, the amount, names and addresses of the sender and receiver of the funds or securities.

IDENTIFICATION OF CUSTOMERS & ACCOUNT OPENING REQUIREMENTS

(section 3)

This section deals with the requirements for account opening and identification of customers before opening accounts, issuing passbook or even establishing any other business relationship with the customer.

REQUIREMENTS FOR INDIVIDUAL CUSTOMERS: (section 3(1) and (2) )

1.    Proof of identity:

Customer to provide a valid, original copy of an official document bearing the names and photograph of the customer or any other identification documents the relevant Regulators may approve from time to time.

2.    Proof of address:

Customer to present originals of receipts issued within the previous 3 months by Public Utilities or any other document as the Regulators may approve from time to time.

REQUIREMENTS FOR BODY CORPORATE: section 3 (3) and (4)

1. Proof of identity:

The Company to present its certificate of Incorporation and other valid official documents attesting to the existence of the body

2. The Manager, employee or assignee delegated by such body corporate to open the account shall be required to produce not only the documents as in 1 above, but must also present proof of the Power of Attorney granted him/her in the behalf.

REQUIREMENTS FOR CASUAL CUSTOMERS: section 3 (5)

A casual customer shall comply with the under listed regardless of the number of transactions including wire transfer involving a sum exceeding USD1000:

1.    Proof of identity:

Customer to provide a valid, original copy of an official document bearing the names and photographs or any other identification documents the relevant Regulators may approve from time to time.

2.    Proof of address:

The customer presents originals of receipts issued within the previous 3 months by Public Utilities or any other document as the Regulators may approve from time to time.

REQUIREMENTS FOR PUBLIC OFFICER: section 3 (8)

Section 25 defines Public Officers as individuals who are or have been entrusted with prominent public function, both within and outside Nigeria and those associated with them.

1.    Proof of identity:

The Officer provides a valid, original copy of an official document bearing the names and photograph or any other identification documents the relevant Regulators may approve from time to time.

2.    Proof of address:

The Customer presents originals of receipts issued within the  previous 3 months by Public Utilities or any other document as the Regulators may approve from time to time.

Apart from the above, the bank in the establishment of any business relationship with Public Officer must put in place appropriate risk Management systems; obtain senior management approval before establishing and during any business relationship with any public officer.

REPORT ON SUSPICIOUS TRANSACTIONS S. 3 (6) & (7):

Where there is a reasonable room to suspect that the amount involved in a transaction is a proceeds of a crime or illegal act, then the Bank shall require identification of customer regardless that the amount in the transaction is less than USD1000 or equivalent.

Where it appears that the customer may not be acting on his own account, the bank shall seek from the customer, by all reasonable means as to the true identity of the principal. Where the customer is a body corporate, the bank shall take reasonable means to understand the ownership, control structure, the natural persons who truly own and control the customer.

SPECIAL SURVELLANCE ON CERTAIN ACCOUNTS: Section 6 (1) & (2)

Where there is a special suspicion on any account because of the frequency which is unjustifiable, unreasonable or unusual the bank shall within 7 days after the transaction:

1.    draw up a written report containing all relevant information, with the identity of the principal and the beneficiaries where applicable

2.    take appropriate steps to prevent the laundering of proceeds of a crime or an illegal act

3.    send a copy of the report to the Commission whether the transaction was completed or not

SPECIAL POWERS OF THE COMMISSION & CBN:

Section 6(5) (b) confers powers on the EFCC and CBN  or their authorized representatives to place a stop order on any account or transaction for a time not exceeding 72 hours if it is discovered in the course of their duties that such accounts are involved in any crime.

Note that where it is not possible for the EFCC or the CBN to conclude their investigation within 72 hours, they must obtain an Order from the Federal High Court directing the Bank to block the funds, accounts or securities.

It is an offence for the Bank to fail to report to the Commission any reasonable suspicion within 7 days as stated in section 6 (1) and (2) and is liable upon conviction to a fine of N1million for each day during which the offence continues.

Note that where funds are blocked under an Order gotten from the Federal High Court by the EFCC or other relevant Agency under section 6(7) and there is evidence of conspiracy between the Bank and the owners of the funds, the bank involved shall not be relieved of liability under this Act and criminal proceedings for all offences arising therefrom may be brought against the directors and employees involved in the conspiracy. (Section 12)

PRESERVATION OF RECORDS: Section 7.  

The bank under this section is required to keep records of customers for a length of 5years as detailed hereunder:

1. Records of customers’ identification must be preserved for at least 5 years after the closure of the account or severance of relations with the customer.
2. Records and other related information of a transaction carried out by a customer including reports made to the commission on any unusual  or suspicious transactions on the account as in section6 shall be preserved for at least 5 years after the transaction or making of the report as the case may be.

COMMUNICATION OF INFORMATION: Section 8.

It is expected that records of customers as required in section 7 shall be communicated on demand to the CBN, NDLEA, and EFCC etc. as the case may be.

MANDATORY PRECAUTIONARY MEASURES TO BE PUT IN PLACE: Section 9.

It is mandatory for all banks to develop programmes towards combating the laundering of proceeds of a crime and other illegal act by:

1. Designation of Compliance officer at Management level at its Head office and every branch
2. Regular training programmes for staff
3. Centralization of information collected
4. Establishment of internal audit to ensure compliance.

It is important to note here that the CBN by this ACT is empowered to impose a penalty of not less than N1million or the suspension of any license issued the bank for failure to comply with the provisions of arousing adequate awareness among the staff.

MANDATORY DISCLOSURES: Section 10.

The bank is under an obligation to report within 7days to the commission of any single transaction, lodgement or transfer of funds in excess of:

1. N5million or its equivalent for individual
2. N10million or its equivalent for body corporate

A contravention of this disclosure is an offence and upon conviction attracts a fine of not less than N250,000.00 and not more than N1million for each day the contravention continues.

PROHIBITION OF NUMBERED OR ANNONYMOUS ACCOUNTS: Section 11.

The Act makes it an offence to create numbered or anonymous accounts.

An individual who contravenes this section is liable upon conviction to a term of not less than 2 years but not exceeding 5 years.

A bank or body corporate that contravenes this section shall be liable to a fine of not less than N10million but not exceeding N50million.

SURVEILLANCE OF BANK ACCOUNTS: Section 13.

In order to identify and locate proceeds, properties, objects or other things related to the commission of an offence under this Act the EFCC, CBN or other regulatory agencies may by the Order of the Federal High Court :

1. Place any bank account or any other account comparable to a bank account under surveillance
2. Obtain access to any suspected computer system
3. Obtain communication of any authentic instrument or private contract, together with all bank, financial and commercial records when the account, telephone line or computer system is used by any person suspected of taking part in a transaction involving the proceeds, of a financial or other crime.

It is worthy to note here that banking secrecy or preservation of customer confidentiality shall not be invoked as a ground for objecting to serving as a witness to facts likely to constitute an offence under this Act or obliging the Agencies with access to relevant information needed under this section.

It therefore becomes an offence under this Act to obstruct the Commission or authorized officers in the performance of their duty.

For an individual who constitutes such obstruction is liable upon conviction for a term not less than 2 years and not exceeding 3 years.

For a bank or body corporate it shall be a fine of N1million (section 22)

EXCLUSIVE JURISDICTION: Section 20.

The Federal High court is bestowed exclusive jurisdiction for the trial of offences under this Act.

WONDER BANKS IN NIGERIA – A LEGAL CRITIQUE

IS FORMATION OF COMPANY MANDATORY BEFORE CARRYING ON ANY BUSINESS IN NIGERIA?

Sections 18 and 19 of the Company & Allied Matters Act, (CAMA) CAP C20 LFN 2004 made it mandatory for the incorporation of companies, associations or partnership for the purpose of carrying on business for profit or gain.

The Statute also made it mandatory as part of the requirements that Companies etc at incorporation must have a Memorandum of Association and Articles of Association which act as the constitution regulating both the internal and external activities of the company etc. section 39 of CAMA provided that businesses not listed in the object clause of the MEMAT would be declared ultra vires.

The foregoing shows that any two or more persons as the case may be can come together to form a company after satisfying the conditions precedent as laid down by CAMA.

WHO CAN ENTER INTO DEPOSIT & LENDING OF MONEY BUSINESS IN NIGERIA?

The Banking business in Nigeria is regulated by the Banks & Other Financial Institutions Act CAP B.3 LFN 2004 (BOFIA). Section 66 BOFIA (Interpretations section) defines Bank as a Bank licensed under this Act and Banking business as the business of receiving deposits on current account, savings account or other similar accounts, paying or collecting cheques, drawn by or paid in by customers, provision of finance or such other business as the governor may by Order published in the Federal Gazette, designate as banking business.

It defines Financial Institutions as any individual, body, association or group of persons, whether Corporate or Unincorporated, other than the banks licensed under this Act which carries on the business of a discount house, finance company and money brokerage and whose principal objects include factoring, project financing, equipment leasing, debt administration, fund management, private ledger services, investment management, local purchases, order financing, export finance, project consultancy, financial consultancy, pension fund management and such other business as the bank may, from time to time designate.

Section 2 (1) and (2) of BOFIA provides that no person shall carry on any banking business in Nigeria except if the company is duly incorporated in Nigeria and holds a valid banking licence issued under this Act. A contravention of this provision is an offence punishable upon conviction for a term of imprisonment not exceeding 10 years or to a fine of N2,000,000.00 or both.

Section 3 BOFIA provides for the requirements and steps for the granting of licence and the CBN is conferred with the powers to implement this Act subject to the overall supervision of the Minister.

This shows that the business of banking is not an exclusive preserve of any particular person or persons but its opened to persons who meet the requirements as stipulated under CAMA and BOFIA.

CAN AN INDIVIDUAL OR PERSONS ENGAGE IN THE BUSINESS OF MONEY LENDING?

An individual, company or partners can engage legally in the business of money lending. This is regulated by the Money Lenders Laws of the various States as the business of money lending is not covered under the 1^st schedule (exclusive legislative list) and the 2^nd schedule (concurrent legislative list) of the 1999 constitution of the Federal Republic of Nigeria. It therefore falls into the Residual list, making it right for the various states to legislate on the business of money lending in accordance with the requirements and peculiarities of their socio-economic environment.

The money lending business in Lagos State is regulated by the Money Lender’s Law of Lagos State CAP. M7. Section 2 of the Law (Interpretation section) defines a money lender as everybody whose business is that of money lending or who carries on or advertises or announces himself or holds himself out in any way as carrying on that business, whether or not he also possesses or owns property or money derived from sources other than the lending of money and whether or not he carries on the business as a principal or as an agent; but shall not include:

·         Any co-operative society

·         Anybody corporate incorporated or empowered by special enactment to lend money in accordance with such enactments.

·         Any person bona fide carrying on the business of banking or insurance or bona fide carrying on any business, not having for its primary object the lending of money, in the course of which and for the purposes whereof he lends money.

·         Any pawn broker licensed under the pawn brokers Law where the loan is made in accordance with the provisions of the pawn brokers Law and does not exceed the sum of N40.00

Section 4 of the Money Lenders Law of Lagos State further enlarged the scope of persons presumed to be money lenders to include any person who lends money at interest or who lends a sum of money in consideration of a larger sum being repaid shall be presumed a money lender until the contrary is proved.

REQUIREMENTS/PROCEDURES FOR ENLISTMENT AS A MONEYLENDER OPERATOR IN LAGOS STATE

Section 5 of the Law provides that no one can operate as a money lender under the Law without the moneylender’s licence. The Licence is given after the intending money lender has fulfilled some requirements.

The person shall first apply to the Magistrate of the district in which the money lenders business is to be carried on for Certificate. At the issuance of the certificate, he shall present it to the State Commissioner who upon satisfaction shall issue the applicant the Licence to carry on business of Money lending. The Certificate and Licence have a year life span and shall expire on the 31^st of December next following respectively. This however is renewable.

The certificate as issued shall not authorize the money lenders carry on the business of money lending except:

·         He does so in his true names

·         The name of a firm in which he is a partner, not being a firm required by CAMA part B, business name to be registered.

·         Or business name whether of an individual or firm in which he is a partner under which he or the firm has at the commencement of this Law, been registered for not less than 3 years both as a money lender under the money lenders law and under CAMA part B, Business names.

·         It shall not include the word ‘BANK’ or otherwise implies that he carries on banking business.

It is worthy to note here too that every money lender shall have a current account with a licenced Bank. The money lenders are by section 15 of the Law restricted from charging arbitrary interests on monies lent. The issuance of Licence for money lending business is overseen by the State Commissioner and the State Commissioner equally has the prerogative to exempt any person from some or even all of the requirements (Section 3 CAP M7)

ARE WONDER BANKS OPERATING LEGALLY UNDER THE EXISTING STATUTES?

From the studies so far made, it is clear that the wonder banks as we know them today by their modus operandi cannot either be classified under Banks as provided and regulated by BOFIA or Money Lenders as provided under the Money Lenders Law of Lagos State, CAP M7.

The Wonder Bank to say the least is an aberration to the economy. They not only do not act in line with existing statutes regulating all forms of banking and money businesses including Money Lending Business, they have also led to the failure of many businesses and monumental fraud on unsuspecting citizens.

It makes a mockery of common sense to allow such an engine of fraud to keep on operating in our environment.The moment to act is now!

MY INTELLECTUAL BANQUET!: EXECUTION OF A WILL IN NIGERIA

MY INTELLECTUAL BANQUET!: EXECUTION OF A WILL IN NIGERIA: "WILLS – THE POWERS OF EXECUTORS UNDER THE WILLS ACT – A LEGAL CRITIQUE MEANING: The Black's Law Dictionary defines Will as 'An instrument by..."

EXECUTION OF A WILL IN NIGERIA

WILLS – THE POWERS OF EXECUTORS UNDER THE WILLS ACT – A LEGAL CRITIQUE

MEANING:

The Black's Law Dictionary defines Will as "An instrument by which a person makes a disposition of his real and personal property; to take effect after his death, and which by its own nature and revocable during his lifetime .... "

It is also "The legal expression or declaration of a person's mind or wishes as to the disposition of his property, to be performed or take effect after his death. A revocable instrument by which a person makes disposition of his property to take effect after his death. A written instrument executed with the formalities required by statutes, whereby a person makes a disposition of his property (real and personal) to take effect after his death".

On the other hand, "Codicil" is defined by the same Dictionary as: A supplement or an addition to a will, it may explain, modify, add to, subtract from, qualify, alter, restrain or revoke provisions in existing will

A will summarily then is a document made by a person called the testator wherein he confers benefits on another person called the beneficiary. A will is a document by which a person transfers benefits or assets to another person. A will is an instrument that provides security or welfare for the family of the maker. A will is the sum total of what a person wishes to happen to those he lives behind on his death.

One striking thing to note about the Will is that until the maker dies, he reserves the right to alter or revoke it. That is why it is called ambulatory. Importantly too, the will takes effect only upon the death of the maker.

TYPES OF WILLS

It might be of interest for us know that there various types of will. The following are some of those varieties, namely:

1.      Holographic Will. One that is entirely written; dated and signed by the hand of the testator himself"

2.      Joint Will. One executed jointly by two persons with reciprocal provisions which show on its face that the devices are made one in consideration of the other. Joint will is one in which the same instruments is executed by two persons as their respective will. It is a testamentary instrument executed by two or more persons in pursuance of a common intention, for the purpose of disposing of their several interests in property owned by them in common, or of their separate property treated as a common fund, to a third person or persons."

3.       Mutual (or reciprocal) Will. One in which two or more persons make mutual or reciprocal provisions in favour of each other. Mutual Wills" are the separate wills of two persons which are reciprocal which are reciprocal in their provisions, and such a will may be both joint and mutual. Sometimes, it is called a "reciprocal", "double", or "counter" will."

4.      Nuncupative Will. An oral will declared or dictated by the testator in his last moment before a sufficient number of witnesses; and after words reduced to writing. A will made by the verbal declaration of the testator, and usually dependent merely on oral testimony for proof. Such wills are invalid in certain states, and in others are valid only under certain circumstances."

It is important to mention that a will unless it is made in contemplation of a particular marriage is revoked by the marriage or remarriage of the testator or

LEGAL TERMS USED IN WILLS:

·         Testator: This usually applies to a man who makes or has made a testament or will, or one who dies leaving a will.

·         Testatrix: A woman who makes a will; a woman who died leaving a will; a female testator in short.

·          Executor: A man appointed by the testator to carry out the directions and requests in his will, and to dispose of the property according to his testament provisions after his death.

·         Executrix: A woman appointed by the testator to administer his Estate upon his death. A female Executor.

·         Beneficiary: One who derives benefits under a will. In him resides the equitable interests in devised property. He can also be called the Legatee.

·         Trustee: One in whom an estate, interest, or power is vested under an express or implied agreement to administer or exercise it for the benefits or to the use of another. One who holds the legal title to property "in trust" for the benefit of another person called the beneficiary and who must carry out specific duties with regard to the property.

·         Estate:  The total of assets and liabilities of the testator including all manners of property, real and personal, choate or inchoate, corporeal or incorporeal.

·          Legacy: Is a gift by will of personal property.

·          Legal representative:  A person who overseas the legal affairs of another. It is always held to be synonymous with "personal representative". It includes the executor or administrator of an estate and a court appointed guardian of a minor or an incompetent person.

·         Administrator (trix): A person appointed by the court to administer/manage or take charge of the assets and liabilities of a deceased person. Such a person may be a male (in which case he is called administrator) or a female (administratix)'".

ADMINISTRATION OF WILLS

The Administration of a Will is the oversight role played by the Executor or Trustee of a Will. It deals with the management and superintendent function of the Executor regarding a Will. It is all about taking the necessary practical steps in not only proving a Will but ensuring that the Executor carries out the wishes and directions of the testator in the Will. It deals with the management of the estate of a deceased person in accordance with the written directions in a Will,and in compliance with available legislation. Plainly, Administration of a Will is all about the determined counsel of the Executor to safeguard and realize the intentions of the testator having regard to who gets what from the estate and rendering appropriate account. Without administration, a Will remains impotent and incapable of being translated into reality. It remains a dead testament. Thus, administration is the necessary push required to give the fullest effect to a will and thereby put smiles on favoured faces. On the faces of surviving beneficiaries thereunder. Now, let us examine the modus operandi of Administration of a will.

APPLICATION FOR GRANT OF PROBATE

As indicated herein before, the various High Court Rules makes adequate and similar provisions governing probate and Administration. We will take the liberty to use the Kaduna State High Court (Civil Procedure) Rules, 1987 as a model in discussing this subject. Order 187 49, Rule 1 of the said Rules requires of any person in possession of any paper or writing of any deceased person purporting to be testamentary to within fourteen (14) days of having knowledge of the death of that person deliver original of same to the Probable Registrar of the Court. Failure to comply attracts a penalty of W100 fine. Under Rule 2 of the said order, the Court is vested with the power to order any person to produce before it any testamentary document whether or not a suit is pending on the probate or Administration. Likewise, the Court can examine any person in custody of such document" and/or call on the Executor on its own to come and prove a will."

The application for grant of probate upon the death of the testator is expected to be made by petition to the probate Registrar of the High Court. Usually, the Chief Registrar who doubles as the probate Registrar with office at each state capital where the Headquarters of the Court is located. If such application is made through a legal practitioner, the office address of the lawyer within its jurisdiction shall be supplied." A personal applicant shall produce a certificate of death of the deceased or such other evidence of death required of him by the probate Registrar. In addition, the personal applicant shall supply all necessary information required of him so as to facilitate the grant. Every application for grant of probate shall be supported by an Affidavit duly sworn to by the Applicant and supported by necessary Exhibits as the probate Registrar may require, specifically, such Affidavit shall state where the deceased died domiciled. Upon the receipt of the application, the probate Registrar may require any other useful information and commence the processing of the application by inspecting the will and verifying its due execution. No grant of probate or of administration with the Will shall issue within seven days of the death of the deceased testator": Improper execution affects grants of probate as the court reserves the right to decline.

THE POWERS OF EXECUTORS OF A WILL:

An "executor" is a personal representative who is responsible for distributing the estate (property, assets, and possessions) of an individual according to the wishes outlined in their Will. The executor has specific powers designated by law and given exclusively to the executor in the Last Will and Testament through which they received that office. The executor being in a fiduciary relationship owes certain duties and responsibilities to the creator (testator/ settlor) of the will or trust. While acting as executor, personal representative or trustee these administrators are subject to various laws, regulations, standards and guidelines including (but not limited to):

They include among others:

·         The first obligation of the executor is to locate and read the original of the most recent Will of the deceased. Hopefully, the "testator" (the individual who wrote the Will) has previously informed the executor or their family where their Will and other important papers are kept. If not, then the executor must search all likely places for a valid Will. If the Will is kept in a safety deposit box, then the executor will have to take a key, the Death Certificate and personal identification in order to access the box. The box can be forced open if they do not have a key. The bank will then draw up an inventory of the contents, and the Will will be released if the executor can demonstrate that they are indeed the person with executor responsibilities for the Will.

·         The executor should apply for the Death Certificate of the testator, which can usually be obtained from the hospital. This usually takes one to two weeks to receive.

·         The executor has the right to determine how to dispose of the deceased's body. Any funeral wishes expressed by the deceased are not legally binding, although in practical terms personal wishes are usually respected. If the deceased has taken time to express their personal wishes through a funeral home service, it will save the family and the executor a great deal of anxiety and grief.

·         The executor must notify everybody who has an interest in the estate and what, if any, is their entitlement described in the Will. If the Will or the authority of the executor is challenged, then the executor may have to provide documentary evidence that they have complied with any legal requirements.

·         A list of assets and liabilities must be drawn up, including their value at the date of death.

·         The executor must secure all assets, either by taking them into his or her possession, or by taking out a full insurance policy.

·         All prospective creditors must be given an opportunity to stake a claim on the estate. The executor must advertise for anybody who may have a claim against the estate. Creditors with a valid claim can recover their debt at any time, even after the estate has been distributed to the beneficiaries.

·         The next step is to apply to probate the Will, so that the assets can be dealt with legally. This may require legal assistance.

·         The executor is responsible for filing taxes on behalf of the deceased, including income taxes and death taxes.

·         Once the executor has obtained legal authority to distribute the estate, they must pay all outstanding debts and expenses, including funeral expenses and all taxes.

·         Once all debts have been paid, the estate can be distributed to the beneficiaries starting with specific bequests to individuals. If the Will provides for the setting up of Trusts, then the executor is responsible for making these arrangements. Once all specific bequests have been distributed, the residue is distributed.

·         The executor is accountable to the beneficiaries for the assets of the deceased. It is therefore vital that accurate records are maintained when dealing with all debts, expenses, taxes and the distribution of the estate.

REFERENCES:

1.      Proudhon, P.J. Commentary; 1989 in Ch. 2

2.      Black’s Law Dictionary, 5^th Ed. 1979

3.      Barron’s Law Dictionary, 2^nd Ed. 1984

4.      Osborne’s Concise Law Dictionary, 7^th Ed. By Roger Bird, Sweet & Maxwell

5.      Joseph . S. An Introduction to Islamic LAW, Oxford Univ. Press, 1964

6.      Itse Sagay; Nigerian Law of Succession; Malthouse Press Ltd, Lagos;  2006

7.      Olayide, A. Cases and Texts on Equity, Trusts & Administration of Estates; Mabrochi International Company Limited; Lagos, 2003

8.      Animashaun T.O.G and  Ojeneyin A.B- Law of Succession Wills and Probabte in Nigeria – MIJ Professionals Publishers Limited; Lagos; 2002

9.      Alexander Pope: Essays on Criticisms; 9^th Ed. 1937

10.  Williams on Wills; VAL Law of Wills; 5^th Ed. 1980

11.  A.A. Utuama; Nigerian Law of Real Property (1990) Shaneson Concise Univ. Series,