IN THE NATIONAL INDUSTRIAL COURT OF NIGERIA
IN THE JOS JUDICIAL DIVISION
HOLDEN AT JOS
BEFORE HIS LORDSHIP HON. JUSTICE I.S. GALADIMA
DATE:
10TH DECEMBER 2025 SUIT
NO: NICN/JOS/46/2024
BETWEEN:
1. FAITH
ISI EMMANUEL
2. DOKBISH
LONGWAL GUJOR …….
CLAIMANTS
AND:
1. GOVERNOR
OF PLATEAU STATE
2. ATTORNEY
GENERAL OF PLATEAU STATE ….....
DEFENDANTS
3. PLATEAU STATE COLLEGE OF HEALTH
TECHNOLOGY
REPRESENTATION:
·
NANTOK DASHUWAR; R.I. PANTUVO; E.S. BUF FOR THE
CLAIMANTS
·
PANSHAK KYAKSE AUDU; K.E. POWAR; ALFRED DANBABA
FOR THE 1ST RESPONDENT
·
P.A DAFFI, ESQ. (HAG OF PLATEAU STATE); SABO
LONGJI, ESQ., N.J. MINER; T.P. CHIGERO; K.D. WUYEP FOR THE 2ND AND 3RD
RESPONDENTS.
1.
At the heart of this dispute is that in 2022
the claimants were offered and accepted appointments at the 3rd defendant
institution and duly commenced their duties. Thereafter, the 1st
defendant, the Governor of Plateau State, suspended them and subsequently
announced their termination. The claimants contend that this action was
unlawful, arguing that the 1st defendant had no statutory authority
to suspend or terminate their employment. They also allege that they have not
received any salary since January 2023 since their employments were halted.
Consequently, the claimants have approached this honourable court to challenge
the 1st defendant’s unlawful interference, vindicate their
employment rights, and obtain orders restoring their employments and
entitlements.
2.
The defendants contest the suit on several
grounds, maintaining that the claimants’ employments were riddled with
irregularities. They further deny any obligation to pay salaries and have asked
the court to dismiss the case in its entirety.
QUESTIONS FOR DETERMINATION:
3.
On 30 September 2024, the claimants filed an
originating summons in which they ask the court to resolve the following
questions:
i. Whether
the 1st defendant is possessed of or clothed with the powers or
authority to unilaterally suspend, terminate, nullify or in any way interfere
with the employments and appointments of the Claimants through Exhibits D and
E, the Claimants having been in the service and employment of the 3rd
Defendant.
ii. By
virtue of the letters of appointment issued to the Claimants attached as
Exhibits A1 – A2, whether the Claimants are not entitled to maintain and retain
their employment with the 3rd Defendant in line with the extant laws
regulating their employment with the 3rd Defendant.
iii. Whether
the failure and refusal of the 3rd Defendant to pay the Claimants
their salaries and allowances thereby retaining same from the month of January
2023 till date or any period of time at all is not unlawful, unjust, illegal
and a violation of the 3rd Defendant’s duties and obligations.
The
Claimants thus seek the following reliefs:
i.
A declaration that the 1st
Defendant has no power or authority to suspend, terminate, nullify or in any
way interfere with the employments and appointments of the Claimants duly
engaged in the services and employment of the 3rd Defendant.
ii.
A declaration that the purported
termination, nullification and cancellation of the employment and appointment
of the Claimants by the 1st Defendant through Exhibits D and E, is
unlawful, illegal, null and void with no legal effect whatsoever.
iii.
A
declaration that the Claimants are entitled to maintain and retain their
employment with the 3rd Defendant in line with the extant laws
regulating their employment with the 3rd Defendant.
iv.
A declaration that the failure and refusal of
the 3rd Defendant to pay the Claimants their salaries and allowances
thereby retaining same from the month of January 2023 to date is unlawful,
unjust, illegal and in violation of the 3rd Respondent’s duties and
obligations.
v.
An order setting aside the purported
suspension and subsequent termination, nullification and cancellation of the
Claimants’ Appointments/Employments made by the 1st Defendant
through the publications made at his instance attached as Exhibits D and E,
same having been done ultra vires and therefore unlawful, null and void.
vi.
An order reinstating the Claimants back to
their positions as staff and employees of the 3rd Defendant in line
with their letters of appointment attached as Exhibits A1 and A2.
vii.
An order directing the Defendants to pay the
Claimants their monthly salaries and allowances as specified by the terms of their
employments from the month of January 2023 to date, as follows:
a. 1st Claimant: The sum of N1, 360, 160. 86
annually paid in monthly installments of N113, 346. 73. per month.
b. 2nd Claimant: The sum of N873, 551.00
annually paid in Monthly installments of N72,795.00 per Month.
viii.
An order of perpetual injunction, restraining
the Defendants, whether by themselves, their agents, privies, assigns or
representatives howsoever described, from victimizing, terminating or
interfering with the Claimants’ appointment and employment with the 3rd
Defendant, without any wrongdoing or violations of the terms of service on the
part of the Claimants.
ix.
N50,000,000.00 (Fifty Million Naira only) as
General Damages against the Defendants jointly and severally for the pain and
suffering imposed on the Claimants by the Defendants.
x.
Costs of this Suit as may be assessed by this
Honourable Court
4.
The
originating summons is supported by a 28-paragraph affidavit sworn by the 1st
claimant, Emmanuel Isi Faith, to which four documents—marked Exhibits A1, A2,
D, and E—are attached. A written address by the claimants’ counsel, Nantok
Dashuwar, Esq., also accompanies the affidavit.
5.
On
18 October 2024 the 2nd and 3rd defendants filed a
Memorandum of Conditional Appearance. Then, on 23 December 2024—albeit out of
time—they filed a five-paragraph counter-affidavit, a written address opposing
the claimants’ supporting affidavit, and a notice of preliminary objection. Those
late processes were thereafter regularized by a motion dated 19 December 2024,
also filed on 23 December 2024.
6.
On
June 5, 2025, the 1st defendant lodged a Memorandum of Conditional Appearance,
a Counter-Affidavit consisting of four principal paragraphs, and a written
address opposing the claimants’ supporting affidavit. Although these documents
were filed after the deadline, they were subsequently regularized by the
defendant’s motion dated May 21, 2025, which was also filed on June 5, 2025.
CLAIMANTS’ FACTS
7.
Based
on the claimants’ pleadings, in 2022, after submitting the required
applications, they were appointed by the Plateau State College of Health
Technology, Pankshin (3rd Defendant) and accepted their letters of appointment,
which were pleaded as Exhibits A1 and A2.
8.
Before
commencing their duties, they completed all required documentation and
faithfully discharged their responsibilities in accordance with their letters
of appointment, the staff Conditions of Service, and the Plateau State College
of Health Technology Law, 2003 (Exhibits B and C).
10. After a change in
administration, the 1st Defendant – the incumbent governor of the
State of Plateau, suspended all newly appointed Plateau State Government staff
and agency workers—including the Claimants— who were employed from October 2022
to 29 May 2023. As a result, the Claimants were denied access to their places
of work and have not received any salary since January 2023, despite never
having faced any disciplinary proceedings or been found in breach of the laws
and regulations governing their employment with the 3rd Defendant.
11. The claimants aver
that they are owed salaries as follows:
a.
1st Claimant:
The sum of N1,360,160.86 annually paid in monthly installments of
N113,346.73. per month.
b.
2nd
Claimant: The sum of N873,551.00 annually paid in Monthly installments of
N72,795.00 per Month.
12. The Claimants contend
that afterward the 1st defendant formed a committee to review the
employments of those hired during the same period, yet the Claimants were
neither invited nor heard, nor were they informed of the committee’s findings.
13. Thereafter, through public announcements, the 1st defendant
purported to terminate and nullify the Claimants’ appointments without serving
them any formal notice or letter of termination via Exhibits D and E.
14. The Claimants assert
that, under the Plateau State College of Health Technology Law, 2003 and the
College’s Conditions of Service, the 1st Defendant has no power to
suspend or terminate their appointments. They were appointed by the 3rd
Defendant—a statutory body governed by its own council—and hold permanent,
pensionable positions. They remain prepared and willing to continue discharging
their duties.
THE
CLAIMANTS’ COUNSEL’ S WRITTEN SUBMISSIONS:
16. The
Claimants’ counsel filed along with their originating summons, a written
address dated 9/9/2024 and filed on 30/9/2024 wherein they formulated 3 issues
for determination as reproduced below:
a. Whether
the 1st Defendant is possessed of or clothed with the powers or
authority to unilaterally suspend, terminate, nullify or in any way interfere
with the employment and appointment of the Claimants through Exhibits D and E,
the Claimants having been in the service and employment of the 3rd
Defendant.
b. By
virtue of the letters of appointment issued to the Claimants by the 3rd
Defendant attached as Exhibits A1 and A2, whether the Claimants are not
entitled to maintain and retain their employment with the 3rd
Defendant in line with the extant laws regulating their employment with the 3rd
Defendant.
c. Whether
the failure and refusal of the 3rd Defendant to pay the Claimants
their salaries and allowances thereby retaining same from the month of January
2023 till date or any period of time at all is not unlawful, unjust, illegal
and a violation of the 3rd Defendant’s duties and obligations.
17. The learned counsel
addressed the three issues he had identified, arguing that the 1st Defendant
lacks any legal authority to suspend, terminate or otherwise interfere with the
Claimants’ employment. Their appointments were made exclusively by the 3rd Defendant
through its Governing Council. As shown in Exhibits A1 and A2, their employment
is governed by the Plateau State College of Health Technology Law, 2003, and
the College’s Scheme of Service—statutory instruments that vest all powers of
appointment, suspension and termination solely in the Governing Council, not in
the 1st Defendant. Indeed, paragraph 2(vii) of each letter of
appointment states: “That you will be subject, in all respects, to all
conditions of service stipulated in the Scheme of Service and other College
Regulations and Instructions, as may be reviewed by the Council from time to
time.”
18. The Claimants contend
that Sections 6(1)(r), 10(1) and (2)(g), and 18(1) of the Plateau State College
of Health Technology Law exclusively vest appointment, suspension and
termination powers in the College’s Governing Council. The 1st
Defendant is not granted any authority over employment matters by the statute.
Accordingly, the actions taken by the 1st Defendant under Exhibits D
and E improperly usurp the Council’s jurisdiction, and any suspension or
termination he purported to effect is ultra vires and void.
19. To underscore this
principle, the Claimants refer to Bob v. The Council, Abia State University
Uturu & Anor (2015) LPELR-25611 (CA), Haruna v. Uniagric, Makurdi (2005) 3
NWLR (Pt. 912) 233 at 275, and Mobile Producing Nigeria Unlimited v. Okon
Johnson & Ors. (2018) 14 NWLR (Pt. 1639) 329 at 359. These authorities
establish that where an employment relationship is defined by statute, only the
body empowered by that statute may validly discipline or terminate the
employee, and any action taken outside that statutory authority is null and
void.
20. The Claimants argue
that their engagement with the 3rd Defendant is governed by statute
rather than a simple master–servant contract. Consequently, any dismissal must
follow the exact procedures laid down in the enabling law and the College’s
Conditions of Service. They maintain that once employment acquires a statutory
character, any departure from the prescribed procedure nullifies the
termination. Because only the Governing Council has authority to appoint or
dismiss staff and the 1st Defendant acted without such power, the Claimants’
employment remains valid and subsisting.
21. They refer to OMIDIORA
v. FCSC (2007) 14 NWLR (Pt. 1053) p. 17 at 32–33; MOGAJI v. BENUE STATE
UNIVERSITY (2022) LPELR-56727 (CA); and UAM & ORS v. ANONGO (2021)
LPELR-57912 (CA), contending that where an employment relationship is governed
by statute, any wrongful or illegal dismissal automatically gives rise to a
court-ordered reinstatement. Finally, learned counsel for the claimants urges
this court to grant all of the reliefs they have sought.
2nd and 3rd
DEFENDANTS’ FACTS:
22. After
service of the originating summons and accompanying documents, the 2nd
and 3rd defendants filed a five-paragraph counter-affidavit on 23
December 2024. It was sworn by Binjin Yildep, a litigation secretary at the
Plateau State Ministry of Justice, with the defendants’ consent. Although this
filing was technically out of time, the defect was cured by an application
dated 19 December 2024 and filed on 23 December 2024.
23. In
their counter-affidavit, the 2nd and 3rd defendants
stated that they never barred the Claimants—or anyone else—from entering the
office, emphasizing that as a public institution it has always remained open.
24. They
explained that the Claimants’ salaries were halted because their appointments
were suspended and placed under review by a committee established by the 1st
Defendant. The Defendants contend that this committee found the recruitment
process to be flawed and not in compliance with the Constitution’s Federal
Character requirement.
25. The 2nd
and 3rd Defendants further contend that the Claimants were invited
and subsequently suspended because their appointments were found
irregular—having been made without the required advertisement and proper
interviews by the Appointment and Promotion Committee under the law governing
the College. They maintain that the Claimants were serving a two-year
probationary term rather than holding permanent positions, and that their
dismissal was carried out lawfully and in full accordance with the
institution’s regulations.
26. The 2nd
and 3rd Defendants maintain that the Claimants delayed to approach
the court precisely because they were aware their appointments were flawed.
They stressed that no interviews were ever held, rendering the entire hiring
process invalid. They also pointed out that the suspension was formally
announced by press release, which constituted sufficient notice to all
concerned.
27. They further argue that because the
Claimants remained on probation, the 3rd Defendant’s Rules of
Service did not fully apply to them, and their employment could therefore be
terminated at any time without completing the full procedural requirements.
They maintain that the dismissals were properly effected and that the College is
not understaffed. Even if there were vacancies, any new appointments would be
made strictly in accordance with the established procedures.
28. The 2nd and 3rd
defendants further maintain that the Claimants’ willingness to work does not
replace the institution’s formal approval, and that their failure to comply
with the College’s employment regulations warranted termination. They further
argue that granting the reliefs sought by the Claimants would substantially
prejudice them – the defendants.
THE
2ND AND 3RD DEFENDANTS’ COUNSEL’ S WRITTEN SUBMISSIONS:
29. Together with their
counter-affidavit, the 2nd and 3rd defendants lodged a written
address dated 19 December 2024 (filed on 23 December 2024) by the learned
Attorney General of the State, in which they posed three issues for
determination:
1.
Given the apparent
facts deposed in the Affidavit evidence of the Parties, whether this suit can
be properly determined via Originating Summons?
2.
Whether the
Claimants have deduced sufficient facts to warrant this Honourable Court grant
their claims?
3.
Whether as
employers, this Honourable Court can force the Claimants on the Defendants?
30. On
issue one, the defendants argued that the suit cannot be properly determined by
Originating Summons because there are serious disputes of facts in the parties’
affidavits. They relied on the cases of Macfoy v. Chola (2023) 17 NWLR (Pt.
1912) 155, Zakirai v. Muhammad (2017) LPELR-42349(SC), and Famfa Oil Ltd. v.
A-G Fed. (2003) 18 NWLR (Pt. 852) 453, which emphasize that Originating Summons
is only suitable for cases involving simple issues of law or interpretation of
documents not where there are conflicting facts.
31. They
argue that the Claimants insist they were validly employed and wrongfully
dismissed, while the Defendants counter that the appointments were irregular
and politically motivated. Those opposing assertions give rise to significant
factual disputes that cannot be resolved on affidavit evidence alone. Relying
on Oguebego v. PDP (2016) 4 NWLR (Pt. 1503) 446 and Ezeigwe v. Nwalulu (2010) 4
NWLR (Pt. 1183) 159, they submitted that the case is not suitable for
determination by Originating Summons.
32. Regarding
the second issue, the defendants argue that the Claimants had not submitted
sufficient documentation to support their case. They maintained that lawful
recruitment into the 3rd Defendant’s institution must follow a
process of public advertisement, application submission, candidate interviews,
and formal approval. The defendants noted that the Claimants produced no proof
they were subjected to or successfully completed any of these statutory
procedures.
33. Relying
on Borishade v. N.B.N. Ltd. (2007) 1 NWLR (Pt. 1015) 217 and Morohunfola v.
Kwara State College of Technology (1990) 4 NWLR (Pt. 145) 506, they emphasized
that a claimant in a wrongful termination suit must prove how the employment
was made, the terms and conditions, and who has authority to appoint or remove
them. The defendants contend that the appointments were made at the tail end of
the previous administration without due process, prompting the incumbent
Governor to review and nullify irregular employments. Therefore, the Claimants
failed to provide sufficient facts for their reliefs to be granted.
34. Regarding
the third issue, defence counsel submitted that a court cannot compel an
employer to retain unwanted staff. They argued that the Claimants’ appointments
were procedurally flawed—having been made without the Governor’s
authorisation—and thus void ab initio. In support, they relied on Heritage Bank
Ltd v. Bentworth Finance (Nig.) Ltd (2018) 9 NWLR (Pt. 1625) 420, at 434.
35. Counsel contends that
an employee serving a three-year probationary term can be lawfully dismissed
during that period, which itself may be extended. He relied on Rule 020303 of
the Civil Service Rules in support of his argument.
36. Counsel
also argues that no matter how willing an employee may be, he cannot compel an
unwilling employer to retain him, relying on Nwoye v. FAAN (2019) 5 NWLR (Pt.
1665) 193 and Chukwuma v. Shell Petroleum (1993) 4 NWLR (Pt. 289) 512.
37. Relying
on Nwosu v. A.P.P. (2020) 16 NWLR (Pt. 1749) 28, they contended that any
procedure grounded in illegality is void and unenforceable. Consequently, the
Court has no jurisdiction to compel the Defendants to appoint or retain the
Claimants, and the suit ought to be dismissed.
2nd and 3rd
DEFENDANTS PRELIMINARY OBJECTION
38. Although
dated 19 December 2024, the 2nd and 3rd Defendants’ notice of preliminary
objection was actually filed on 23 December 2024. It was accompanied by a
seven-paragraph affidavit sworn by Binjing M. Yildep, a litigation clerk in the
Plateau State Ministry of Justice. That affidavit simply repeats the facts set
out in their 23 December 2024 counter-affidavit opposing the originating
summons, which in turn duplicates the assertions made in the earlier
counter-affidavit.
39. Within,
they seek the following orders:
i.
An order dismissing this suit for want of
requisite jurisdiction.
ii.
That this suit cannot be sustained by the
claimants jointly claiming the reliefs against the defendants individually.
iii.
That this suit is contentious and therefore
ought to be brought under the normal writ.
iv.
And for further or other orders of this court.
40. Alongside
their notice of preliminary objection, the 2nd and 3rd
defendants submitted a written address in which they framed three issues for
determination as follows:
i. Whether this honourable court can hear
this matter in view of the fact that the claimants were employed separately, at
different times and for different position?
ii. Whether this honourable court has the
requisite jurisdiction to hear this matter in view of the fact that the
employments of the claimants have not been confirmed?
iii. Whether it will be appropriate for this
honourable court to determine this suit under originating summons considering
that the facts of the suit are contentious and hostile?
41.
In
addressing the first issue, counsel for the 2nd and 3rd
defendants led by P.A. Daffi, the Honorable Attorney General of Plateau State,
began by disputing the court’s jurisdiction. He argued that this type of action
must be brought by a single party rather than jointly, relying on Ebo-Ade &
Ors v. Ojo-Oniro & Ors (2018) LPELR-51498 (CA) at pages 7–10, paragraph A.
He added that, because each applicant was engaged under a separate appointment,
they should have commenced individual suits, citing Padawa & Ors v. Jatau
(2002) LPELR-5380 (CA) at pages 9–11, paragraph D.
42.
On the
second point, counsel argued that an employee serving a three-year probation
may be dismissed at any time during that term and that the probationary period
itself can be extended. He relied on Rule 020303 of the Civil Service Rules to
support this submission.
43. Counsel also argues
that no matter how eager an employee may be, he cannot compel an employer who
does not wish to retain him. He points out that these claimants had served the 3rd
defendant for only two years and were still on probation. In support, counsel
relied on Ibrahim & Anor v. National Commissioner for Colleges of Education
& Anor (2017) LPELR-45497 (CA).
44. On his issue 3, learned Counsel submitted that it is not proper for the
Claimants to institute this suit through Originating Summons. That the purpose
of instituting a suit through originating summons is to resolve issues
expeditiously and such issue often bothers on interpretation of law, deed or
contract and the issues before the court must be non-contentious. Counsel
relied on the case of Jev & Anor V. Iyortyom & Ors (2014) LPELR-23000
(SC), Zakirai V. Muhammad & Ors. (2017) LEPELR – 42349 (SC), Dapianlong
& Ors V. Dariye & Anor (2007) LPELR-928 (SC).
45. Counsel contended that
there are genuine factual disputes before the Honourable Court. A careful
review of the affidavits filed by the complainants and by the second and third
defendants/objectors, he submitted, demonstrates serious points of contention that
can only be resolved by adducing oral evidence. He relied on the decision in
Military Administrator, Federal Housing Authority & Anor v. Aro (1991)
LPELR-3185 (SC).
46. In
closing, counsel argued that resolving this dispute necessitates hearing oral
evidence from the parties, which can only occur if the action is commenced by
writ. Counsel therefore submits that:
a. The
Claimants having been employed individually cannot sustain a joint suit against
the defendants:
b. The
Claimants being under a probative period cannot sustain a claim against the
defendants.
c. The
suit being contentious and hostile in nature can only be dully adjudicated upon
through the writ of summons.
47. Finally,
learned counsel respectfully asked this Honourable Court to dismiss the suit in
the interests of justice.
1ST
DEFENDANT’S FACTS:
48. After receipt of the originating summons and related
processes, the 1st defendant, on 5 June 2025, filed a five-paragraph
counter-affidavit sworn by Azumi John, a litigation secretary at A.D. Ringsum
& Co., counsel for the 1st defendant. Although this affidavit
was filed out of time, the defect was cured by an application dated 21 May
2025, which was also filed on 5 June 2025.
49. In its counter-affidavit, the 1st defendant
avers that the claimants never formally accepted their appointments, failed to
complete the required documentation, and did not report for duty with the
College. It further alleges that the incoming State leadership uncovered a
series of last-minute recruitments across ministries, departments, and agencies
that were marred by irregularities. As a result, a Panel of Investigation was
established, and the Governor issued a white paper suspending the entire
employment process on the grounds of those irregularities.
50. The 1st defendant further asserted that, as a
public institution, the 3rd defendant never barred the claimants—or
anyone else—from entering its premises. In response to the claimants’ demand
for salaries, he maintained that they were not entitled to any payment, since
they had neither completed the necessary documentation nor resumed their
duties. He also explained that the investigating committee saw no need to
summon or interview the claimants, as all required data and information had
already been supplied by the 3rd defendant.
51. The counter-affidavit also
pointed out that the publication concerning the Claimants’ employment was based
on the White Paper’s findings, which revealed that the appointments exceeded
the number approved by the then Governor. The Defendants maintained that the
recall of workers through Exhibit E was based on the recommended and approved
number for implementation. They also stated that the notice of suspension was
properly made public through a broadcast and press release, which served as
sufficient notice to the Claimants.
52. It was further deposed that the Claimants’ appointments to
the third Defendant did not comply with the laws governing its recruitment.
When they were suspended, they remained on probation and had not yet fallen
fully under the third Defendant’s Scheme of Service. The first Defendant added
that their appointments were purely temporary and conditional, and that their
willingness to work could not cure the procedural irregularities in their
hiring. Thus, non-compliance with the third Defendant’s employment rules
justified their termination.
53. Lastly, the 1st defendant pointed out that the
Claimants have produced no evidence of receiving any salary from the third
defendant and argued that granting their requested reliefs would cause the
defendants substantial prejudice.
THE 1ST
DEFENDANT’S COUNSEL’ S WRITTEN SUBMISSIONS:
54. The 1st
defendant filed along with their counter-affidavit, a written address dated
15/5/2025 and filed on 5/6/2025 wherein they formulated a sole issue for
determination thus – “Whether the
Claimants have proved their case and are entitled to the reliefs sought”.
55. The 1st
defendant argues that the claimants have failed to discharge the burden of
proof and therefore are not entitled to any of the reliefs they seek. In a
civil action, the burden lies squarely on the claimants to establish their case
by credible evidence rather than to depend on any weakness in the defence.
Because the claimants have not adduced sufficient evidence to demonstrate their
entitlement, the defendant submits that the court should decide against them.
The defendant further relies on the decision in Akanmode v. Dino (2009) All
FWLR Pt. 471 at 929, 958-959 paras. H–A, which confirms that a defendant need
not call any witnesses where the claimant has not made out a prima facie case.
56. The 1st defendant
further submits that the Claimants did not comply with the laid down procedures
for valid employment as provided in the applicable conditions of service.
Section iii (i) states as follows: “Every appointment to an established posts
shall be conveyed in writing by the Registrar, or by the Officer authorized by
him on his behalf shall not be valid until it has been accepted in writing”.
The Claimants accordingly failed to produce sufficient materials showing that
their employments were properly processed or formally accepted in accordance
with the law. On this basis, the 1st Defendant maintains that their
appointments were irregular and invalid.
57. The 1st defendant contends that the claimants’ appointments
were made at the tail end of the previous administration without following the
required procedures. He therefore constituted an investigative committee, whose
white paper uncovered procedural irregularities and prompted the suspension of
the appointment exercise. Relying on settled authorities, the 1st defendant
submits that any action taken outside prescribed procedures is irregular and
void.
58. Moreover, the first defendant notes that the Claimants
remained within the two-year probationary period set out in their appointment
letters, meaning their posts had not yet been confirmed as substantive. On that
basis, he argues the Claimants have failed to establish valid employment or any
entitlement to relief and therefore urges the court to dismiss the suit for
lack of merit.
COURT’S DECISION:
59. In
light of the parties’ submissions, the materials before the court, and the
questions framed for determination, this court is of the view that there are
two principal issues—each embracing the remaining matters—that must be
resolved:
1.
Does this court have the requisite
jurisdiction to entertain and determine this case?
2.
Whether, in view of the facts and evidence
presented before this honourable court, the Claimants have successfully
established their claims in this suit?
ISSUE 1
60. The
first issue relates to jurisdiction and arises from the second and third
defendants’ notice of preliminary objection. It is both appropriate and
well-settled that this objection be addressed at this stage, since it questions
the court’s power to hear and decide the matter.
61. Accordingly,
issue No. 1 must be taken first since it involves a fundamental question of
law—as established in Bronik Motors Ltd & Anor v. Wema Bank Ltd (1983) 1
SCNLR 296 and Okoya v. Santilli (1990) 2 NWLR (Pt. 131) 172. The defendants
have challenged this court’s jurisdiction to hear and determine the suit on the
grounds set out in their notice of preliminary objection. Those grounds are:
1. That
the Honourable Court has no jurisdiction to hear this suit, given that the
claimants’ employment was still within their probationary period.
Particulars
a. That
the claimants were employed by the 3rd defendant, but their
appointment was yet to be confirmed.
2. That
this suit cannot be maintained as a joint action by the claimants.
Particulars
a. That
the claimants were employed separately and not jointly.
b. That
the claimants were employed at different times.
c. That
the claimants were employed for different positions.
3. This
action is contested and should therefore be commenced by the ordinary writ of
summons.
Particulars
a. That
the facts of this suit are in opposite direction in terms of that of the
Claimants and the Defendants.
b. That
the procedure in Originating Summons is only applicable in suits that are not
contentious and basically bothers on interpretation.
63. I
carefully reviewed the first ground of the 2nd and 3rd
defendants’ preliminary objection. The preliminary objection
raised by the defendants, asserting that this Honourable Court lacks
jurisdiction to hear the suit because the claimants' employment were still
within their probationary period and their appointment was yet to be confirmed,
is misconceived and ought to be dismissed. This court possesses exclusive
jurisdiction over labour and employment matters, irrespective of the
probationary status of an employee.
64. Firstly,
it is fundamental to understand the expansive jurisdiction of the National
Industrial Court of Nigeria. By virtue of Section 254C (1) of the Constitution
of the Federal Republic of Nigeria, 1999 (as amended), the NICN is vested with
exclusive jurisdiction in civil causes and matters relating to or connected
with any labour, employment, trade unions, industrial relations, and matters
arising from the workplace, conditions of service, including health, safety,
welfare of labour, employee, worker and matters incidental thereto or connected
therewith. This constitutional provision establishes the NICN as the primary
forum for resolving all disputes arising from an employment relationship. The
mere fact that an employee is on probation does not remove the employment
relationship from the ambit of the NICN's jurisdiction.
65. Secondly,
an employment relationship, whether probationary or confirmed, is still a
contractual relationship. Section 81(1) of the Labour Act, Cap L1 LFN 2004,
explicitly grants jurisdiction to a court to hear complaints where "any
question, difference or dispute arises as to the rights or liabilities of a
party to a contract or touching any misconduct, neglect, ill-treatment or
injury to the person or property of a party to a contract." This provision
clearly indicates that disputes arising from an employment contract, even
during a probationary period, are justiciable. The existence of a contract of
employment, regardless of its stage (probationary or confirmed), is sufficient
to invoke the jurisdiction of the court, particularly the NICN, which specializes
in such matters.
66. Furthermore,
the argument that an unconfirmed appointment divests the court of jurisdiction
conflates the merits of the case with the court's power to hear it. While the
terms of a probationary employment may allow for termination with less
formality or notice, as seen in cases like NITEL PLC & ANOR v. AKWA ((2005)
LPELR-5971(CA) Pp. 24-26, Paras. B-A), where the Court of Appeal acknowledged
an employer's right to terminate during probation, this does not mean the court
cannot inquire into whether such termination was done in accordance with the
terms of the probation or the law. The court's jurisdiction is to determine
whether the rights and obligations under the probationary contract were
breached or properly exercised. The question of whether the termination was
lawful or wrongful is a matter for the substantive hearing, not a
jurisdictional bar.
67. In
ASCA BITUMEN CO. LTD v. ISAH (2016) LPELR-40778(CA), the Court of Appeal
emphasized what a party needs to plead when their cause of action is founded on
a contract of employment. This underscores that the existence of a contract,
even if probationary, forms the basis of the action, and the court has the
jurisdiction to interpret and enforce its terms. The conditions of service,
even for probationary employees, constitute the terms of their engagement. The
failure to confirm an appointment or the termination during probation are
actions taken within the framework of an existing employment contract, which
the NICN is empowered to adjudicate.
68. Hence,
this ground of preliminary objection fails. The court’s jurisdiction depends
not on formal confirmation of an appointment but on the presence of an
employment relationship and a dispute arising from it. Even as probationary
staff, the claimants qualify as employees entitled to invoke the National
Industrial Court’s jurisdiction for any alleged breach of their contract or
infringement of their labour rights. The court is fully empowered to hear the
case and decide whether the third defendant acted consistently with the terms
of probationary service and the applicable labour laws.
69. On
the second ground of the defendants' preliminary objection, it is noteworthy
that it is not in dispute that the claimants were offered employment by the 3rd
defendant on different dates. The Claimants expressly stated in paragraph 3 of
the affidavit supporting the originating summons that, "We were granted
employment by the 3rd respondent at various times within the year
2022 via our respective letters of appointments issued to us upon our
respective applications….”
70. Their
letters of employment tendered as (Exhibits A1 and A2) leave no doubt as to the
factuality of that position. These documents speak for themselves, as it is
well established principle that documentary evidence is the best evidence, for
the reason that it speaks for itself - A.G
Bendel State v. U.B.A Ltd (1986) 4 NWLR (PART 37) 547; Akinbisade V. The State
(2006) 17 NWLR (PART 1007)184 SC.
71. The 2nd
and 3rd defendants contend that these claimants cannot sue jointly
since they were employed separately and not jointly. They also based their
argument on the ground that the claimants were employed in different positions
in the 3rd defendant institution.
72. The
sustainability of this ground of objection raised by the 2nd and 3rd
defendants, contending that the claimants cannot sue jointly due to separate
employment and different positions, hinges on the principles governing joinder
of parties in civil litigation. While the defendants' argument highlights
individual contractual relationships, the overarching consideration for joinder
of plaintiffs is whether their claims arise from the same act or transaction or
series of acts or transactions, and whether there would be common questions of
law or fact if separate actions were brought.
73. It
should be noted at this point that the stipulations of Order 13 Rule 1 of the
court's Rules clearly address the matter of joining parties as
claimants/claimants. These Rules state the following: “All persons may be
joined in one action as claimants in whom any right to relief is alleged to
exist whether jointly or severally and judgment may be given for such
claimant(s) as may be found to be entitled to relief and for such relief as the
claimant may be entitled to without any amendment.” See also: Ibigbami &
Anor V. Military Governor, Ekiti State & Ors. (2003) LPELR- 5619 (CA);
Registered Trustee, N.A.C.H.P.N V. M.H.W.U.N (2008) ALL FWLR (PT. 412) P.1013.
This court, like all courts, is obligated to use its authority to prevent
multiple lawsuits by employing the joinder of parties to resolve such issues in
a single case. See: Akpamgbo Okadigbo & Ors. V. Chidi & Ors.
(2015) LPELR- 24564 (SC).
74. The
defendants' objection focuses on the individual nature of the employment
contracts and the differences in positions. However, this does not
automatically preclude joint action. The critical factor is the nexus between
the claims. If the claimants' grievances, despite their separate engagements
and differing roles, stem from a common policy, a series of related actions by
the defendants, or a single event that affected them all in a similar legal
manner, then joinder would be permissible. For instance, if all claimants were
victims of a mass layoff, a discriminatory policy, or a breach of a general
condition of service applicable to a class of employees, their claims, though
individually proven, would share common questions of fact and law.
75. The
Court of Appeal in ENUGUNUM & ORS v. CHEVRON (NIG) LTD ((2014)
LPELR-24088(CA) Pp. 23-24, Paras. B-C), addressed the question of whether
employees with the same conditions of service have a collective right to sue or
to be represented in a suit. While the present query mentions 'different
positions', the underlying principle from Enugunum case is that a commonality
in the cause of action or the nature of the grievance can justify collective
action. If the claimants, despite their different positions, are challenging a
common act or omission by the defendants (e.g., a wrongful termination policy,
a breach of a general employment agreement, or a failure to pay certain
entitlements that apply across various roles), then the objection based solely
on separate employment and different positions may not be sustainable. The
court will look beyond the superficial differences in employment terms to the
substance of the claims.
76. Furthermore,
the case of UNION BANK v. UGBE & ORS ((2019) LPELR-47893(CA) P. 24, Paras.
B-C), highlights that while plaintiffs can join in an action, they cannot set
up conflicting claims between themselves. This implies that if the separate
employment and different positions lead to claims that are inherently
contradictory or mutually exclusive, then the joinder might be problematic.
However, if the claims, though distinct in their individual details, are
consistent in their overall objective and do not conflict, this case would not
support the defendants' objection.
77. Therefore,
the defendants’ objection is unlikely to succeed if the claimants’ separate
disputes, though based on different appointments and positions, actually arise
from the same act or series of acts by the defendants and turn on common
questions of law or fact. The court will look to the substance of the claims
and the efficient administration of justice rather than technical distinctions
between individual contracts. If the claimants can show a shared link or nexus
in their causes of action, the joinder objection will probably fail. It is for
the defendants to prove that trying the claims together would cause
embarrassment or delay, or that the claims are so unrelated they cannot be
conveniently heard in one proceeding. In the absence of such a showing—and
given the court’s preference to avoid multiple suits—the objection is unlikely
to stand.
78. It
should be noted that the 2nd and 3rd defendants both misconstrued and
misapplied the ruling in Ebo-Ade & Ors v. Ojo-Oniro & Ors (supra), upon
which they heavily relied. In fact, that decision affirms the propriety of
joint proceedings, even though its facts differ from those in the present case.
The second ground of objection is hereby dismissed. It is
indeed ironic that the 2nd and 3rd defendants invoke this
objection when they themselves used a single instrument to terminate both
claimants, despite each having a separate employment. On that basis alone,
upholding their objection would be unjust.
79. Regarding
the third issue, Counsel to the 2nd and 3rd Defendants
argued that the Claimants initiated this case using an originating summons,
which they believe is an incorrect procedure. Counsel contends that, given the
contentious issues between the parties in this case, a formal writ of complaint
should have been used instead.
80. Meanwhile,
ORDER 3 (1)(b) NATIONAL INDUSTRIAL COURT (CIVIL PROCEDURE) RULES 2017 and
specifically, Order 3(3) of the said Rules states and I quote: “Civil
proceedings that may be commenced by way of originating summons include matters
relating principally to the interpretation of any constitution, enactment,
agreements or any other instrument relating to employment, labour, industrial
relations in respect of which the court has jurisdiction by virtue of the
provisions of section 254C of the Constitution of the Federal Republic of
Nigeria 1999 (as amended) or by any Act or Law in force in Nigeria.”
81. The
legal stance outlined in the court's rules has been consistently upheld in
various judicial decisions. For instance, in the case of Pam & Anor V.
Nasiru Mohammed & Anor (2008) 16 NWLR (PART 1112)1, Justice Oguntade
articulated the following: “It is trite therefore that originating summons is
the appropriate procedure where what is in dispute is the simple construction
or interpretation of document in respect of which pleadings are unnecessary”.
82. Even if the defendants
contend there are factual disputes, the real issue is legal: who is empowered
to appoint or remove staff at the third defendant institution. The claimants
rely on uncontested documents—their letters of appointment, the Conditions of
Service, and the Plateau State College of Health Technology Law, 2003—and the
sole question is how those instruments should be interpreted in light of the
first defendant’s statutory powers.
83. I therefore conclude
that this matter is predominantly a legal question rather than a factual one
and was correctly initiated by Originating Summons since it seeks to interpret
the statutory and administrative powers of the 1st Defendant rather than resolve
conflicting facts. Accordingly, the Claimants’ use of Originating Summons is
appropriate, and the jurisdictional objections raised by the 2nd and
3rd Defendants are dismissed.
ISSSUE
TWO:
84. On
this point, the court must determine whether the claimants have established
their case and are entitled to the remedies they request. In examining this
second issue, the court will focus on the specific questions the claimants have
raised and address each in turn. The three questions set out in the originating
summons are:
1. Whether
the 1st Defendant is possessed of or clothed with the powers or
authority to unilaterally suspend, terminate, nullify or in any way interfere
with the employments and appointments of the Claimants through Exhibits D and
E, the Claimants having been in the service and employment of the 3rd
Defendant.
2. By
virtue of the letters of appointment issued to the Claimants attached as
Exhibits A1 – A2, whether the Claimants are not entitled to maintain and retain
their employment with the 3rd Defendant in line with the extant laws
regulating their employment with the 3rd Defendant.
3. Whether
the failure and refusal of the 3rd Defendant to pay the Claimants
their salaries and allowances thereby retaining same from the month of January
2023 till date or any period of time at all is not unlawful, unjust, illegal
and a violation of the 3rd Defendant’s duties and obligations.
85. Because
questions 1 and 2 are interrelated, the court will consider them together. At
bottom, the issue is whether the 1st defendant had authority to terminate the
claimants’ employment. If he did not, the court must then determine whether the
claimants have the right to remain in their positions at the third defendant’s
institution and to recover their unpaid salaries – if any.
86. It is
a well-settled rule that in civil proceedings the claimant carries the burden
of proof; until that burden is discharged, the defendant need not call any
evidence. A party asserting infringement of rights or seeking a remedy must
succeed on the strength of its own case, proving facts on a balance of
probabilities as prescribed by sections 131 and 135 of the Evidence Act 2011.
In wrongful-dismissal suits specifically, the claimant must first establish the
contractual terms and conditions governing the employment relationship and then
show how the employer breached them – refer to Katto v. Central Bank of Nigeria
(1999) 6 NWLR (Pt. 607) 390–394.
87. The
claimants based their case on the affidavit filed in support of the originating
summons and on their counsel’s submissions. In paragraph 6 of that affidavit,
they averred that they duly discharged their duties under the third defendant
in line with their respective letters of appointment, the third defendant’s
Conditions of Service for Staff, and the Plateau State College of Health
Technology Law, 2003, all of which were annexed as Exhibits B and C.
88. By
contrast, the defendants maintained that the claimants’ appointments were
vitiated by procedural irregularities and thus never validly constituted. They
further asserted that the Governor lawfully terminated the claimants’
employment after following the proper process, which included establishing a
preliminary committee both before and after their suspension and dismissal.
89. It is
important to highlight that there are three categories of employments
relationships;
1. a
simple master-servant relationship governed by common law;
2. employment
in which the office is held at the pleasure of the employer
3. employment
protected by statute.
See:
Iderima v. R.S.C.S.C. (2005) 7 SC (PART 111) 135; Olaniyan v. UNILAG (1985) 2
NWLR (PART 9) 599.
90. Where
an employment is held at the pleasure of the employer, it is regarded as one at
will. In such a case, the employer retains the discretion to terminate the
employment at any time, irrespective of the of the tenure stated in the
contract. This principle was clearly restated in the case of Olaniyan & Ors
V. University of Lagos (Supra) at 599/612.
91. On
the other hand, it is settled law that where an employment enjoys statutory
flavor, the relationship between the employer and employee relationship is
regulated by the provisions of a statute or regulation derived from a statute.
The Supreme court elaborated on this principle in the case of Imoloame V. West
African Examinations Council (1999) 9 NWLR (265) 303 stated as follows:
“there is an employment with
statutory flavor when the appointment and termination is governed by statutory
provision. It is accepted that where the contract of service is governed by
provision of statute or where the conditions of service are contained in
regulation derived statutory provisions, they invest the employee with a legal
status higher than the ordinary one of master and servant. They accordingly
enjoy statutory flavour.”
92. It
suffices to ask at this juncture the following questions:
(a). Is the 3rd defendant a
body created by statute?
(b). Does the enabling
statute or a regulation derived from it make express provisions regulating the
employment of the category of these claimants in question?
93. There
is no gainsaying that the 3rd defendant institution, the claimants’
employer, is a creation of statute. The claimants aver that their employments
are subject to the 3rd
Defendant’s Condition of Service for Staff and the Plateau State Health
Technology Law, 2003. [See – Paragraph 6 of the Affidavit in
Support of the Originating Summons]. This fact is unchallenged. The said
averment is in consonance with paragraph 7 of the letters of offer of
employment of the claimants (Exhibits A1 – A2), which state clearly as follows:
“That you will be
subject, in all respects, to all conditions of service stipulated in the scheme
of service and other College Regulations and Instructions, as may be reviewed
by the Council from time to time.”
94. Regarding
the claimants’ positions at the 3rd defendant’s institution, I am
satisfied that their appointments are statutorily protected. That protection is
not undermined by the defendants’ assertion that the claimants were still on
probation when they were purportedly terminated. The appellate court’s decision
in Babatunde v. Governing Council, Federal Polytechnic, Ede & Anor is
directly on point, and I will set out the relevant passage from that judgment
below:
“the question that determines
whether an employment has statutory flavour is not whether the status of the
employee is on the higher echelon or low ladder of the service. It is also not
determined by whether an employee is on probation or a permanent or a confirmed
employee. It is rather whether the terms of engagement are controlled and
determined by statute as relating to engagement and termination.”
95. Having
determined that the claimants are statutory employees of the 3rd
defendant whose employment can only be terminated in accordance with its
enabling statute or any regulations or subsidiary instruments, it is therefore
necessary to examine how the defendants actually brought their employment to an
end.
96. The
affidavit evidence shows that the 1st defendant allegedly suspended
the claimants and, by means of published notices, purported to terminate their
employment. That suspension lies at the heart of this dispute and raises the
question whether the 1st defendant was entitled, both lawfully and
properly, to bring the claimants’ service to an end.
97. Accordingly,
the claimants firmly reject the first defendant’s claimed power to bring their
employment to an end. It is a well-settled principle—reflected in section 11 of
the Interpretation Act (Cap.192, 1990)—that the authority to appoint carries
with it the authority to dismiss. Yet this Court has already found that the
College (the third defendant) is, and always has been, the claimants’ only
employer. The defendants, by contrast, contend that the Governor, as Visitor of
the College, validly exercised his visitorial prerogative to terminate their
appointments.
98. Having
considered the claimants’ evidence, the burden of proof has plainly shifted to
the defendants. They must now demonstrate that the 1st defendant validly
exercised the authority under which the claimants’ employments were terminated.
99. In
explaining a litigant’s duty to establish his case, the Court of Appeal in
Aliyu & Ors v. Yola & Ors (2022) LCN/16188 (CA) stated, inter alia, as
follows:
“the
burden is on the plaintiff to establish his claim. This is the evidential
burden of proof. It is only after the plaintiff has adduced sufficient credible
evidence that the burden of proof would shift to the defendant. The shifting
burden of proof is enacted in Section 136 of the Evidence Act 2011, and
it provides that the burden of proof as to any particular fact lies on the
person who wishes the Court to believe in its existence unless it is provided
by any law that the proof of that fact shall lie on any particular person. But
the burden may in the course of a case be shifted from one side to the other.
As explained in ADIGHIJE v. NWAOGU (2010) 12 NWLR (PT.1209) 419 @
463: “Section 137 of the Evidence Act, 2004 (now Section 133 (1)
Evidence Act, 2011)”.
100. I
have reviewed the entire record to identify any authority showing that the 1st
defendant lawfully possessed power to suspend and terminate the claimants—who
were employees of the 3rd defendant—but I find no provision in the statute
establishing the College that vests such authority in the Governor.
101. In
response to the defendants’ contention that the claimants remained on probation
with the 3rd defendant at the time their employments were
terminated, Exhibits A1 and A2 shed light on probationary terms and related
provisions. Paragraph 3 of each letter of appointment reads in material part:
“That you serve on probation for two years or for such longer period as may be
deemed available.”
102. The
claimants did not specify the precise dates of their suspension or dismissal.
However, their appointment letters (Exhibits A1–A2) are dated 2022, and this
suit was filed on September 30, 2024—approximately one year and ten months
later, i.e. under two years. It follows that their employment was terminated
during their probationary period.
103. It is important to
state that the fact that the claimants were still on probation does not negate
the statutory nature of their employments. Their employments can only be
determined in accordance with the statutes and relevant instruments of the 3rd
defendant institution. See Babatunde V. The Governing Council Federal
Polytechnic, Ede & Anor (supra).
104. For the avoidance of
any doubts, the contents of exhibits A1 – A2 are clear on issues of discipline
or termination during probationary periods. The excerpt below from exhibits A1
– A2 is relevant to resolving the issue at hand:
(iv).
That within your probationary period, if it is established to the satisfaction
of the Governing Council/College Management that you are not qualified for
efficient service, your appointment may be terminated at any time without
compensation.
(v)
That while you remain on probation, unless you are summarily dismissed, your
engagement may any time be terminated by you or by the College subject to one
Calendar Months’ Notice or, with the consent of the College, by the payment of
a month’s salary in lieu of notice.
105. The wording of those
instruments is plain and unambiguous. They clearly allow for termination
without compensation during the probationary period, but only if the Governing
Council/College Management—whose duty it is to determine an employee’s
unfitness for efficient service—so directs. There is no evidence before this
court that the College’s Governing Council or Management participated in the
claimants’ suspensions or dismissals without notice or pay. It therefore rings
hollow for the defendants to insist that, because the claimants held different
positions, each must bring a separate action.
106. I find, without
hesitation, that the defendants have failed to establish that the first
defendant retains any residual authority to suspend or terminate the claimants’
employment when, under their terms and conditions of employment, that power
lies exclusively with the Governing Council/College Management.
107. The defendants
maintain that a committee was set up both before and after the claimants’
suspensions. According to the 2nd and 3rd defendants, the
claimants were asked to appear before that committee but did not do so. The 1st
defendant, however, insists no invitation or interview was necessary since all
pertinent information had already been supplied by the 3rd
defendant. The claimants strongly deny these assertions. Notably, there is no
evidence before this court that the claimants—or anyone acting on their
behalf—were ever summoned to such a committee, nor is there any record of the
committee’s resolutions. Accordingly, the court is not satisfied that any
invitation to appear was issued to the claimants either before or after their
alleged terminations.
108. I am also aware that
the defendants stated further in their defence that the claimants’ employments
were not advertised and that the employments were marred by irregularities. In
my mind, what the defendants failed to prove is the fact that the purported
failure (if any), to adhere to the employment procedures or guidelines, is the
claimants doing and not the defendants’.
109. In Nigerian labour
law, the general principle is that 'he who asserts must prove.' This principle
is fundamental to the adversarial system and is enshrined in the Evidence Act.
So, when a claimant asserts wrongful termination of employment, the initial
burden lies on the claimant to prove the existence of the contract of
employment, the terms and conditions of that contract, and that the defendant
is their employer. This position was affirmed in cases such as AJI v. CHAD
BASIN DEVELOPMENT AUTHORITY & ANOR (2015) LPELR-24562(SC) and INEC v.
OMOTOSHO & ORS (2021) LPELR-56626(CA). Once the employee establishes these
foundational facts, the burden then shifts to the employer to justify the
termination or to prove any alleged breach of the contract by the employee, or,
as in this scenario, to prove the alleged irregularities in the employment
process.
110. In the scenario
presented, the defendants are alleging that the claimants' employments were not
advertised and were 'marred by irregularities.' For these allegations to hold
any legal weight, the burden of proving these irregularities rests squarely on
the defendants. It is not enough for the defendants to merely state these facts
in their defence; they must adduce credible, cogent, and admissible evidence to
substantiate their claims. This includes providing evidence that the employment
procedures or guidelines existed, that they were breached, and crucially, the
nature and extent of these irregularities. The Court of Appeal in MAINSTREET
BANK REGISTRARS LTD v. AHAIWE ((2019) LPELR-47057(CA) emphasized the effect of
failure to prove conditions of service in a claim for its breach, which by
analogy, extends to proving the conditions or procedures that were allegedly
breached during employment.
111. Furthermore, even if
the defendants succeed in proving that there were procedural irregularities,
they must go a step further. They need to demonstrate that these purported
failures to adhere to employment procedures or guidelines are attributable to
the claimants, or that these irregularities fundamentally vitiate the
employment contract itself. If the irregularities were a result of the
defendants' own internal administrative failings, or a breach of their own
internal rules, it would be difficult for them to use such failings as a
defence against the claimants, especially if the claimants were not complicit
in or aware of these irregularities. An employer cannot typically benefit from
its own wrong or negligence in following due process.
112. It must be stated
unequivocally that the reasons for terminating the claimants—or, put
differently, the justification for their suspension and termination—are
irrelevant to this suit. The real issue is whether the proper procedure was
followed and whether the authority to suspend or terminate their employment
properly lies with the 1st defendant, the State Governor and Visitor
of the 3rd defendant.
113. After reviewing all
the evidence, this Court finds that the defendants did not observe the
applicable statutory and regulatory requirements when purporting to suspend and
terminate the claimants’ employment. Those suspensions and terminations are
therefore unlawful, illegal, null and void. The 1st defendant, as
Governor or Visitor of Plateau State College of Health Technology, had no power
to suspend or terminate the claimants’ appointments in that manner. I so hold,
and answer question one in the claimants’ favor.
114. Respecting the
claimants’ claim for unpaid salaries, they assert that before the announcement
of their suspension, the 3rd defendant had paid their respective
salaries all through to the month leading to January 2023 and ceased to pay
their salaries from January 2023 till the date of filing this suit. It is
important to note that the 1st defendant deny this assertion made
and stated that there is no proof that the claimants received any salary from
the 3rd defendant based on the claimants assertion.
115. Apart from the
claimants’ averments in their affidavit, which the defendants denied in their
counter affidavit, there is no other evidence whether in the form of an account
statement or salary/payment slip to establish the claim that the claimants were
not paid their salaries or to show the last month when the claimants received
their salaries. It is trite that evidence is the medium of proof, and proof is
the essence of evidence - Anekwe V. State (2014) ALL FWLR (PART 744) 92 AT 109
(SC). The dearth of evidence to support the claims of salary arrears by the
claimants is fatal to them. Consequently, this court is not convinced that the
claimants have provided satisfactory evidence of arrears of owed salaries from
January 2023 – to date. I so hold.
116. Essentially, question
three for determination is resolved partly in favour of the claimants.
117. Consequently, question
1 of the originating summons which is “whether the 1st respondent is
possessed of or clothed with the powers or authority to unilaterally suspend,
terminate, nullify or in any way interfere with the employments and
appointments of the claimants through Exhibits D and E, the claimants having
been in the service and employment of the 3rd defendant”, is
answered in the negative.
118. Question 2 of the
originating summons which is, “by virtue of the various letters of appointment
issued to the claimants attached as Exhibits A1 – A2, whether the claimants are
not entitled to maintain and retain their employment with the 3rd
defendant in line with extant laws regulating their employment with the 3rd
defendant”, is answered in the affirmative.
119. Question 3 of the
originating summons which is “whether the failure and refusal of the 3rd
defendant to pay the claimants their salaries and allowances thereby retaining
same from the month of January 2023 till date or any period of time at all is
not unlawful, unjust, illegal and a violation of the 3rd defendant’s
duties and obligations,” is resolved in the negative in the absence of specific
prove.
120. Therefore, for the
sake of clarity and the avoidance of any doubt whatsoever, this court hereby
grants only the following reliefs sought:
a.
A declaration that the 1st
defendant has no power or authority to suspend, terminate, nullify or in any
way interfere with the employments/appointments of the claimants duly engaged
in the services and employment of the 3rd defendant.
b.
A declaration that the purported termination,
nullification and cancellation of the employments and appointments of the
claimants by the 1st defendant
through exhibits D and E, is unlawful, illegal, null and void with no
legal effect whatsoever.
c.
A declaration that the claimants are entitled
to maintain and retain their respective employments with the 3rd
defendant in line with the extant laws regulating their employments.
d.
An order setting aside the purported
suspensions and subsequent terminations, nullifications and cancellations of
the claimants’ appointments and employments made by the 1st
defendant through the publications made at his instance attached as exhibits D
and E, same having been done ultra vires and therefore unlawful, null and void.
e.
An order reinstating the claimants back to
their respective positions as staff and employees of the 3rd
defendant in line with their respective letters of appointments attached as
exhibits A1 – A2) respectively.
f.
N2,000,000.00 (Two Million Naira) general
damages against the defendants jointly and severally for the collective pain
and suffering imposed on the claimants by the defendants. The judgment,
including the monetary awards, must be satisfied within 30 days of this
decision. Should the defendants fail to comply, interest will accrue on the
unpaid money at 5% per month until full payment is made.
121. In
view of the findings and decisions of this court as reflected above, reliefs
numbers 1, 2, 3, 5 and 6 of the originating summons are granted, while reliefs
4, 7, 8 and 9 are hereby denied. Cost of this suit is awarded in favour of the
claimants in the sum of N250,000.00 only.
122. Based
therefore on the above findings, this court is satisfied that the claimants’
case succeeds in part. I hereby enter judgment for the claimants as stated
hereinbefore.
Delivered in Jos this 10th
December 2025.
Hon
Justice Ibrahim Suleiman Galadima
Judge.
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