Appeal No: CA/PH/361/2019 – Chief Thompson Joseph Ibulubo & 5 Ors v. Dr. Alfred Seminitari Abam & 4 Ors

Appeal No: CA/PH/361/2019 – Chief Thompson Joseph Ibulubo & 5 Ors v. Dr. Alfred Seminitari Abam & 4 Ors

We represented the 3rd, 4th, and 5th Respondents in this appeal, in which final judgment was delivered by the Court of Appeal of Nigeria on 5 February 2026.

Background Facts

Following the death of the erstwhile Amayanabo (King) of Okrika in Rivers State, Nigeria, Late King S.P.U. Ogan, Ado VIII, a dispute arose as to who was the rightful person to succeed the Late Amayanabo and, by necessary implication, who between the 1st Appellant and 1st Respondent was rightfully crowned and installed as the Amayanabo of Okrika.

The Appellants instituted the action at the lower court, the Rivers State High Court, contending that their house, the Ibulubo House, is entitled to produce the next Amayanabo of Okrika. They claimed that they are among the ruling houses of Okrika that make up the Ado Royal Family, all of whom are entitled to produce the Amayanabo, and that it was their rightful turn to do so, the other houses having produced the Amayanabo at some point.

They further contended that although the other five ruling houses—Abam, Dokube, Fibika, Ibanichuka, and Ogan—were the original ruling houses, their house (Ibulubo House), which broke out from Dokube House to become an independent house in 1971, is now also part of the ruling houses and entitled to produce the next Amayanabo, having never produced one unlike the other five.

In proof of their case at the High Court, the Appellants relied heavily on two documents signed in 1997, alleging that both documents constituted an agreement by all ruling houses and the Late Amayanabo that the Ibulubo House would produce the next Amayanabo of Okrika, over and above the Abam House, which had been in existence long before it.

In firm denial of the Appellants’ claims, the Respondents tendered and relied on a judgment of the Supreme Court of Nigeria, as well as a duly gazetted official document of the Rivers State Government recognizing the Ado Royal Family as comprising only five houses—Abam, Dokube, Fibika, Ibanichuka, and Ogan. Notably, the Government Gazette did not include the Ibulubo House, which significantly weakened the Appellants’ case.

At the end of the trial, the lower court dismissed the case of the Appellants (then Claimants) and held that the Ibulubo House is not among the ruling houses of Okrika and cannot produce the Amayanabo of Okrika at any time.

Aggrieved by the judgment, the Appellants filed this appeal at the Court of Appeal. The appeal was heard on 24 November 2025, and judgment was reserved thereafter. I.M. Abibo, Esq., led the team representing the 3rd, 4th, and 5th Respondents.

Judgment

In its judgment, the Court of Appeal formulated two issues for determination.

In resolving the first and principal issue (considered as the fulcrum of the entire appeal), the court held that the Appellants failed to prove that their house (the Ibulubo House) is or was at any time among the ruling houses of Okrika entitled to produce the Amayanabo.

On the second issue, the court held that the trial court was wrong in ordering the Rivers State Government to recognize the 1st Respondent because the 1st Respondent did not seek such a relief. The Court of Appeal re-emphasized that a trial court ought not to act like “Father Christmas” or “Santa Claus” by granting a relief in favour of a party when such relief was not specifically sought by that party.

Granville Abibo & Co

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