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A Judicial Misconcpetion of Mosque Dispute in a Common Law Jurisdiction: The Supreme Court's Declaration of High Court's Jurisdiction in Imamship Dispute in Nigeria
(Miyyeti Research and Publications, 2017-03) Syed Abdulkader, Sharifah Zubaida; Ishola, Abdullahi Saliu
The Supreme Court of Nigeria declares jurisdiction for the State High Court in Imamaship Disputes on the ground that such disputes does not fall within the purview of Islamic Personal Law matters as spelt out in the 1999 Constitution of the Federal Republic of Nigeria. Whereas waqf is listed as an Islamic law personal law matter and Mosque is by law considered a waqf. This implies that Imamahsip dispute is a waqf management dispute. Therefore, the State High Court ought not to have jurisdiction. This paper examines the decision of the Supreme Court in the case of Abdulasalam v. Salawu whereas the erroneous decision as reached.
A New Guide to the Principles and Practice of Mīrāth in Nigeria
(Centre for Islamic Heritage, Al-Hikmah University, Ilorin - Nigeria, 2022-04) Arikewuyo, Nafiu Ahmad; Ishola, Abdullahi Saliu; Waliyullahi a. Adeyemi
This book contains five chapters covering various subjects on on Shariah Practice, Principles of Islamic Inheritance, Practical aspects of Islamic Inheritance and case studies. The chapters are written by experienced scholars who are practitioners and specialists in the field.
A SWOT Analysis of the Dispute Resolution Mechanisms in the Islamic Finance Industry in Malaysia
(Grosvenor House Publishing Limited, 2020) Zubair, Aishat Abdul-Qadir; Professor Dr. Rabiah Engku Adawiah Ali
This chapter is divided into seven sections. The first section gives a general introduction and section two examines the court process as a mechanism for the resolution of Islamic finance disputes in Malaysia. This is followed by the third section that evaluates the use of arbitration under the auspices of the Kuala Lumpur Regional Centre for Arbitration (KLRCA). Section four deals with the court-annexed mediation under the auspices of Kuala Lumpur Court Mediation Centre (KLCMC); while section five deals with mediation/adjudication under the auspices of the Financial Mediation Bureau (FMB). The process of mediation under the Malaysian Mediation Centre (MMC) is the main aim of section six while the last section which is section seven gives a general conclusion.
Administration of pension funds under Nigerian new contributory pension scheme: A review under Islamic Law
(Faculty of Law, Kwara State University, Malete., 2022-12-31) Onikosi Ahmeed Adedeji; Adekunle A . Aminu; Ahmed A. Muhammed-Mikaaeel
Search for financial security after active service years of employees in Nigeria gave birth to pension scheme regimes in Nigeria. The focus point of the new pension scheme is security of funds and reasonable investment for profitability. Lots of Muslim subscribers have been complaining against the present administration regime of their pension funds. Hence, this paper examines the administration of funds under the new contributory pension scheme from Islamic law perspective. The paper adopts doctrinal method of legal research. It was discovered that Shari’ah is very much interested in what happens to Muslim funds inclusive of the pension funds. The paper discovered further that the administration of pension funds in Nigeria is marred with gharar, riba and maisir and thus violates Shari’ah tenet. The paper discovered also that the present structure of pension scheme in Nigeria which lacks Shari’ah Advisory Board has been responsible for the continuous violation of Shari’ah tenet in the administration of pension funds. The paper thus principally recommends amendment of the extant pension regime to pave way for Shari’ah Advisory Board to guide on administration of pension funds.
Alternative Dispute Resolution in Family Disputes: An Appraisal of Financial and Property Rights of Muslim Women in Nigeria.
(Jabatan Kehakiman Syariah Malaysia & Ahmad Ibrahim Kulliyah of Laws, Malaysia, 2021) Zubair, Aishat Abdul-Qadir; Kudirat Magaji Owolabi Wopa
In Nigeria, Muslim women hardly enjoy the rights which may avail them in Shari‘ah during the marriage or at divorce. Financial support and property rights are fundamental issues that need to be resolved. Hence, depriving women of their entitlement of these rights often leave them at an economically disadvantaged position. The implication of this situation to the society at large cannot be overemphasised since women build generations in years to come. The current position of the Common law as well as the strict property rights approach of the courts clearly cannot offer justice to women. Hence, there is need for alternative route to access justice. The article aims to examine the aptness of Alternative Dispute Resolution (ADR) mechanisms in family disputes related matters and hindrances to the use of ADR to enforce financial and property rights of women in Nigeria. The article recommends among others the amendment of the Marriage Act, Matrimonial Cause Act and Matrimonial Causes Rule, Court Rules to capture both Islamic and conventional ADR mechanisms and enforcement of its outcome.
AMNESTY AS ANTIDOTE TO TERRORISM: LEGALITY OR OTHERWISE UNDER INTERNATIONAL AND ISLAMIC LAWS
(DEPARTMENT OF ISLAMIC LAW FACULTY OF LAW, AL-HIKMAH UNIVERSITY, ILORIN, NIGERIA, 2019-06) Salman, Kamaldeen Olaitan
The menace of terrorism is increasing geometrically across the globe. Many lives and properties have been lost in the process and the losses are still counting. Many countries of the world have been affected including Nigeria. In Nigeria, Bokoharam have established themselves as dreadful terrorists in the North Eastern part of the country. They have claimed many lives, destroyed many properties and left other permanently maimed for life. This has caused for serious concern with a view to finding a lasting solution to the unfortunate situation. This made the Federal government of Nigeria to propose granting amnesty to the dreadful Bokoharam with a view to laying their menace to rest. Hence, this study, which is essentially literature based with particular emphasis on the relevant international legal framework on the concept of terrorism and amnesty as antidote for the menace of terrorism as well as various relevant injunctions from the Holy Qur’an, examines the subject matter of this research both under the international law and Islamic law. The study also examines the effect of amnesty and its impact on terrorism under the two areas of law. The paper argues that amnesty is a valid solution to act of terrorism both under the International and Islamic Laws. The article further stated that if the identified and highlighted conditions stated for sincere repentance by the terrorists are met, amnesty stands a better chance of eradicating the menace of terrorisms in Nigeria. The study recommends that the federal government should strictly ensure that the Bokoharam terrorists meet the conditions of repentance before they could be granted amnesty as was done in the West in the past.
An Analysis of Dispute Resolution Mechanisms in the Islamic Banking and Finance Industry in Malaysia
(Fakultas Hukum Universitas Ahmad Dahlan, 2020) Zubair, Aishat Abdul-Qadir
Introduction to The Problem: With the increasing boost to the Malaysian Islamic finance industry and the sophistication experienced in the industry with regards to product development, there is a substantial downside of such enviable achievements, which is the gradual surge in the number of disputes involving Sharia-compliant transactions. It is therefore important to analyse the existing dispute resolution mechanisms in the Islamic finance industry in Malaysia. Purpose/Objective Study: The article aims to analyse the court system as a dispute resolution mechanism as well as the other alternative dispute resolution mechanisms available to parties in resolving the dispute in the Islamic banking and finance industry in Malaysia. Design/Methodology/Approach: This study adopts a doctrinal legal method in examining the relevant Islamic dispute resolution mechanisms that are unique to Islamic finance disputes. Findings: The findings of this research reveal that some issues are causing untold hardships on parties in Islamic finance contractual disputes with the present jurisdiction of the courts in Malaysia. It is in line with the hypothesis of the research that the continued preference for litigation as a means of settling disputes in the Islamic finance industry is not sustainable due to the paradigm shift in dispute resolution involving financial matters globally
An Analysis of the Legal Regime of Pension Administration in Nigeria
(University of Uyo, 2022-07-30) Ahmed Abiodun Muhammed-Mikaaeel; Ahmeed Adedeji Onikosi
This paper analyses the legal regime for pension administration in Nigeria. Based on the various reports implicating various criticisms against the current legal regime on the pension scheme in the country, this paper provides content analysis with the aid of the doctrinal method. It examines the legal regime for pension in Nigeria from 2004 to 2014. The paper x-rays the inherent shortcomings in the 2004 pension scheme giving rise to the 2014 pension scheme. The laudable benefits of the 2014 pension scheme are orchestrated. However, the paper finds that there are inherent lapses, which include lack of direct prosecutorial power on the part of the relevant agencies, unjust and insensitive exclusion of the state and local government workers from the coverage of the current pension scheme and non-Shari’ah compliant approach of the pension scheme. It therefore recommends amendment of the current pension regime to get rid of the inherent shortcomings.
An Analysis Of The Primary Sources Of Shari’ah
(A PUBLICATION OF THE FACULTY OF LAW, 2019) Salman, Kamaldeen Olaitan
Sources of Islamic Law are classified into primary and secondary sources. The primary sources as agreed by scholars includes: Quran, Hadith and Ijma’. Although there are divergent opinions by the scholars on the inclusion of Ijma’ into the primary sources of Shariah as that was never part of the sources stated by the Prophet Muhammad (SAW). The purpose of this article is to discuss the important of this primary source of Islamic law in an attempt to solve any contemporary issue in our society. The article focuses on the detail analysis of Quran as sources of Shari’ah. The article reveals that Quran is a primary source of Sharia which all other sources are dependent upon. The article embarks on extensive examination of Hadith of Prophet Muhammad as another primary source of Sharia. Ijma’ formed last discussion on the primary sources of Shari’ah with focus on its important and condition that must be satisfied before relying on it to formulate Islamic rule
AN EXAMINATION OF EMPLOYMENT OF A NON-MUSLIM IN ISLAMIC ORGANISATION
(2024-06) Salman, Kamaldeen Olaitan
The world is created in such a way that no one can completely exist independent of another especially when it comes earning a living. Thus, engagement in one employment or the other becomes inevitable. In view of the inability of the government to provide employment for all and sundry, private organisations sprung up to fill the large vacuum within their limited capacities with faith-based organisations not left out. The problem of job and employment discrimination thus ensued. Hence the topical debate whether a non-Muslim can be employed in an Islamic organizational setting. The study relies on the doctrinal method of legal research to examine the legal implication of Qur’an Chapter 4 verse 144 on employment of non-Muslims in an Islamic organizational setting. The study explores the general rules and exceptions pertaining to non-Muslim employments in an Islamic organization. The study finds that the positions of Islamic jurists founded on the Sunnah of Prophet Muhammad copiously supported employment of non-Muslims in Islamic organization with satisfaction of certain conditions precedent including observance of non-discrimination, meeting job requirements and qualifications, respecting religious beliefs of one another within the organizational setting and legal considerations. The study recommends active employments of non-Muslims in Islamic organisations as a way of showcasing the beauty of Shari’ah principles to the non-Muslims for proper inevitable human peaceful co-existence
AN EXPLORATION OF DISPUTE RESOLUTION MECHANISMS IN ISLAMIC COMMERCIAL TRANSACTION
(Department of Islamic Law, Faculty of Law, Al-Hikmah University, 2021-06) Zubair, Aishat Abdul-Qadir
There is a recent boost to Islamic Commercial law in Nigeria most especially with the sophistication experienced in its emerging Islamic finance industry, with regards to Islamic banking and Islamic capital market, Sukuk. There is however a looming challenge on the industry in terms of its dispute resolution mechanism. This is because there seems to be an over-dependence on common law institutions, no thanks to the Nigerian colonial heritage, in issues involving Islamic law in general and Islamic commercial law in particular. The aim of this study is therefore to explore the various Islamic Dispute Resolution mechanisms that could be used in resolving Islamic commercial law disputes. This study adopts a doctrinal legal method in exploring the relevant Islamic dispute resolution mechanisms that are unique to Islamic law in general and Islamic commercial law in particular. Finally, the research proposes for the adoption of Islamic Dispute Resolution mechanisms in resolving Islamic Commercial law disputes. The findings of this research reveal that there are indeed dispute resolution mechanisms in Islamic law that are suitable for solving numerous disputes emanating from our ever-innovative Islamic commercial law especially when we take into consideration its uniqueness vis-à-vis Fiqh Muamalat and Shari’ah.
Analysis of Misconception of Nature of Dissolution of Nikāḥ at the Instance of Wife under Islamic Family Law
(Kwasu Law Journal (KWASULJ), 2021) AbdulWahab Mhammad Jamiu ELESIN
Apart from death, wedlock (nikāḥ) may come to an end through separation which also takes different methods under Islamic family law such as separation by way of consent between the parties (khulʻu) otherwise known as “dissolution of marriage at instance of the wife”. However, reading through some court decisions, it is observed that true nature of khulʻu is misconceived. Identifying nature of khulʻu therefore becomes significantly momentous as it guides the courts, legal practitioners, lecturers, students of law as well as other stakeholders in drawing legal opinion or decision. The paper reviewed opinions of major schools of fiqh as well as judicial decisions on the subject matter of study. The research consulted Qur’ān, Sunnah, fiqh manuals, tafsīr books and academic literature. Research findings revealed that, confusion within Muslims occurs in the mix-up of true nature of khulʻu. The recommended that experts in Islamic family law review opinions of the jurists on the subject
ANTI-TERRORISM FINANCING LAWS IN MALAYSIA: CURRENT TRENDS AND DEVELOPMENTS
(Ahmad Ibrahim Kulliyyah of Laws (AIKOL), 2015) Zubair, Aishat Abdul-Qadir; Umar A. Oseni; Norhashimah Mohd Yasin
Malaysia has continued to proactively enhance its legal framework for combating terrorism financing as a phenomenal response to the global war against terrorism. This paper revisits the provisions relating to anti-terrorism financing in the Anti-Money Laundering and Anti-Terrorism Financing Act 2001 (AMLATFA), and the recent amendment made to the Act in 2014, as well as the Penal Code of Malaysia. While this study focuses on Anti-Terrorism Laws in Malaysia, AMLATFA forms the crux of the discussion in the light of current developments in anti-terrorism legislation in Malaysia. A brief Islamic legal perspective on anti-terrorism financing is given in the light of specific provisions of AMLATFA and the Penal Code. The paper finds that Malaysia is keeping up with the global developments in Anti-Terrorism Financing laws and this has helped it to maintain a good image in the global world as a country that is ready to combat terrorism generally and terrorism financing specifically. With the emerging threats of the self-styled Islamic State in Iraq and Levant (ISIL) in Malaysia and the world at large, there is no better time than now to come up with a more comprehensive law such as the Prevention of Terrorism Act 2015 to complement existing legislations on terrorism financing.
Application of Corporate Personality Doctrine under the Nigerian Corporate Law and Shari'ah
(Lloyd Law College, India, 2022-12-31) Ahmed A. Muhammed-Mikaaeel
Corporate personality doctrine has come to protect business enterprises from associated risks in the course of business transactions. The beneficiaries of the corporate personality doctrine are the corporate managers because of the statutory protection they enjoy under the Nigerian corporate law. The statutory protection is being used as catalyst to perpetuate corporate governance failure. With the recognition of artificial personality (Shakhsiyyah ‘Itibaariyyah) in Islamic jurisprudence vide the position of certain schools of jurisprudence, there is need to examine whether such statutory protection is affirmed as well. This paper therefore examines the application of corporate personality doctrine under the Nigerian corporate law and Shari’ah. This paper adopts doctrinal method of legal research vide reliance on the primary and secondary sources like Qur’an and hadith, Qiyas, the Nigerian Constitution, Company and Allied Matters Act, text books, journals and internet facilities. The paper reveals that the implications of corporate personality doctrine under the Nigerian Corporate Law and Shari’ah are not on all fours. It further reveals that the existing legal framework in the country favours the application of the corporate personality doctrine under the Nigerian Corporate Law but hinders the actual practicability of Shari’ah rules to corporate personality doctrine. The paper concludes that to fully activate the provision of Section 38 of the Constitution in favour of Shari’ah, there is need for amendment of the existing framework to make way for Shari’ah modification in dealing with the corporate activities by Muslim corporate managers as a form of contribution to fight against corporate governance failure in the country.
Application of Corporate Personality Doctrine under the Nigerian Corporate Law and Shari'ah
(Lloyd Law College, India, 2022-09-30) Ahmed A. Muhammed-Mikaaeel
Corporate personality doctrine has come to protect business enterprises from associated risks in the course of business transactions. The beneficiaries of the corporate personality doctrine are the corporate managers because of the statutory protection they enjoy under the Nigerian corporate law. The statutory protection is being used as catalyst to perpetuate corporate governance failure. With the recognition of artificial personality (Shakhsiyyah ‘Itibaariyyah) in Islamic jurisprudence vide the position of certain schools of jurisprudence, there is need to examine whether such statutory protection is affirmed as well. This paper therefore examines the application of corporate personality doctrine under the Nigerian corporate law and Shari’ah. This paper adopts doctrinal method of legal research vide reliance on the primary and secondary sources like Qur’an and hadith, Qiyas, the Nigerian Constitution, Company and Allied Matters Act, text books, journals and internet facilities. The paper reveals that the implications of corporate personality doctrine under the Nigerian Corporate Law and Shari’ah are not on all fours. It further reveals that the existing legal framework in the country favours the application of the corporate personality doctrine under the Nigerian Corporate Law but hinders the actual practicability of Shari’ah rules to corporate personality doctrine. The paper concludes that to fully activate the provision of Section 38 of the Constitution in favour of Shari’ah, there is need for amendment of the existing framework to make way for Shari’ah modification in dealing with the corporate activities by Muslim corporate managers as a form of contribution to fight against corporate governance failure in the country.
Appraisal of Misconception of Retirement of Wife (Istibdāluz-Zawjah) and Incorrectly Practice Ware under Islamic Family Law
(Al-Hikmah University Journal of Islamic Law (HUJIL), 2021) AbdulWahab Mhammad Jamiu ELESIN
Marriage and divorce are parts of the natural identity of human beings that has been given ample attention within socio-cultural, religious and political studies. The position of Islamic law is that “Female vulva is prohibited in principleالأَصْلُ فِي الأَبْضَاعِ التَّحْرِيمُ”. As a result, Islam vehemently prohibits free intermingling between people of opposite sex. Permissibility of sexual and all other marital relationships with a woman are strictly restricted into only two means viz nikāh and milkul-yamin. Sūratul-Muminun23, verses 5-7. Therefore, marriage under Islamic law is “a contract for the purpose of legalising sexual intercourse and the procreation of children. It is purely a civil contract, the terms of which depend, within very wide limits, on the will of the consenting parties, and to the validity of which no religious ceremony is necessary”. Lawful cohabitation of husband and wife relies on existence of the bond of marriage. Once it broke via any means, man and woman can no longer legally cohabit. However, the practice of “wāre” which is retirement of a wife and replace her with another wife, seems to be a misconception, misunderstanding, misinterpretation of aim of istibdāluz-zawjah subsequently misapplication and therefore, an inconsistent with the laws regulating nikāh and talāq, to the extent that it may lead to marrying more than four wife at time. This paper reviewed the practice. Our findings revealed that there is misapplication along the line and therefore made recommendations accordingly.
Capital Punishment in Nigerian Courts: The Position of Abolitionists vis-a-vis Islamic Jurisprudence
(Ekiti State University, Faculty of Law, Ekiti, Nigeria, 2020-01-30) Ahmed Abiodun Muhammed-Mikaaeel
Pronouncement of capital punishments have seen many light of the day to in the Nigerian Courts to the extent that a group of people (otherwise known as Abolitionists) have kicked against pronouncement of capital punishment with a view to abolish same. This made our courts to timeously intervene and confirmed the constitutionality of death sentence in our criminal law jurisprudence. The Islamic law jurisprudence is also firm on capital punishment in deserving cases. This study is essentially literature based with particular emphasis on the Constitution of the Federal Republic of Nigeria, 1999 As Amended as well as other relevant criminal law legislations. The study carefully examines the nature and types of capital offences under Common and Islamic Law. It goes further to x-ray the object of capital punishment and the attitude of courts to pronouncements in capital related offences vis-à-vis the Abolitionists campaign hinged on the Nigerian constitutional provision. The paper contends that under the Common Law, the attitudes of courts to pronouncement of capital punishment is positive such that once the offence has been successfully proved beyond reasonable doubt, death sentence is not negotiable. More so, under the Shariah, neither the Qadi nor the executioner can lessen or reduce the hadd punishment ordained by Allah (SWT). The study recommends practical independence of judiciary so that they can continue to stand firm against the Abolitionists in their mission to get rid of the much important capital punishment. Attitude, Abolitionists, Common Law, Capital Punishment, Death Sentence, Prouncement, Islamic Law, Shariah, Hadd and Qadi.
Capital Punishment in Nigerian Courts: The Position of Abolitionists vis-a-vis Islamic Jurisprudence
(Faculty of Law, Ekiti State University, Ekiti, Nigeria, 2020-01-31) Ahmed Abiodun Muhammed-Mikaaeel
Pronouncement of capital punishments have seen many light of the day to in the Nigerian Courts to the extent that a group of people (otherwise known as Abolitionists) have kicked against pronouncement of capital punishment with a view to abolish same. This made our courts to timeously intervene and confirmed the constitutionality of death sentence in our criminal law jurisprudence. The Islamic law jurisprudence is also firm on capital punishment in deserving cases. This study is essentially literature based with particular emphasis on the Constitution of the Federal Republic of Nigeria, 1999 As Amended as well as other relevant criminal law legislations. The study carefully examines the nature and types of capital offences under Common and Islamic Law. It goes further to x-ray the object of capital punishment and the attitude of courts to pronouncements in capital related offences vis-à-vis the Abolitionists campaign hinged on the Nigerian constitutional provision. The paper contends that under the Common Law, the attitudes of courts to pronouncement of capital punishment is positive such that once the offence has been successfully proved beyond reasonable doubt, death sentence is not negotiable. More so, under the Shariah, neither the Qadi nor the executioner can lessen or reduce the hadd punishment ordained by Allah (SWT). The study recommends practical independence of judiciary so that they can continue to stand firm against the Abolitionists in their mission to get rid of the much important capital punishment.
Challenges in the discharge of State obligations on educational right of children during Covid-19: Nigeria and Ethiopia in focus
(Vishwakarma University, India, 2021-10-31) Ahmed A. Muhammed-Mikaaeel
Covid-19 has metamorphosed into a deadly pandemic across the universe since its outbreak in December, 2019. It continues to threaten human existence and particularly children who are vulnerable by their very nature. At a point, it interrupts children’s right to education across the universe. Efforts of governments towards discharging their obligations on educational rights of children under the laws met series of challenges. Nigeria and Ethiopia, like their counterparts across the globe, resorted to total lockdown and stay at home as part of the measures to contain the spread of Covid-19. This has consequently impacted negatively on the educational right of children in the two countries. Against the foregoing backdrop, this paper, relying on doctrinal method of legal research, seeks to examine the challenges in the discharge of State obligations on educational right of children during Covid-19 using Nigeria and Ethiopia as a case study. The paper x-rays the extent of the effect of Covid-19 on the children’s educational right in Nigeria and Ethiopia by investigating the adequacy or otherwise of the various measures put in place by the governments to cushion the effect of the pandemic on the children’s educational right. The paper also examines the various challenges faced by the governments in the two countries while discharging their obligations towards educational rights of the children. The paper concludes that the efforts put in place by the two governments to cushion the effect of Covid-19 on the educational right of the children were inadequate. For future purpose, the paper recommends, amongst others, provisions of adequate facilities in educational institutions and adequate training of teachers in technical-know-how required for virtual learning at period of lock down.
Combating Corporation-Induced Elenvironmental Pollution in Nigeria Vide Shari'ah Mechanism
(Alliance University, Bengaluru, India, 2022-11-25) Ahmed Abiodun Muhammed-Mikaaeel; Aishat Abdul-Qadir Zubair
The menace of environmental pollution is not limited to a particular clime. The scourge is being felt globally. Efforts to combat the menace is still ongoing at global, regional and national levels. Nigeria, as a sovereign nation, has suffered and is still suffering the menace of environmental pollution. The discovery of crude oil in commercial quantity gave birth to corporation-induced environmental pollution. National effort towards combating the corporation-induced pollution gave rise to series of legal frameworks while the country continues to experience environmental degradation. Against this backdrop, this paper looks for options beyond the conventional corporate law vide Shari’ah mechanism. This paper, which employs the Qualitative Research Design, adopts both the doctrinal and non-doctrinal legal research approaches. For the doctrinal approach, content analysis was adopted to analyze the primary sources like texts of Fiqh and legislations as well as the secondary sources such as textbooks, journals, articles, reports, among others. With the aid of comparative analysis, the paper compares approaches to corporation-induced environmental protection under the conventional law and Shari’ah. The paper further presents a visual representation of the various views using thematic analysis with the help of ATLAS.ti software. The paper contends that environmental pollution signifies corporate governance failure. It also argues that despite the availability of legal framework for environmental protection, the menace of corporation-induced pollution is persistent owing to certain challenges. It is contended that Nigeria has never considered Shari’ah perspective in protecting its environment. Hence, Shari’ah approach is recommended for combating corporation-induced environmental pollution in Nigeria.

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