1. 𝘖𝘯 𝘔𝘰𝘯𝘥𝘢𝘺, 30 𝘋𝘦𝘤𝘦𝘮𝘣𝘦𝘳 2024, 𝘪𝘵’𝘴 𝘳𝘦𝘱𝘰𝘳𝘵𝘦𝘥 𝘪𝘯 𝘛𝘩𝘦𝘊𝘢𝘣𝘭𝘦 𝘯𝘦𝘸𝘴 𝘵𝘩𝘢𝘵 “𝘚𝘪𝘮𝘪𝘯𝘢𝘭𝘢𝘺𝘪 𝘍𝘶𝘣𝘢𝘳𝘢, 𝘎𝘰𝘷𝘦𝘳𝘯𝘰𝘳 𝘰𝘧 𝘙𝘪𝘷𝘦𝘳𝘴 𝘴𝘵𝘢𝘵𝘦, 𝘩𝘢𝘴 𝘱𝘳𝘦𝘴𝘦𝘯𝘵𝘦𝘥 𝘵𝘩𝘦 2025 𝘣𝘶𝘥𝘨𝘦𝘵 𝘱𝘳𝘰𝘱𝘰𝘴𝘢𝘭 𝘵𝘰 𝘵𝘩𝘦 𝘝𝘪𝘤𝘵𝘰𝘳 𝘖𝘬𝘰-𝘑𝘶𝘮𝘣𝘰-𝘭𝘦𝘥 𝘙𝘪𝘷𝘦𝘳𝘴 𝘩𝘰𝘶𝘴𝘦 𝘰𝘧 𝘢𝘴𝘴𝘦𝘮𝘣𝘭𝘺. 𝘍𝘶𝘣𝘢𝘳𝘢 𝘱𝘳𝘦𝘴𝘦𝘯𝘵𝘦𝘥 𝘵𝘩𝘦 𝘕1.1 𝘵𝘳𝘪𝘭𝘭𝘪𝘰𝘯 𝘢𝘱𝘱𝘳𝘰𝘱𝘳𝘪𝘢𝘵𝘪𝘰𝘯 𝘣𝘪𝘭𝘭 𝘵𝘰 𝘵𝘩𝘦 𝘩𝘰𝘶𝘴𝘦 𝘰𝘯 𝘔𝘰𝘯𝘥𝘢𝘺”. 𝘐 𝘳𝘦𝘴𝘱𝘦𝘤𝘵𝘧𝘶𝘭𝘭𝘺 𝘣𝘦𝘭𝘪𝘦𝘷𝘦 𝘵𝘩𝘦 𝘱𝘳𝘦𝘴𝘦𝘯𝘵𝘢𝘵𝘪𝘰𝘯 𝘸𝘢𝘴 𝘭𝘢𝘸𝘧𝘶𝘭, 𝘤𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯𝘢𝘭 𝘢𝘯𝘥 𝘪𝘯 𝘰𝘳𝘥𝘦𝘳.
2. 𝘉𝘺 𝘷𝘪𝘳𝘵𝘶𝘦 𝘰𝘧 𝘚𝘦𝘤𝘵𝘪𝘰𝘯 109 𝘰𝘧 𝘵𝘩𝘦 𝘊𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯 𝘰𝘧 𝘵𝘩𝘦 𝘍𝘦𝘥𝘦𝘳𝘢𝘭 𝘙𝘦𝘱𝘶𝘣𝘭𝘪𝘤 𝘰𝘧 𝘕𝘪𝘨𝘦𝘳𝘪𝘢, 𝘢𝘯𝘥 𝘰𝘯 𝘵𝘩𝘦 𝘢𝘶𝘵𝘩𝘰𝘳𝘪𝘵𝘺 𝘰𝘧 𝘵𝘩𝘦 𝘤𝘢𝘴𝘦𝘴 𝘰𝘧 𝘋𝘈𝘗𝘐𝘈𝘕𝘓𝘖𝘕𝘎 𝘝 𝘋𝘈𝘙𝘐𝘕𝘎 (2007) (𝘚𝘊): 𝘈𝘎 𝘝 𝘈𝘉𝘜𝘉𝘈𝘒𝘈𝘙 (𝘚𝘊) 𝘢𝘯𝘥 𝘈𝘉𝘌𝘎𝘜𝘕𝘋𝘌 𝘝 𝘖𝘕𝘋𝘖 𝘚𝘛𝘈𝘛𝘌 𝘏𝘖𝘈, 𝘵𝘩𝘦 27 𝘮𝘦𝘮𝘣𝘦𝘳𝘴 𝘰𝘧 𝘵𝘩𝘦 32-𝘮𝘦𝘮𝘣𝘦𝘳 𝘏𝘰𝘶𝘴𝘦 𝘰𝘧 𝘈𝘴𝘴𝘦𝘮𝘣𝘭𝘺 𝘰𝘧 𝘙𝘪𝘷𝘦𝘳𝘴 𝘚𝘵𝘢𝘵𝘦 𝘸𝘩𝘰 𝘰𝘯 11 𝘋𝘦𝘤𝘦𝘮𝘣𝘦𝘳 2023 𝘥𝘦𝘧𝘦𝘤𝘵𝘦𝘥 𝘵𝘰 𝘢 𝘱𝘰𝘭𝘪𝘵𝘪𝘤𝘢𝘭 𝘱𝘢𝘳𝘵𝘺 𝘥𝘪𝘧𝘧𝘦𝘳𝘦𝘯𝘵 𝘧𝘳𝘰𝘮 𝘵𝘩𝘦 𝘰𝘯𝘦 𝘰𝘯 𝘸𝘩𝘰𝘴𝘦 𝘱𝘭𝘢𝘵𝘧𝘰𝘳𝘮 𝘵𝘩𝘦𝘺 𝘸𝘦𝘳𝘦 𝘦𝘭𝘦𝘤𝘵𝘦𝘥, 𝘩𝘢𝘥 𝘢𝘶𝘵𝘰𝘮𝘢𝘵𝘪𝘤𝘢𝘭𝘭𝘺 𝘭𝘰𝘴𝘵 𝘵𝘩𝘦𝘪𝘳 𝘴𝘦𝘢𝘵𝘴 𝘪𝘯 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦 𝘢𝘯𝘥 𝘢𝘤𝘤𝘰𝘳𝘥𝘪𝘯𝘨𝘭𝘺 𝘤𝘦𝘢𝘴𝘦𝘥 𝘵𝘰 𝘣𝘦 𝘮𝘦𝘮𝘣𝘦𝘳𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦. 𝘛𝘩𝘦 𝘢𝘧𝘧𝘦𝘤𝘵𝘦𝘥 𝘏𝘰𝘯𝘰𝘶𝘳𝘢𝘣𝘭𝘦𝘴 𝘢𝘤𝘤𝘰𝘳𝘥𝘪𝘯𝘨𝘭𝘺 𝘩𝘢𝘷𝘦 𝘯𝘰 𝘳𝘪𝘨𝘩𝘵 𝘵𝘰 𝘱𝘢𝘳𝘢𝘥𝘦 𝘵𝘩𝘦𝘮𝘴𝘦𝘭𝘷𝘦𝘴 𝘢𝘴 𝘳𝘦𝘱𝘳𝘦𝘴𝘦𝘯𝘵𝘪𝘯𝘨 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦 𝘰𝘧 𝘈𝘴𝘴𝘦𝘮𝘣𝘭𝘺 𝘰𝘧 𝘙𝘪𝘷𝘦𝘳𝘴 𝘚𝘵𝘢𝘵𝘦. 𝘐𝘵’𝘴 𝘢 𝘱𝘶𝘯𝘪𝘴𝘩𝘢𝘣𝘭𝘦 𝘰𝘧𝘧𝘦𝘯𝘤𝘦 𝘧𝘰𝘳 𝘢𝘯𝘺 𝘱𝘦𝘳𝘴𝘰𝘯 𝘸𝘩𝘰 𝘪𝘴 𝘯𝘰𝘵 𝘢 𝘮𝘦𝘮𝘣𝘦𝘳 𝘰𝘧 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦 𝘵𝘰 𝘱𝘢𝘳𝘢𝘥𝘦 𝘩𝘪𝘮𝘴𝘦𝘭𝘧 𝘢𝘴 𝘰𝘯𝘦 𝘰𝘳 𝘵𝘰 𝘱𝘶𝘳𝘱𝘰𝘳𝘵 𝘵𝘰 𝘳𝘦𝘱𝘳𝘦𝘴𝘦𝘯𝘵 𝘰𝘳 𝘵𝘰 𝘢𝘤𝘵 𝘧𝘰𝘳 𝘰𝘳 𝘰𝘯 𝘣𝘦𝘩𝘢𝘭𝘧 𝘰𝘧 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦. 𝘚𝘦𝘦 𝘚𝘦𝘤𝘵𝘪𝘰𝘯 99 𝘰𝘧 𝘵𝘩𝘦 𝘊𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯.
3. 𝘎𝘰𝘷𝘦𝘳𝘯𝘰𝘳 𝘍𝘶𝘣𝘢𝘳𝘢 𝘰𝘧 𝘙𝘪𝘷𝘦𝘳𝘴 𝘚𝘵𝘢𝘵𝘦 𝘩𝘢𝘷𝘪𝘯𝘨 𝘴𝘸𝘰𝘳𝘯 𝘵𝘰 𝘶𝘱𝘩𝘰𝘭𝘥 𝘵𝘩𝘦 𝘕𝘪𝘨𝘦𝘳𝘪𝘢𝘯 𝘊𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯, 𝘩𝘢𝘴 𝘢 𝘥𝘶𝘵𝘺 𝘵𝘰 𝘱𝘳𝘰𝘵𝘦𝘤𝘵 𝘵𝘩𝘦 𝘊𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯 𝘣𝘺 𝘦𝘯𝘴𝘶𝘳𝘪𝘯𝘨 𝘩𝘦 𝘱𝘳𝘦𝘴𝘦𝘯𝘵𝘴 𝘵𝘩𝘦 𝘚𝘵𝘢𝘵𝘦’𝘴 𝘣𝘶𝘥𝘨𝘦𝘵 𝘵𝘰 𝘢 𝘨𝘳𝘰𝘶𝘱 𝘰𝘧 𝘦𝘹𝘪𝘴𝘵𝘪𝘯𝘨 𝘮𝘦𝘮𝘣𝘦𝘳𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦.
4. 𝘚𝘦𝘤𝘵𝘪𝘰𝘯 121 𝘰𝘧 𝘵𝘩𝘦 𝘊𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯 𝘰𝘧 𝘵𝘩𝘦 𝘍𝘦𝘥𝘦𝘳𝘢𝘭 𝘙𝘦𝘱𝘶𝘣𝘭𝘪𝘤 𝘰𝘧 𝘕𝘪𝘨𝘦𝘳𝘪𝘢, 1999, 𝘮𝘢𝘯𝘥𝘢𝘵𝘦𝘴 𝘵𝘩𝘦 𝘎𝘰𝘷𝘦𝘳𝘯𝘰𝘳 𝘰𝘧 𝘢 𝘚𝘵𝘢𝘵𝘦 𝘢𝘴 𝘧𝘰𝘭𝘭𝘰𝘸𝘴: “𝘛𝘩𝘦 𝘎𝘰𝘷𝘦𝘳𝘯𝘰𝘳 𝘴𝘩𝘢𝘭𝘭 𝘤𝘢𝘶𝘴𝘦 𝘵𝘰 𝘣𝘦 𝘱𝘳𝘦𝘱𝘢𝘳𝘦𝘥 𝘢𝘯𝘥 𝘭𝘢𝘪𝘥 𝘣𝘦𝘧𝘰𝘳𝘦 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦 𝘰𝘧 𝘈𝘴𝘴𝘦𝘮𝘣𝘭𝘺 𝘢𝘵 𝘢𝘯𝘺 𝘵𝘪𝘮𝘦 𝘣𝘦𝘧𝘰𝘳𝘦 𝘵𝘩𝘦 𝘤𝘰𝘮𝘮𝘦𝘯𝘤𝘦𝘮𝘦𝘯𝘵 𝘰𝘧 𝘦𝘢𝘤𝘩 𝘧𝘪𝘯𝘢𝘯𝘤𝘪𝘢𝘭 𝘺𝘦𝘢𝘳 𝘦𝘴𝘵𝘪𝘮𝘢𝘵𝘦𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘳𝘦𝘷𝘦𝘯𝘶𝘦𝘴 𝘢𝘯𝘥 𝘦𝘹𝘱𝘦𝘯𝘥𝘪𝘵𝘶𝘳𝘦 𝘰𝘧 𝘵𝘩𝘦 𝘚𝘵𝘢𝘵𝘦 𝘧𝘰𝘳 𝘵𝘩𝘦 𝘯𝘦𝘹𝘵 𝘧𝘰𝘭𝘭𝘰𝘸𝘪𝘯𝘨 𝘧𝘪𝘯𝘢𝘯𝘤𝘪𝘢𝘭 𝘺𝘦𝘢𝘳”
5. 𝘍𝘰𝘭𝘭𝘰𝘸𝘪𝘯𝘨 𝘵𝘩𝘦 11/12/2023 𝘥𝘦𝘧𝘦𝘤𝘵𝘪𝘰𝘯 𝘸𝘩𝘪𝘤𝘩 𝘭𝘦𝘥 𝘵𝘰 𝘢𝘶𝘵𝘰𝘮𝘢𝘵𝘪𝘤 𝘭𝘰𝘴𝘴 𝘰𝘧 27 𝘴𝘦𝘢𝘵𝘴 𝘪𝘯 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦, 𝘵𝘩𝘦 𝘎𝘰𝘷𝘦𝘳𝘯𝘰𝘳 𝘰𝘧 𝘙𝘪𝘷𝘦𝘳𝘴 𝘚𝘵𝘢𝘵𝘦 𝘮𝘢𝘺 𝘰𝘯𝘭𝘺 𝘳𝘦𝘭𝘢𝘵𝘦 𝘵𝘰/𝘸𝘪𝘵𝘩 𝘵𝘩𝘦 𝘳𝘦𝘮𝘢𝘪𝘯𝘪𝘯𝘨 𝘮𝘦𝘮𝘣𝘦𝘳𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦 (𝘪.𝘦., 𝘵𝘩𝘰𝘴𝘦 𝘸𝘩𝘰 𝘥𝘪𝘥 𝘯𝘰𝘵 𝘥𝘦𝘧𝘦𝘤𝘵).
6. 𝘖𝘧 𝘤𝘰𝘶𝘳𝘴𝘦, 𝘪𝘵’𝘥 𝘣𝘦 𝘶𝘯𝘤𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯𝘢𝘭, 𝘪𝘭𝘭𝘦𝘨𝘢𝘭, 𝘢𝘯𝘥 𝘪𝘯𝘢𝘱𝘱𝘳𝘰𝘱𝘳𝘪𝘢𝘵𝘦, 𝘢𝘯𝘥 𝘮𝘢𝘺 𝘣𝘦 𝘤𝘰𝘯𝘴𝘪𝘥𝘦𝘳𝘦𝘥 𝘢𝘯 𝘪𝘮𝘱𝘦𝘢𝘤𝘩𝘢𝘣𝘭𝘦 𝘰𝘧𝘧𝘦𝘯𝘤𝘦, 𝘧𝘰𝘳 𝘵𝘩𝘦 𝘎𝘰𝘷𝘦𝘳𝘯𝘰𝘳 𝘵𝘰 𝘱𝘳𝘦𝘴𝘦𝘯𝘵 𝘣𝘶𝘥𝘨𝘦𝘵 𝘦𝘴𝘵𝘪𝘮𝘢𝘵𝘦𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘚𝘵𝘢𝘵𝘦 𝘵𝘰/𝘣𝘦𝘧𝘰𝘳𝘦 𝘢 𝘨𝘳𝘰𝘶𝘱 𝘰𝘧 𝘱𝘦𝘰𝘱𝘭𝘦 𝘸𝘩𝘰 𝘢𝘳𝘦 𝘕𝘖 𝘭𝘰𝘯𝘨𝘦𝘳 𝘮𝘦𝘮𝘣𝘦𝘳𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦 𝘰𝘧 𝘈𝘴𝘴𝘦𝘮𝘣𝘭𝘺 𝘰𝘧 𝘵𝘩𝘦 𝘚𝘵𝘢𝘵𝘦.
7. 𝘈𝘴 𝘱𝘦𝘳𝘴𝘰𝘯𝘴 𝘸𝘩𝘰 𝘩𝘢𝘷𝘦 𝘢 𝘱𝘳𝘪𝘮𝘢𝘳𝘺 𝘥𝘶𝘵𝘺, 𝘪𝘮𝘱𝘰𝘴𝘦𝘥 𝘣𝘺 𝘙𝘶𝘭𝘦 1 𝘰𝘧 𝘵𝘩𝘦 𝘙𝘶𝘭𝘦𝘴 𝘰𝘧 𝘗𝘳𝘰𝘧𝘦𝘴𝘴𝘪𝘰𝘯𝘢𝘭 𝘊𝘰𝘯𝘥𝘶𝘤𝘵 𝘧𝘰𝘳 𝘓𝘦𝘨𝘢𝘭 𝘗𝘳𝘢𝘤𝘵𝘪𝘵𝘪𝘰𝘯𝘦𝘳𝘴, 2023, 𝘵𝘰 𝘶𝘱𝘩𝘰𝘭𝘥 𝘵𝘩𝘦 𝘳𝘶𝘭𝘦 𝘰𝘧 𝘭𝘢𝘸 𝘢𝘯𝘥 𝘵𝘩𝘦 𝘤𝘢𝘶𝘴𝘦 𝘰𝘧 𝘫𝘶𝘴𝘵𝘪𝘤𝘦 𝘢𝘵 𝘢𝘭𝘭 𝘵𝘪𝘮𝘦𝘴 𝘪𝘳𝘳𝘦𝘴𝘱𝘦𝘤𝘵𝘪𝘷𝘦 𝘰𝘧 𝘵𝘩𝘦 𝘤𝘪𝘳𝘤𝘶𝘮𝘴𝘵𝘢𝘯𝘤𝘦𝘴, 𝘢𝘭𝘭 𝘭𝘢𝘸𝘺𝘦𝘳𝘴 𝘪𝘯 𝘕𝘪𝘨𝘦𝘳𝘪𝘢 𝘰𝘶𝘨𝘩𝘵 𝘵𝘰 𝘴𝘵𝘢𝘯𝘥 𝘸𝘪𝘵𝘩 𝘎𝘰𝘷𝘦𝘳𝘯𝘰𝘳 𝘍𝘶𝘣𝘢𝘳𝘢 𝘰𝘧 𝘙𝘪𝘷𝘦𝘳𝘴 𝘚𝘵𝘢𝘵𝘦 𝘪𝘯 𝘩𝘪𝘴 𝘦𝘧𝘧𝘰𝘳𝘵𝘴 𝘢𝘵 𝘥𝘦𝘧𝘦𝘯𝘥𝘪𝘯𝘨 𝘵𝘩𝘦 𝘊𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯 𝘰𝘧 𝘵𝘩𝘦 𝘍𝘦𝘥𝘦𝘳𝘢𝘭 𝘙𝘦𝘱𝘶𝘣𝘭𝘪𝘤 𝘸𝘩𝘪𝘤𝘩 𝘩𝘦 𝘩𝘢𝘴 𝘴𝘸𝘰𝘳𝘯 𝘵𝘰 𝘶𝘱𝘩𝘰𝘭𝘥..
8. 𝘜𝘯𝘵𝘪𝘭 𝘵𝘩𝘦 𝘐𝘕𝘌𝘊 𝘵𝘢𝘬𝘦𝘴 𝘴𝘵𝘦𝘱𝘴 𝘵𝘰 𝘧𝘪𝘭𝘭 𝘵𝘩𝘦 𝘷𝘢𝘤𝘢𝘯𝘤𝘪𝘦𝘴 𝘤𝘳𝘦𝘢𝘵𝘦𝘥 𝘣𝘺 𝘵𝘩𝘦 𝘥𝘦𝘧𝘦𝘤𝘵𝘪𝘰𝘯 𝘰𝘧 27 𝘮𝘦𝘮𝘣𝘦𝘳𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘙𝘪𝘷𝘦𝘳𝘴 𝘚𝘵𝘢𝘵𝘦 𝘏𝘰𝘶𝘴𝘦 𝘰𝘧 𝘈𝘴𝘴𝘦𝘮𝘣𝘭𝘺, 𝘎𝘰𝘷𝘦𝘳𝘯𝘰𝘳 𝘍𝘶𝘣𝘢𝘳𝘢 𝘪𝘴 𝘦𝘯𝘵𝘪𝘵𝘭𝘦𝘥 𝘵𝘰 𝘤𝘰𝘯𝘵𝘪𝘯𝘶𝘦 𝘵𝘰 𝘳𝘦𝘭𝘢𝘵𝘦 𝘵𝘰 𝘵𝘩𝘦 𝘳𝘦𝘮𝘢𝘪𝘯𝘪𝘯𝘨 𝘮𝘦𝘮𝘣𝘦𝘳𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦 𝘸𝘩𝘰 𝘢𝘭𝘰𝘯𝘦 𝘢𝘳𝘦 𝘵𝘩𝘦 𝘢𝘶𝘵𝘩𝘦𝘯𝘵𝘪𝘤 𝘮𝘦𝘮𝘣𝘦𝘳𝘴 𝘰𝘧 𝘵𝘩𝘦 𝘏𝘰𝘶𝘴𝘦, 𝘪𝘯 𝘰𝘳𝘥𝘦𝘳 𝘵𝘰 𝘦𝘯𝘴𝘶𝘳𝘦 𝘵𝘩𝘢𝘵 𝘵𝘩𝘦 𝘢𝘧𝘧𝘢𝘪𝘳𝘴 𝘰𝘧 𝘙𝘪𝘷𝘦𝘳𝘴 𝘚𝘵𝘢𝘵𝘦 𝘢𝘳𝘦 𝘯𝘰𝘵 𝘨𝘳𝘰𝘶𝘯𝘥 𝘵𝘰 𝘢 𝘩𝘢𝘭𝘵.
9. See: “𝗥𝗶𝘃𝗲𝗿𝘀 𝗦𝘁𝗮𝘁𝗲 (𝗣𝗮𝗿𝘁 𝟮): 𝗖𝗮𝗻 𝗧𝗵𝗲 𝗥𝗲𝗺𝗮𝗶𝗻𝗶𝗻𝗴 𝗠𝗲𝗺𝗯𝗲𝗿𝘀 𝗢𝗳 𝗔 𝗛𝗼𝘂𝘀𝗲 𝗢𝗳 𝗔𝘀𝘀𝗲𝗺𝗯𝗹𝘆 𝗩𝗮𝗹𝗶𝗱𝗹𝘆 𝗖𝗼𝗻𝗱𝘂𝗰𝘁 𝗧𝗵𝗲 𝗕𝘂𝘀𝗶𝗻𝗲𝘀𝘀 𝗢𝗳 𝗧𝗵𝗲 𝗛𝗼𝘂𝘀𝗲 𝗔𝗳𝘁𝗲𝗿 𝗔𝗻 𝗨𝗻𝗰𝗼𝗻𝘀𝘁𝗶𝘁𝘂𝘁𝗶𝗼𝗻𝗮𝗹 𝗗𝗲𝗳𝗲𝗰𝘁𝗶𝗼𝗻 𝗕𝘆 𝗧𝗵𝗲 𝗠𝗮𝗷𝗼𝗿𝗶𝘁𝘆” By Sylvester Udemezue, published by TheNigeriaLawyer on 13 May 2024;
10. See also “𝗥𝗶𝘃𝗲𝗿𝘀 𝗦𝘁𝗮𝘁𝗲 𝗛𝗼𝘂𝘀𝗲 𝗢𝗳 𝗔𝘀𝘀𝗲𝗺𝗯𝗹𝘆 𝗔𝗻𝗱 𝗧𝗵𝗲 𝗙𝗮𝗹𝗹𝗮𝗰𝘆 𝗢𝗳 “𝗮𝘂𝘁𝗵𝗲𝗻𝘁𝗶𝗰 𝗟𝗲𝗴𝗶𝘀𝗹𝗮𝘁𝘂𝗿𝗲”(A Legal Opinion)” -By Sylvester Udemezue, published 02 November 2024 in BarristerNG.
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By Ebun-Olu Adegboruwa, SAN

Article 7 of the African Charter on Human and Peoples’ Rights (Ratification and Enforcement) Act, 2004, states that “every individual shall have the right to have his cause heard”. This is also echoed in Article 8 of the Universal Declaration of Human Rights that ‘everyone has the right to an effective remedy by the competent national tribunals for acts violating the fundamental rights granted him by the constitution or by law’. The Supreme Court of Nigeria adopted this concept as its motto through the Latin maxim ubi jus ibi remedium, meaning where there is a right, there is a remedy.

The learned authors of A Dictionary of Law, define it in these terms: ‘the principle is that where one’s right is invaded or destroyed, the law gives a remedy to protect it or damages for its loss. Further, where one’s right is denied the law affords the remedy of an action for its enforcement. This right to a remedy therefore includes more than is usually meant in English law by the term “remedy”, as it includes a right of action. Wherever, therefore, a right exists there is also a remedy. Ashby v White (1703) 14 St Tr 695, 92 ER 126’. This right is inherent in mankind itself as a way of preserving peace, law and order in the society thus avoiding resort to anarchy, lawlessness and all the ugly instances of self-help. The status quo ordinarily leans in favour of the rich, the mighty and those in authority, such that in many cases, policy formulation and implementation result in the breach of entrenched rights and privileges. The resort to justice by the victim is usually considered to be preferable and beneficial.  In this regard, Article 2 of the International Covenant on Civil and Political Rights provides that each party to the Covenant shall ‘ensure that any person whose rights or freedoms as herein recognized are violated shall have an effective remedy’.

A recent study by the Ministry of Foreign Affairs of the Kingdom of The Netherlands in collaboration with the Communication & Marketing Research Group (CMRG) Limited gave some detailed perspectives on the utility of the justice sector in Nigeria. According to the report: 

“The Justice Needs and Satisfaction (JNS) 2023 study presents the justice experiences of 6,573 randomly selected Nigerian adults. The data and findings outline the legal problems they encounter, their impact, and the steps people take to address their legal needs. The 2023 JNS Report report is an essential tool for understanding the needs of people in Nigeria, identifying areas that require improvement, and monitoring the progress of various justice initiatives currently underway.“

Highlights from the Study:

• Approximately 81% of Nigerians experienced at least one legal problem in the past year, with many facing multiple problems.
• 55% of all legal problems were resolved either partially or completely, with about 82% of those resolutions deemed fair or very fair.
• The most common legal problem categories experienced by Nigerians include disputes with neighbours, domestic violence, land disputes, crime, and housing problems.
• Approximately 86% of Nigerians with a legal problem take some form of action to address their most serious problem.
• When addressing their most pressing legal problems, people often rely on their inner circle, frequently seeking help from family and friends.
• Beyond one’s social network, the most frequent sources of help include the police (11%), community/traditional leaders (8%), religious authorities (6%), landlords (6%), local public authorities (5%), and lawyers (5%).”

Stakeholders in the legal profession have always known about this alarming situation but they carry on as if it is normal. The right of access to justice bears a universal meaning that should not be subject to the vagaries of territories which are hostile to its affirmation. The Legal Information Institute of the Cornell Law School, defines as “the ethical, philosophical idea that people are to be treated impartially, fairly, properly, and reasonably by the law and by the arbiters of the law, that laws are to ensure that no harm befalls another, and that, where harm is alleged, a remedial action is taken – both the accuser and the accused receive a morally right consequence merited by their actions. Justice is a legal structure or system that is designed to judge in a general sense who should be accorded a benefit or burden when the law is applied to a person’s factual circumstances.”

The idea of justice springs from the fact that human beings are created equal but by reason of personal strength, status, wealth or influence, one person may be placed in a position of advantage more than the other such that if they were to plead on any matter in dispute between them, the strong may lord it over the weak. The idea of justice is meant to create a balance for society, in order to avoid the rule of self, to abolish any preference for arbitrariness and the regime of might over reason. Justice creates the forum where persons who have grievances can table them for resolution, so that the wrong person can be corrected and the right person justified and appeased. Society thrives on the principle of justice because it gives a sense of assurance to everybody, be it the weak, the strong or the handicapped that given all variables, the system will work to correct all wrongs and offer a remedy to the aggrieved.

Factors hindering access to justice

Many factors contribute to denial of access to justice, depending on which perspective the issue is viewed. The focus of this discourse is to highlight the impact of the declining population of lawyers on justice administration, flowing from the JNS study. By conservative estimates, Nigeria’s population is said to be above 200 million while the number of lawyers is roughly around 200,000 to 250,000. Included are members of the judiciary, being Magistrates, Judges, Justices and Tribunal members.

This group also includes lawyers who have ventured in politics, business and those who have travelled out of Nigeria. And I guess it also includes those who have passed on to glory. Effectively, therefore, the number of lawyers who are available to render legal services to those who desire it is declining every day. It is projected that Nigeria has about 3,000 active law firms with 6% increase per year. The standard law firms are mostly located in the urban areas of Lagos, Abuja, Port-Harcourt, Kaduna, Benin, Kano, etc. Given the poor state of infrastructure, especially power supply, it is very expensive to maintain a law firm. In contrast, the Body of Benchers admits an average of 4,000 students into the Nigerian Bar every year, with a growing population of unemployed lawyers who mostly crowd around these law firms.

Although it is not totally abhorrent to have alternative dispute resolution mechanisms, resort to arbitrariness in these fora cannot be ruled out. In the local courts set up in religious places and in the villages, the absence of a written code of adjudication presents such options as sometimes unenviable. Notwithstanding these reservations, the JNS study ranks the police as the top preference by those who seek remedy standing at 11%, followed by community/traditional leaders with 8%, religious authorities with 6%, landlords with 6%, local public authorities 5% and lawyers 5%.

Why do citizens boycott lawyers to have their matters resolved by traditional rulers and religious entities? First, the lawyer-to-citizen ratio is very low. Second, the cost of securing quality legal service is very high. Third, the uncertainty of redress is pushing potential litigants to unusual terrains. Fourth, the unreasonable delay associated with the administration of justice in Nigeria has no rival elsewhere in the globe. Fifth is the issue of corruption, through which a right cause is buried in absurd technical interpretations, judicial conflicts and legal abracadabra. There are of course cultural and religious factors which discourage access to justice, whereby the myth has been falsely planted in the minds of people that no one goes to court to become friends thereafter, forgetting that most legislations contain provisions that encourage settlement between warring parties.

The right of access to justice as encapsulated in section 6 (6) (b) of the Constitution of the Federal Republic of Nigeria, 1999 as amended, gives the power of adjudication to the courts. This right is granted unfettered, subject in some cases, to certain legal limitations, whereas the sources listed in the JNS report lack the basic ingredients of justice administration, especially the right of appeal to competent organs. When the police judge you as guilty, to whom do you take your case? If you are not satisfied with the verdict of your pastor or imam, do you stop worshipping in that church or mosque?

The point to note about the statutory guarantee of the right of access to justice is that it brings everybody and every person under the law such that the concept of justice cannot be meaningful without access as its denial is akin to absence of justice. Part of the solution is for the government to subsidize access to justice and improve infrastructure. Furthermore, the issue of backlog of law students should be addressed urgently by way of encouraging more states to partner together to build more law schools so that the training institutions can liberalize the admission process for citizens who genuinely wish to study law.

By Suyi Ayodele

Mudashiru Obasa was until January 13, 2025, the Speaker, Lagos State House of Assembly. He was first elected to the House in 2007. He was re-elected in 2011, 2014, 2019 and 2023! If his mouth allowed him to complete his current term, he would have been a member of the Lagos legislative arm for 25 years.

Like the proverbial squirrel whose palm kernel was cracked for him by a benevolent spirit, Obasa began his political career as a councillor in 1999 at his Agege Local Government Area of the state under the banner of Alliance for Democracy (AD). He has God to thank and President Bola Ahmed Tinubu to worship for his rise to political stardom.

But like the biblical Jeshurun, who in Deuteronomy 32: 15 is recorded thus: “ But Jeshurun waxed fat, and kicked; thou art waxen fat, thou art grown thick, thou art covered with fatness; then he forsook God which made him, and lightly esteemed the Rock of his salvation:, Obasa thought that having been Speaker for a period of 10 years less four months, he is now bigger and stronger than those who made him. He was made to pay for that indiscretion on January 13, when he was impeached by the House.

The pigeon is a lovely bird. It is equally a spiritual bird. It is not the type of avian that one will slaughter occasionally for consumption. Yeah, people do eat the pigeon. It is a delicacy one will crave after the first taste. But the bird is revered and, in some cases, worshipped as a deity. Its most appealing characteristic is its loyalty to its owner. The pigeon can be trusted to stand by you no matter the vicissitudes of life.

Pigeons are sold in pairs, male and female. Its reproduction is also in pairs. It lays two eggs, hatches the two and they come out male and female. Why it is so, only the Creator knows. A domesticated avian, the pigeon has its sibling in the wild. It is called òrófó in my place. The English translation of òrófó is wild pigeon.

Òrófó shares the same reproductive system with the pigeon. The two have so many things in common. The only difference is that while the pigeon is a peaceful bird, òrófó on its part is boastful. There are so many folktales about òrófó. One of them tells why one can hardly find a flight of òrófó as one finds a colony of pigeons. Òrófó, according to the tale, tells the sharpshooter that it remains out of the reach of the hunter’s bullets. To prove it, the hunter often fires at the bird of pride. In some cases, the hunter uses a catapult. The pigeon does not suffer such fate.

But the most interesting tale about òrófó is the one the elders of my place use in cautioning men to be circumspect about what comes out of their mouths. The saying, the mouth of a bird is its undoing; the wild pigeon lays two eggs, hatches two chicks and brags about that its nest is filled up with chicks (Ẹnu ẹyẹ níí p’ẹyẹ; ẹnu òrófó níí pa òrófó; òrófó yé eyin méjì, ó bímọ mẹ́jì, ó ní ilé òun kún ṣọ́ṣọ́ṣọ́), tells the story.

According to the tale, while in the comity of other birds, òrófó boasted that its nest was filled up with so many chicks. Other birds that were familiar with the reproductive capacity of òrófó wondered where it got the other chicks. But the hawk had a different idea. Since òrófó said its house was filled up with chicks, it would not be a bad idea that anytime the hawk was hungry, òrófó’s nest was where to go look for food. And on each occasion, the hawk would end up eating the two hatched chicks in òrófó’s nest, leaving the mother to wail about the calamity. That is why it is difficult to find a flight of òrófó; its offspring are in the belly of the hawk due to the indiscretion of the mother bird.

As it is with òrófó, so it is with any man who cannot control his mouth. The Holy Book, the Bible, in Proverbs 18:21, talks about the power of the tongue. It says in the tongue lies death and life. The Scripture, again, in James 3:5-6, describes the tongue as a fire in spite of its small size. African Indigenous Religion (AIR) – I got the new nomenclature from Professor Wande Abimbola who cautioned that we should not denigrate our religion by calling it African Traditional Religion (ATR) – talks about the talkative pawn of Àlàbá (Ìwòfà Àlàbá), who says everything he sees.

Ìwòfà Àlàbá, however, met his waterloo the day he told the king that he saw a dried-up corpse on a tree, which talked like it was still alive. The king and his chiefs followed Ìwòfà Àlàbá to the spot and though there was a corpse on the tree, it refused to talk. It was after the execution of Ìwòfà Àlàbá for deceiving the throne that the corpse spoke! Discretion is the master of all wisdom.

Nigerian politics is a one-way traffic. There are owners of each state of the Federation. Governors are the most powerful in the political calculation of this era. It is even more dangerous if the governor enjoys the backing of the godfather. There is no point denying that President Tinubu is the godfather of all political godfathers in Nigeria today. He is what my people call Òòsà àkúnlèbo (the deity one worships on his knee). Many said that the president earned that stature through the deployment of his deadly political strategies. Those who contested that in the past have terrible tales to tell.

It was that formidable man that Obasa confronted frontally while receiving Governor Babajide Sawo-Olu to the Lagos State House of Assembly to present the year 2025 Appropriation Bill to the House on November 21, 2024. It is foolish to call the servant on an errand for the master, stupid. The insult goes back to the master.

To start with, Obasa was said to have kept the governor and members of the Governor’s Advisory Council waiting for close to two hours. Why did he do that? Did he not have the information that the governor would be coming? What point was the Speaker trying to prove? And when he elected to receive the party, the Speaker spent 11 and half minutes, lecturing, threatening and disparaging the August visitor.

I watched the video of the encounter, and I wondered who prepared pounded yam for Obasa and assured him that getting the soup would not be a problem. I equally got a full text of the Speaker’s speech, and each sentence points at a man who voluntarily sought death in its corner! From the beginning to the end, Obasa spoke like someone who has Lagos in his pocket.

In paragraph four, for instance, Obasa warned that the conviviality between the House and the governor notwithstanding, “… it is necessary to harp on the fact that under democracy, this arm of government remains independent.” He told the governor that the Assembly “is a sanctuary and temple, just like every other temple anywhere where we all worship. No one will violate any temple and expect the gods to accept his or her sacrifice. And if such happens, there must be an appease to the gods to accept such atonement. No amount of intimidation or coercion will disintegrate or change the belief of all the members of this institution!”

Obasa was bold, and he did not hide it. Governor Sanwo-Olu, he warned, should perish the idea of getting a wishy-washy budget as “this honourable House will look at the budget and do the necessary scrutiny as usual”, adding that the assembly “will never be disgraced, abused or ridiculed in the name of creating a seamless working ambience.” Good talk. But not here; not in this nation!

The governor maintained his cool. That probably emboldened the Speaker to further warn “that those who live in glass houses must not throw stones as the saying goes…. In other words, those who are facilitating or planning to interfere in this House or destroy the cohesion of this institution should also be prepared for the same fate.”

Like someone under a spell, Obasa went ahead to talk about the touchy issue of Lagos governorship in 2027 and declared that if he made up his mind, he would contest, pointing out that he was not “too young or lack experience to run; whereas those who have been before me are not better off.”

Then he boasted, like a poor student of the concept of Avoidance Strategy in Stylistics, about his enviable ancestry which he claimed had never been in doubt and declared that he had “never claimed to be related to Onikoyi, Oniru, or any of the other popular Lagos families as the case may be.” Háà! ‘Lénu e (for your mouth), Mudashiru!

My people say that every man knows which proverb points in his direction; only the coward feigns ignorance. Who was Obasa’s target when he talked about not claiming any relationship with “any of the other popular Lagos families as the case may be?” Who were the past governors of Lagos State that “are not better off?” How did the Agege boy forget that Asiwaju Bola Tinubu was once a governor of the state; that Tinubu is believed to have ‘built’ Lagos? Did he also have the inimitable Alhaji Lateef Jakande in mind as one of those past governors?

If it were to be true that Obasa is better than all the other past governors of Lagos State, what does the first law of Robert Greene’s “The 48 Laws of Power” say about subordinates not outshining their masters? Where was Obasa when the late Senator Bayo Osinowo addressed the Assembly and told them how God reminded Satan that He, God “will never create, and I have never created, and I will never create what I can never destroy”?

Why did the ex-speaker decide to throw overboard the fine words of advice from the late senator to wit: “So, the leaders will not promote anybody they can never destroy. The leaders will not promote anybody they can never tear to pieces. They have codes, as they are promoting you, they are keeping your…, what do you call it, your file. So, if you continue doing good, they keep on giving you good things… But when you step on the toes of those who created you, you are in trouble. My new colleagues, I am begging you listen to your leaders…?”

Obasa grew up in Lagos. His knowledge of native wisdom may not be as sound as those of us the Lagosians call “ará ìlú òkè (those from the hinterlands). But he spoke about “eni bá yára l’ògún ńgbè. Meaning, the god of iron favours the swift”. If he knows that, why did he forget the wisdom in the saying that the okro can never be taller than the one that planted it; that to harvest the seeds, all the farmer needs to do is to bend the stem?

If native intelligence is lost on him, what about the injunction in the Qur’an, which in Surat 6, (2) Al-An’am, Allah “He is Who has created you from clay, and then has decreed a stated term (for you to die). And there is with Him another determined term (for you to be resurrected), yet you doubt (in the Resurrection)?”

Why did he not ask his Christian friends in the House to interpret Jeremiah 18:1-6, where God instructed Prophet Jeremiah to proceed to the potter’s house to learn the wisdom of what the creator can do to his creatures? Why did he not read verse 6 which says: “O house of Israel, cannot I do with you as this potter? Saith the Lord. Behold, as the clay is in the potter’s hand, so are ye in mine hand, O house of Israel.”

If it were to be a sane clime, Obasa would have been applauded for establishing the independence of the Assembly. But here, the godfather is like God. He creates and destroys that which he created! That is exactly what happened to Obasa on January 13. At a time, he was hearing the footsteps of his fellow members behind him, he never realised that those ones had gone back to take instruction from the godfather. That was why when his time came, nobody stood up to defend him! The creator holds the “codes!”

Power is like the venison of hoopoe (Àgbìgbò). It is the sweetest of all meats. No hunter likes to share it with anybody. If the godfather’s son is interested in Lagos in 2027, wisdom demands that all clay political creatures of the godfather should steer clear. Every wrestler should know that whenever he is confronted by his personal god, the end to all bouts has come. When a pigeon turns to òrófó, the hawk is always available to eat its chick.

How Obasa allowed himself to be drawn to fight his own Ori (head/destiny) is a research topic for students of Political Science. Now the godfather has scored yet another goal. 2027 will be an interesting year in Lagos. But more importantly, the dramas and razzmatazz that will herald the year are going to be more interesting. May we all be alive and have enough money to buy popcorn and ice cream as we watch the soap opera.