Daily Law Tips (Tip 793) by Onyekachi Umah, Esq., LL.M, ACIArb(UK)
Introduction:
There is a video showing a heavily bearded-man, that claims that where there is a divorce in Nigeria, the wife will not benefit from the property of the husband, unless the wife proves that she contributed financially to such property. And, that the wife will only get a share that equals her contributions. He compared the alleged Nigerian position with the cases of Jeff Bezos and Bill Gates, where their wives got (or may get) fortunes from the properties of their ex-husbands, without proof of contribution.
The content of the said video is a half-truth, having in mind the laudable and progressive legal innovations in the Nigerian matrimonial jurisprudence. This work will rely on some well researched academic works and the judgements of the appellate courts in Nigeria, to showcase the true position of Nigerian law on marital property settlement/sharing after divorce. It must be pointed out that section 72 (1) of the Matrimonial Causes Act is the basis for every settlement of property of divorced parties. This section grants discretion to courts to settle property of divorced couples in a manner that is “… just and equitable in the circumstances of the cases ….”.
Since divorce and settlement of marital property is the issue here, the Married Women’s Property Act 1882 will not be considered at all, because the federal law is used to determine ownership of property between married couples, where there is no divorce. The Married Women’s Property Act 1882 applies to married couples under the English Marriage, that are not divorced or divorcing.
The marriages to be considered in this work are the marriages made under the Marriage Act (ie, English Marriages). Hence, Customary Marriages and Islamic Marriages are omitted in this discussion. By the way, Customary and Islamic Marriages share property after divorce according to the customs and Islamic teachings that are not contrary to the Constitution of Nigeria. Ironically, most customs vests properties after divorce on the husbands and not on the wives (even where wives contributed to the property). This practice is against the fairness and equality preached by the Constitution of Nigeria, and will be discussed in a separate work.
Marriage, Divorce and the Marital property:
An English Marriage (Statutory Marriage) is the union of a man and a woman for life to the exclusion of all other persons and in accordance with the federal law on marriage (the Marriage Act). The marriage rites start from the Marriage Registries, where statutory notices are given. Also, the marriage may end in the Marriage Registry or in a licensed place of marriage, with a celebration of marriage having in attendance at least 2 witnesses. The celebration of marriage must be conducted before 6:00pm in the evening if in a licensed place of worship and 4:00pm if in a Marriage Registry.
English marriages are not immune to divorce and divorce comes with the need to share/settle the property of the marriage and the obligations towards the children of the marriage, that are less than 21 years old. Where there is a divorce and a settlement of property is needed, all the properties of the spouses are considered, including the property owned separately or jointly. It means that a property in the name of either spouses or in their joint names are to be considered, as well as a property that belongs to any of them but in the name of a third party (trustee). Properties already settled by a Pre-Nuptial or Post Nuptial agreements are also to be considered by the court, since such agreements are never final in Nigeria.
Marital property has not been defined by any law in Nigeria. However, the Nigerian courts have tried to define this term or make conclusions as to what it is. In the case of MR. THEOPHILUS OKEY ANIETO v. MRS. VERONICA EBELE ANIETO (2019)LCN/12987(CA), the court explained marital property, when it stated, that; “It is however essential that the property should have been purchased in the course of the marriage or where the property was purchased before the marriage, that the payment for the property was completed after and in the course of the marriage, as in the case of a property purchased on mortgage ….”. Hence, it is safe to conclude the martial property is a property that its full ownership was acquired the course of marriage by any of the spouses.
It is important to point out that many scholars have argued that by the words of the Matrimonial Causes Act, the court cannot share property (in the sense of transferring titles) in cases of termination of marriage but can only settle properties (by giving access and possessions to property according to needs of parties). Hence, the scholars further differentiated the settlement of marital property from the sharing of marital property.
A critical look at the Matrimonial Causes Act, specifically sections 70, 71, 72 and 73, rather reveals the unlimited powers of the courts in determining the fate of all properties of spouses, where there is divorce. It does not focus on ownership of property, since undoubtedly, ownership rests on the marriage union and their participants. Rather it focuses on the management (sharing and settlement) of the property for the benefits the participants of the marriage union. Property ownership are issues of land law and corporate law and not family law (divorce), in a sense.
At this point, this work will defeat the temptation of delving into the jurisprudence of sharing and settlement of property but focus on legal awareness on the powers of courts to direct the affairs of marital property for the good of spouses and their children. To this end, sharing of marital property and settlement of marital property are used interchangeably to mean one and same thing; the determination of the fate of property for the benefit of spouses and their children, to ensure post marriage wealth redistribution and adjustment.
Settlement/Sharing of Marital Property:
By agreement, a couple may settle their property through a Pre-Marriage Agreement (Pre-Nuptial Contract) or a Post-Marriage Agreement (Post-Nuptial Contract). Above all, all agreements towards the sharing and settlement of marital property must be presented to a State High Court for the Judge to verify it and ensure that it is “… just and equitable in the circumstances of the cases …” and in line with the Matrimonial Causes Act (a federal law for termination of English marriages). To this end, there cannot be a valid and lasting settlement of marital property without the orders and blessings of a court of law.
Only the State High Courts and the High Court of the Federal Capital Territory, Abuja, can entertain and resolves cases of divorce and settlement of marital property in English marriages. Hence, the Magistrate Courts, Customary Courts, Area Courts and National Industrial Court cannot entertain such cases, in any part of Nigeria. The judges of the High Courts are to settle marital property by applying fairness, equality, equity and in line with the needs of spouses and their children. However, there are two major approaches or models that judges in Nigeria apply in the settlement of marital property, and there are the Male-Chauvinist Approach and the Egalitarian Approach.
1. 1. The Male-Chauvinist Approach:
The most common approach in the settlement of property in Nigeria is the Male-Chauvinist Approach, where judges focus only on the strict property title rights. The Spouse whose name is on the title document of a marital property is deemed the owner, unless the other spouse has documentary evidence of co-ownership/joint ownership or tangible contribution to the same property. Often, marital property titles are in the name of male spouses, so that the Male-Chauvinist Approach is seen to favour most male spouses.
The Male-Chauvinist Approach focuses only on the direct financial or non-financial contributions of spouses towards a property, for it to conclude that there is a joint ownership. It relies a lot on the principles in the case of ONABOLU v. ONABOLU (2005) 2 SMC 135; that “… a person who claim to be the joint owner of a property must be able to quantify his contribution. He must give detailed particulars and support them where necessary with receipts of what he bought towards the building of the property…”.
This model is simply, a garbage in, garbage out system. In this a husband or wife receives only what he/she proves to have DIRECTLY contributed FINANCIALLY/NON-FINANCIALLY towards the property of the marriage. And, whatever contribution that cannot be proven is lost and the marital property lost too. It is title-finding oppressive and highly conservative. It does not consider the INDIRECT, INVISIBLE and often UNQUANTIFIABLE contributions of spouses towards marital properties.
It is on its own, a contradiction of the principle of family contract, where contracts are often oral and unwritten, made in beds and kiss, without any fear of breach of contract. The Male-Chauvinist Approach is narrow, discriminatory, male-biased and divisive. It treats marital property and contributions to it in isolation to all other marriage sacrifices and contributions and also expects every family agreement to be documented.
This approach pays deaf ears to the realities of Nigerian marriages, where wives do a lot of unpaid family chores and also serve their husbands, for their husbands to focus their own resources towards acquiring marital property for the family. The Male-Chauvinist Approach says that a wife that took care of all household groceries and children school fees, so that the husband could focus his own resources on acquiring a family house, has not made any contribution to the family house.
It is an unfair approach designed to oppress women and wives, and has a strong origin in the customary laws in Nigeria, where wives are may helpers and properties of their husbands. The Male-Chauvinist Approach is a sympathizer to the repugnant customary systems, where “wives are mere properties and as properties, cannot own properties”. It puts the onus on wives to show documentary proofs of their contributions to the ownership of a marital property, even where there are obvious proof that wives earned more and even took care of other family affairs and cost.
Male-Chauvinist Approach was enforced in the cases of Amadi v Nwosu 1992 Legalpedia SC UJBT 1, 4; Akinboni v Akinboni [2002] 5 NWLR (pt 761) 564; Essien v Essien [2009] 9 NWLR (Pt 1146) 306, 331-332; Egunjobi v Egunjobi (1976) 2 FNLR 78; Kafi v Kafi [1986] 3 NWLR (Pt 27) 175 (although the court recognized the unquantifiable and quantifiable contributions of the wife); Nwanya v Nwanya [1987] 3 NWLR (Pt 62) 697; Sodipe v Sodipe (1990) 5 WRN 98 and many others.
2. 2. The Egalitarian Approach:
The Constitution of Nigeria is fixed on fairness and equality of all persons (egalitarianism), including husbands and wives. Also, the Constitution overrules all other laws, customs and judgements in Nigeria, including the Matrimonial Causes Act. The Egalitarian Approach in settlement and sharing of marital property, treats spouses are equals and takes into account their wholistic contributions to the marriage.
It focuses on the DIRECT and INDIRECT, VISIBLE and INVISIBLE, QUANTIFIABLE and UNQUANTIFIABLE contributions of spouses towards marital properties. It is liberal, open-minded and unbiased towards any spouse or sex, by treating all spouses equally and fairly. Hence, marital properties are considered to be jointly owned by both spouses, since both contributed in diverse ways towards the marriage itself and not towards specific items and properties.
In the face of marital realities, wives, often play non-financial roles towards property acquisitions and as such must not be left out in the sharing of marital properties. In some cases, wives earn salaries and own large investments, after all they are human beings. Where because of undeniable closeness to children, wives orally agree to focus their wealth on the education and advancement of the children, while husbands focus theirs on marital properties, it is injustice for any court to deny that the wives are co-owners of the marriage properties.
Under the Egalitarian Approach, the justice-focused courts, rely on the principle of equity to determine the rights of spouses to a property and not on proof of financial/non-financial contributions to the property. This is a property redistribution model. Under this, every ex-spouse is compensated from the wealth of their union. The sense here, is that while a spouse (mostly a wife) makes food, babysits and focuses on house chores, she indirectly contributes to the purchase of any marital property by her spouse. With this approach and model, the cases of Jeff Bezoe and Bill Gates (where their wives got chunks of the investment of their husbands, without having any direct contributions to such) would have also been same in Nigeria. This model is adjustive, equitable and reflective of Nigerian families.
The Egalitarian Approach is supported by the judgments of Nigerian appellate courts in the cases of Oghoyone v Oghoyone [2010] 3 NWLR (Pt 1182) 564, 584 (CA); Okere v Akaluka (2014) LPELR-24287 (CA) 1, 60-61; MR. THEOPHILUS OKEY ANIETO v. MRS. VERONICA EBELE ANIETO (2019)LCN/12987(CA) and others. Some of the positions of the courts on the Egalitarian Approach in the above cases are briefly discussed below;
1. The court in the case of Mueller v Mueller [2006] 6 NWLR (pt 977) 627, where a man claimed a joint ownership of a marital property and the court, held that; “As husband and wife there is nothing wrong in buying property in the name of one of the parties. Such still remains marital property which belongs to the parties jointly”.
2. The court in the case of Oghoyone v Oghoyone [2010] 3 NWLR (Pt 1182) 564, 584 (CA), opined that; “Bearing in mind the changing social and economic realities, a Judge is to ascertain the parties shared intentions, actual, inferred with respect to the property in the light of their conduct. In that light I am satisfied that when the going was good the parties made contributions to ensure that they had good living accommodation. When the going turns bad it is only right and equitable that each side recoups its contribution and call it a day.”
3. In the case of Okere v Akaluka (2014) LPELR-24287 (CA) 1, 60-61, the court stated, that; “Rather, the dictum of Denning, M.R. in the Falconer’s case (supra) where he held that sometimes the indirect contributions of a wife to the marital property cannot be quantified in monetary terms which would entitle her to a share in the property should apply, accords with modern reality particularly where the parties were husband and wife of Christian and Statutory marriage. Thus, it was held in the Falconer and Rimmer cases, that wives were entitled without further proof to share in the marital property acquired during marriage since it was the performance of their functions as wives that enabled their husbands (if at all in this case ) to perform theirs.”
4. In the recent case of MR. THEOPHILUS OKEY ANIETO v. MRS. VERONICA EBELE ANIETO (2019)LCN/12987(CA); “… it is correct that the contribution of a party does not necessarily have to be in the nature of cash outlay for the purchase or development of the property. It can be by way of moral and/or financial contribution to the business of a husband by a wife where the property is purchased from the profits of the business… It is however essential that the property should have been purchased in the course of the marriage or where the property was purchased before the marriage, that the payment for the property was completed after and in the course of the marriage, as in the case of a property purchased on mortgage.?”
Conclusion:
English marriage can only be terminated by a court of law and the marital property shared by the court, among the spouse and for the benefit of the children, in a manner that is “… just and equitable in the circumstances of the cases …”. Hence, the fairness in the settlement and sharing of marital property sits on the plates the judges of the High Court. Judges are encouraged to be egalitarian at all times, focusing on fairness to all spouses under the Egalitarian Approach in the settlement of marital property.
While, there are calls for the amendment of the Matrimonial Causes Act (MCA) to expressly acknowledgment indirect and invisible contributions of spouses towards marital property, progressive judges are already exercising their powers under section 72 of the MCA, fairly and equitably by adapting the Egalitarian Approach in the settlement of marital property. There is no need to wait for legislative changes, where judges have discretion. Hence, there is need for some of the matrimonial cases to reach the apex court (the Supreme Court of Nigeria) for the court to lend its voice and weight to the Egalitarian Approach.
My authorities, are:
1. Sections 1, 2, 3, 4, 5, 6, 33 to 45, 318 and 319 of the Constitution of the Federal Republic of Nigeria, 1999.
2. Section 1, 2, 3, 6, 7, 8, 9, 10, 11, 12, 13, 14, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 33, 34, 35, 39, 42, 46, 47 and 49 of the Marriage Act, 1914.
3. Sections 1,2, 15, 16, 70, 71, 72, of the Matrimonial Causes Act, 1970
4. The judgment of the Court of Appeal in the case of Mueller v Mueller [2006] 6 NWLR (pt 977) 627.
5. The judgment of the Court of Appeal in the case of Oghoyone v Oghoyone [2010] 3 NWLR (Pt 1182) 564 or accessed 14 May 2021
6. The judgment of the Court of Appeal in the case of Okere v Akaluka (2014) LPELR-24287 (CA) 1, 60-61 or accessed 14 May 2021
7. The judgment of the Court of Appeal in the case of MR. THEOPHILUS OKEY ANIETO v. MRS. VERONICA EBELE ANIETO (2019)LCN/12987(CA) accessed 14 May 2021
8. Chinedu Efe and Oghenerioborue Eberechi, “Property Rights of Nigerian Women at Divorce: A Case for a Redistribution Order” [2020] 23 PER / PELJ accessed 18 May 2021.
9. Michael Attah, “Divorcing Marriage from Marital Assets: Why Equity and Women Fail in Property Readjustment Actions in Nigeria” [2018] 62 (3) Journal of African Law accessed 18 May 2021
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44. Onyekachi Umah, “Abandonment Of Wife/Husband, Children Or Dependants Is A Crime” (LearnNigerianLaws.com, 3 December 2019) accessed 20 April 2021
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55. Onyekachi Umah, “Can Court Dismiss Divorce Case Because Husband Impregnated Wife?” (LearnNigerianLaws.com, 12 March 2021) accessed 14 May 2021
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