In Tabik Investment Ltd V Guaranty Trust Bank Plc (2011) LPELR-3131 (SC); & Biye V Biye (2014) LPELR-24003(CA) amongst other numerous decisions, the Supreme Court and this Court have stated emphatically that payment of legal fees and evidence of same is an integral part of the certification process, it cannot be waived and none can be exempted from paying such certification fees. It is not in issue that the documents tendered as Exhibit 41 are public documents, and the law is that for them to be legally admissible evidence, they must be duly certified – Sections 102 to 105 of the Evidence Act, 2011; Alamieyeseigha V FRN (2006) 16 NWLR (Pt. 1004) 1; & Araka V Egbue (2003) 17 NWLR (Pt. 848). It is also the law that, with regard to public documents, persons interested in being issued with certified true copies of same by those having custody of them, must pay the prescribed fees before same are issued.
— J.H. Sankey, JCA. Brila Energy Ltd. v. FRN (2018) – CA/L/658CA/2017