While applications for amendments cannot be totally avoided in the judicial process, they could be reduced to a manageable level, as opposed to the present trend where they are in annoying proliferation. Let me proffer some solutions. And I think they can help to some extent, if not to all extent. Litigants and counsel who do their work diligently will certainly reduce the frequent applications for amendment. So much of it can be avoided if both counsel and his client are intimately involved in pre-trial factual investigations and inquiries before going into litigation and filing their pleadings. Counsel, on his part, can reduce the frequency of applications for amendment if he takes pains during chamber pre-litigation interviews, to ask and seek for relevant information, oral and documentary, from the client. There is also the collateral aspect of the matter and it is this. The client on his part, has a duty to surrender all the facts of the case and I really mean all the facts of the case (including incriminating and exculpating evidence) to his counsel. I say this because one of the basic causes of frequent application for amendment is that some clients are of the habit of dishing out half truths to their counsel or deliberately give facts in installments, only to get stock in open court to the embarrassment of counsel. That is not right. No party has any right to either adulterate the facts of a case or give facts to counsel piece meal.
— Tobi, JCA. Abraham v Olorunfunmi (1990) – CA/L/83/89