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SPECIAL DAMAGES REQUIRES PROOF

Dictum

In Neka B.B.B. Manufacturing Co. Ltd v. ACB Ltd (2004) 2 NWLR (Pt 858) 521 at 540 this Court held on the point thus:- “It is trite law that where the claimant specifically alleges that he suffered special damages he must per force prove it. The method of such proof is to lay before the court concrete evidence demonstrating in no uncertain terms easily cognisable the loss or damages he has suffered so that the opposing party and the Court as umpire would readily see and appreciate the nature of the special damages suffered and being claimed. A damage is special in the sense that it is easily discernible and quantified. It should not rest on a puerile conception or notion which would give rise to speculation, approximation or estimate or such fractions.”

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SPECIAL DAMAGES WILL BE UPHELD UPON EVIDENCE ADDUCED AND NOT CHALLENGED

On special damages, it has been held that where the plaintiff plead the special damages and gives necessary particulars and adduce some evidence of it without the defendant challenging or contradicting the evidence, he has discharged the onus of proof placed on him and unless the evidence adduced is of such a quality that no...

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SPECIAL DAMAGES DOES NOT SUCCEED ON ADMISSION BY OTHER PARTY – SPECIAL DAMAGES MUST BE STRICTLY PROVED

The paramount question that arises is whether a claim for special damages such as the Respondent’s claim in the instant appeal, will succeed on the defendant’s part admission of the claim. This was the question answered by the Supreme Court in the case of NNPC V CLIFCO NIG. LTD (2011) 4 MJSC 142 at 174...

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NO QUANTITY OF EVIDENCE TO WARRANT SPECIAL DAMAGES

Judicial decisions have shown that there is no particular type or quantity of evidence to warrant special damages. See the case of SPDC Ltd v. Tiebo VII & Ors (2005) 9 NWLR (Pt. 931) 439 wherein this Court said:- “…in other words, it is a general guide and arises from the fact that it is...

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SPECIAL DAMAGES MUST BE PROVED TO THE LAST KOBO

The law is settled that where a party claims special damages, the burden is on him to prove the special damages to the last kobo. He has to do this by leading credible evidence most of the time by documents which show the actual loss he has suffered. See Arisons Trading & Engineering Co. Ltd...

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SPECIAL DAMAGES SUCCEEDS ONLY ON ACTUAL LOSS

It is indeed trite that a claim for special damages must not only be specifically pleaded item by item with corresponding monetary value of the claimed item, the items as particularized must further be proved by credible evidence for the Court to grant the claim. Where special damages have not been specifically pleaded and proved,...

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CLAIMANT SHOULD ESTABLISH ENTITLEMENT TO SPECIAL DAMAGES

Whenever special damages are claimed, the party so claiming has an uphill task of a strict proof. In effect the rule requires anyone asking for special damages to prove strictly that he suffered such special damages as he claimed. Thus, the claimant should establish his entitlement to that type of damages by credible evidence of...

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