judgments of the Court. The fact that the Plaintiff herein is a judgment creditor is not in issue. In fact, he has taken advantage of Article 24(2) only for his efforts to be torpedoed by the constraints inherent in rules of civil procedure in the 1st defendant’s country as evidenced from Annexure CM8 & CM9. Be that as it may, the Plaintiff’s suit hinges on the failure of the 1st defendant to voluntarily comply with the judgment of this Court in the Suit No. HRCM/376/15 granted in his favour. The inability of the Plaintiff to utilize the methods provided by the rules of this Court for the execution of the judgment was as a result of the 1st defendant’s failure and/or neglect to live up to its obligations as a member of ECOWAS. In such situation, what cause of action, if any, is open to the Plaintiff? A “Cause of action” has been defined in Halsbury’s Law of England (4th ed), Vol 37, para 20 at page 27 as follows: “ ..a factual situation the existence of which entitles one person to obtain from the court a remedy against another person. The phrase has been held from earliest time to include every fact which is material to be proved to entitle the plaintiff to succeed, and every fact which the defendant would have a right to traverse. Cause of action has also been taken to mean that particular act of the defendant which gives the plaintiff his cause of complaint, or subject matter or grievance founding the action, not merely the technical cause of action.” 15

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