move motion to regularize pastor
move motion to regularize pastor
Your honour we have a motion to regularize the processes filed out of time before this court.
The defendant has been served and so with the kind permission of the Court may we move the
motion sir
Your honour the motion is…
BROUGHT PURSUANT TO SECTION 6 (6) & 36 OF THE CONSTITUTION OF THE FEDERAL
REPUBLIC OF NIGERIA, 1999 (AS AMENDED); ORDER 23 RULE 2 of THE MAGISTRATE COURT
OF LAGOS STATE (CIVIL PROCEDURE) RULES 2019 AND UNDER THE INHERENT JURISDICTION
OF THE HONOURABLE COURT
Your honour the said motion is dated the ………… of February 2025
Your honour by this motion we are praying for….
1. AN ORDER OF THIS HONOURABLE COURT extending the time within which the Claimant/
Respondent may file and serve his Counter-Affidavit dated the 4th of November 2024 in
response to the Motion on Notice dated 27th September 2024 and filed on 1st October 2024.
and the Better and Further Affidavit dated the 27th of November 2024 in response to the
Motion on Notice dated 27th September 2024 and filed on 1st October 2024, in this case.
2. We are also praying for AN ORDER OF THIS HONOURABLE COURT deeming the already filed
and served Counter-Affidavit dated the 4th of November 2024 in response to the Motion on
Notice dated 27th September 2024 and filed on 1st October 2024, and the Better and Further
Affidavit dated the 27th of November 2024 in response to the Motion on Notice dated 27th
September 2024 and filed on 1st October 2024 already filed and served in these proceedings
as properly filed and served.
3. AND FOR SUCH FURTHER or other orders as this Honourable Court may deem fit to make in
the circumstances.
Your honor the grounds upon which the application is brought are as stated on the face of the
motion paper.
In support of the motion my Lord is an 8 paragraph affidavit deposed to by one Adisa Kazeem
Balogun, litigation clerk in our firm. We shall be relying on all the said depositions contained
therein Your honor in compliance with the rules of court we have filed a written address dated
the ….. of February 2025 We shall be adopting same as our oral argument in support of this
case.
We humbly urge your honour to grant our application.
Most grateful my sir.
Move in terms
Your honor we have a motion to regularize the processes filed out of time before this court. The
defendant has been served and so with the kind permission of the Court may we move in terms
sir…..
Your honour the motion is…
BROUGHT PURSUANT TO SECTION 6 (6) & 36 OF THE CONSTITUTION OF THE FEDERAL
REPUBLIC OF NIGERIA, 1999 (AS AMENDED); ORDER 23 RULE 2 of THE MAGISTRATE COURT
OF LAGOS STATE (CIVIL PROCEDURE) RULES 2019 AND UNDER THE INHERENT JURISDICTION
OF THE HONOURABLE COURT
Your honour the said motion is dated the ………… of February 2025
Your honour we seek the leave of the court to move in terms of the motion paper sir. Most
grateful my lord