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Norwich Pharmacal: The Remedy Nigeria Forgot, and Why Gadzama May Return It

Background Between 1974 and 1976, English law invented four interim remedies. Nigeria adopted two, distorted one, and ignored the fourth. The 2026 decision in Gadzama v LPDC, may unwittingly provide

The 2026 decision in Gadzama v LPDC may inadvertently create a constitutional basis for Nigeria to adopt the fourth interim remedy, which was previously ignored. From 1974 to 1976, English law introduced four interim remedies, two of which were adopted by Nigeria but distorted, while the fourth was completely ignored. The Gadzama case may offer a way to incorporate this missing remedy into the Nigerian legal system.

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