IN THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY

IN THE ABUJA JUDICIAL DIVISION

HOLDEN AT ABUJA

SUIT NO: FCT/HC/GWD/CV/66/2023

BETWEEN

COMR. CHIMA KENNETH

EMEKA.…………………………CLAIMANT/APPLICANT

AND

NIGERIAN BREWERIES PLC ……………………………DEFENDANT/RESPONDENT

THE CLAIMANT’S-APPLICANT’S WRITTEN ADDRESS IN SUPPORT OF THE

MOTION FOR EXTENSION OF TIME

1.0 INTRODUCTION
The Claimant filed an application before this Honourable Court praying
for the following orders:
1. AN ORDER of this Honourable Court extending the time within which
the Claimant/Applicant may file her Final Written Address as ordered
by this Honourable Court on the 2nd Day of November 2023 in line
with the Rules of this Court.
2. AN ORDER of this Honourable court deeming the already filed and
served Final Written Address of the Claimant/Applicant filed on the
_________ day of ____________, 20______ as properly
filed and served

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 And for such further orders or orders as this honourable court may
deem fit to make in the circumstances.

2.0 ISSUE FOR DERTEMINATION

In arguing this application, the applicant humbly formulates a single
issue for determination:
(i) Whether in view of the affidavit evidence before this court, the
applicant is not entitled to the relief sought.

3.0 ARGUMENT ON THE ISSUE

It is my humble submission that by virtue of the affidavit evidence placed
before this court, the applicant is entitled to the relief sought subject to the
discretion of this court. In law, an application for an extension of time is
designed to vest the applicant with the right of being heard in the suit so
that the court can decide the rights of parties on the merit and not punish
them for mistakes or acts done as a result of circumstances beyond their
control in the conduct of their matter before the court which would not
sacrifice justice on the alter of technicalities.
See U.T.C (Nig.) Ltd V. Chief Pamotei&Ors. (2002) FWLR (pt. 129) 1557

My Lord, Order 49 Rule 4 of the Civil Procedure Rules of this Court provides
as follows:
“The court may, as often as he deems fit and either before
or after the expiration of the time appointed by these rules
or by any judgment or order of the court, extend the time
or adjourn for doing any act or taking any proceedings.”
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My lord, this Court has powers to grant this application and I humbly submit
that this application will not prejudice the respondent and it is not brought
mala fide, it ought to be allowed. I urge your lordship to so hold.

In the case herein, the necessary processes have been filed in accordance
with the rules of this Court and the appropriate fees have been paid, the
applicant obviously is entitled to the discretion of your lordship.

4.0 CONCLUSION
It is my humble submission that the applicant has sufficiently by the
affidavit evidence before this honourable court, lucidly shown the need for
your lordship discretion.

I, therefore urge your Lordship to grant this application.

Dated this..............................day of............................202……..

__________________
C. I. MAIDOH-ANENE, ESQ.,
MARK JOSEPH SEKPE
℅ Ifeanyi Anugom &Co,
Life-Will Plaza,
Opposite Gwagwalada Market,
Gwagwalada
07069650525
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 Collins.paradigmslaw@gmail.com
For Service On

Nigerian Breweries PLC,

℅ Counsel:

Uche Nworah Esq.,

of Uche Nwarah & Co,

Suit 2002, Anbeez Plaza,

Wuse 5 Abuja.