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I am not entirely sure what counsel for the 1st Cross-Respondent intended to achieve by relying on sections 146(3) and 385 of the CAMA 1990 to contend that the transaction was a contract under seal and therefore subject to a 12-year limitation period.
The difficulty, to my mind, is that both provisions are quite express as to their subject matter.
Section 146(3) concerns the issuance and form of share certificates, while section 385 concerns the recovery of declared dividends. Neither provision, on its face, provides that a transaction involving shares constitutes a contract under seal, nor does either provision prescribe a 12-year limitation period for claims arising from the acquisition of shares.
That makes the reliance on these provisions rather curious, particularly where the claim itself appears to have centred on monies paid for shares that were allegedly not allotted and a subsequent purported allotment of those shares.
Indeed, section 385 is particularly difficult to reconcile with the argument because its 12-year period is expressly tied to a specific subject: dividends.
Perhaps there was a more nuanced doctrinal basis for counsel's submission, but not from the provisions themselves.
The GOAT debate Messi settled was always between him and Maradona. Iβm not sure why Ronaldo fans are convulsing when the debate between Messi and Ronaldo was never really about who the GOAT is but simply about who was the greater player of this generation.
Inherited $350 billion. Handed back $4.7 trillion. Thatβs $4.3 trillion of market value in 15 years. About $800 million a day.
And he did it as the first openly gay Fortune 500 CEO and being asked to follow Steve Jobs.
[Only Jensen Huang has created more market value as a CEO.]
There's a place for Tim Cook in the business hall of fame.
Some thoughts on Abubakar v. Providus Bank Ltd. (SC/CV/132/2026):
1οΈβ£ I found it curious that in his dissenting judgment, Garba, JSC still referenced the now-deleted section 233(5) of the 1999 Constitution (as amended). That subsection was expunged by the Second Alteration Act, 2010, a point the lead judgment itself (per Abubakar, JSC) took care to flag and correct in respect of counsel's own reliance on it. Not entirely sure why it resurfaced in the dissent.
2οΈβ£ I agree with the Appellants' position that issue/ground 2 (computation of time for filing the notice of appeal) was properly a ground of law alone, not mixed law and fact. The relevant facts, the date the ruling was delivered and the date the notice of appeal was filed, were never in dispute. What remained was purely a question of statutory interpretation: whether section 15(2)(a) of the Interpretation Act had been correctly applied by the Court of Appeal in excluding (or failing to exclude) the date of the ruling from the computation. Where the facts are settled and all that's left is applying the law to them, that's a ground of law.
3οΈβ£ One gap I noticed: the Court never squarely addressed the Appellants' core factual allegation, that the scheme document eventually presented to the trial court for final sanction materially differed from the version the shareholders had actually approved at the earlier court-ordered meetings. The Court dismissed this as a matter properly requiring "investigation of contested facts" (hence mixed law and fact, requiring leave), and separately found "nothing on record suggesting... any feature rendering the Scheme unfair" when exercising its own section 22 powers, but at no point did it directly engage with or resolve the alteration allegation on its merits.