Abstract
When Hon. Justice Inumidun Akande (Rtd), an erstwhile Chief Judge of Lagos State, unveiled the High Court of Lagos State (Civil procedure) Rules in 2012, a major striking feature was the introduction of the Pre-action Protocol Form 01 as one of the documents that must necessarily accompany a writ of summons or originating summons by virtue of Order 3 rules 2 and 8 which inexplicably omitted originating motions from the processes that must be so accompanied.
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