In 1959 a Fundamental Rights Chapter was included, for reasons which are wjdely known,1 in the Constitution of the Federation of Nigeria.2 While the number of reported decisions directly involving that Chapter of the Constitution is as yet relatively small, it seems desirable to discover the approach which the courts have taken in such cases. It appears that little thought is being given in Nigeria to the manner in which the courts do, or should, treat fundamental rights cases. Many persons, in the tradition of Ivor Jennings, discount altogether the value of having fundamental rights provisions in the Constitution. Further battle with such persons is useless, for the provisions are in the Constitution; the question is no longer whether they should be there, but is rather what use should be made of them. This latter problem is not one for judges alone, though they bear the immediate brunt of meeting it. It is a problem for lawyers, law teachers and students, political scientists, indeed for society as a whole; and it must be given some more or less satisfactory answers if the courts are to play the part which the Constitution obviously intends they should play.