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I. L. KUTIGI, J.S.C (Delivering the Lead Ruling): This is a Motion on Notice by the appellant/applicant praying this Court for-
"(a) Leave to amend the Notice and Grounds of Appeal filed on 27th January,1989, against the judgment of the Court of Appeal dated 11th November, 1988;
(b) leave to amend Plaintiff Writ and pleadings to enable plaintiff claim for his lost 13371 bags of granulated white sugar in the currency of USA dollars in which plaintiff prepaid the cost of his entire cargo of sugar;
(c) leave to argue points not taken in the Courts below:
(d) an order waiving the rules of Court so as to deem as properly Filed and served the Additional Appellant Brief now sworn along as Exhibit D herein, being substantially the same as was filed without leave of Court on 25/11/91.
And for such further and/or other orders as this Honourable Court may deem fit to make in the circumstances.
And further take notice that the applicant will at the hearing of this Motion rely on the Record of App…