MOHAMMED MUSTAPHA, J.C.A. (Delivering the Lead Ruling): This is an application brought pursuant to Order 6 Rule 4 and 15 of the rules of this Court, 2011, and the inherent jurisdiction of the Court; for leave to amend the Notice of Appeal dated 25th, and filed on the 29th of September, 2013, and any such order as this Court may deem fit to make in the circumstance.
The grounds of bringing the application are:
1. After the filing of the original notice of appeal and appellant's brief of argument, there was a change of counsel as Chief A.S. Awomolo SAN was briefed to take over the appeal;
2. A close review of the judgment of the lower Court and the grounds of appeal and subsequent discussion with the appellant's Director of Legal reveal that it has become necessary to amend the entire grounds of appeal in the manner in which the real issue arising from the appeal may be determined by this Court;
3. The issues raise substantial issues of law which breached fundamental rights of the applicant…