TOM SHAIBU YAKUBU, J.C.A. (Delivering the Leading Judgment): This appeal is against the ruling delivered by the National Industrial Court, holden at Lagos, which was delivered on 28th September, 2017. The respondent had instituted an action against the appellant and claimed that her dismissal from the services of the appellant, was unlawful, hence she claimed that she was entitled to special damages against the appellant. In opposing the claim, the appellant filed its statement of defence. It also contemporaneously, filed a Motion on Notice, seeking an order of the Court for the dismissal of the suit on the ground that there are defects in the respondent's complaint, which rendered it incompetent and thereby robbing the Court of its jurisdiction to entertain the suit. The respondent, filed a counter- affidavit and a written address in her opposition to the appellant's motion on notice aforesaid and also a reply to the appellant's statement of defence. The appellant, in turn filed a reβ¦