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Where a document attached to an affidavit is neither marked as exhibit nor referred to at all in the affidavit, such a document is generally deemed that no evidence has been placed before the Court. Nonetheless, courts will still proceed to consider such a document on its merit since the decision is subject to review by the appellate Courts.[1]
Relevant rules of court should be referred to. For instance, Order 17 of the Court of Appeal Rules makes reference to exhibits mandatory.
[1]NDCA & GASPA Projects Management Engineering Ltd. v GASPA Project Mgt. Group Ltd and others (2019) LPELR-47607(CA).