Sexual Harassment in the Workplace: Case Study of the Nigerian Legal Sector

Sexual Harassment has been a habitual phenomenon among legal professionals. Consequently, “suffering and smiling” is the concealed solution to this challenge due to the importance of livelihood and career development. This study seeks to examine the prevalence of sexual harassment within the Nigerian legal profession, whether there is need for the victims to be protected and provided with legal structure to confidently report issue of sexual harassment, and whether there is a need for domestic law for the society. Empirical and descriptive research methods were adopted, 561 Nigerian lawyers were surveyed using a structured questionnaire. Data were collected and analyzed using frequencies, chi-square, chart, regression and correlation analysis. It revealed that there is no adequate social structure for addressing sexual harassment and prolonged exposure to sexual harassment has disguised its true effect on the victims. Thus, there is a need for professional regulation to combat sexual harassment among the lawyers. Keywords: Behavioural adaptation; Nigerian legal professionals; National Industrial Court of Nigeria; Unprofessional behaviour: Sexual harassment in the workplace DOI : 10.7176/JLPG/86-13 Publication date :June 30 th 2019

military and paramilitary sectors. However, (Amos, 2016) reported that the Nigerian women police of the selected survey are victim of discrimination, intimidation, sexual harassment and hostile environment in the course of their day to day work activities. Especially in the area of posting when the senior rank officers either demand for sexual gratification or money in exchange for good posting, which is ordinarily one of the officer's primary duty.
Nevertheless, our point of controversy is whether the Nigerian legal profession is affected by the societal trend called sexual harassment? (Ladebo, 2003) reported that sexual harassment permeates all facets of Nigerian national life and he further referred to the statement of one of his respondents-'even at the bench, there is harassment, so who is going to judge the case?' Although this statement was uttered by an interviewed judge prior the Constitutional empowerment of the (NICN) to adjudicate on sexual harassment matters. However, till date there is no statistical proof of this assertion, neither at the bar nor at the bench. This is one of the gaps this study seeks to fill. In a conference organised by the International Bar Association in 2009, Adekoya, a Senior Advocate of Nigeria (SAN), (Adekoya, 2009) acknowlegded that female lawyers face certain problems within the profession, ranging from; gender-discrimination to gender pay-gap, with explicit exclusion of sexual harassment, although gender-discrimination is one of the types of sexual harassment according to Fitzgerald and Ormerod which cannot be easily detached from sexual harassment in the workplace (Fitzgerald and Ormerod, 1991).
Based on our observation, there is no research on sexual harassment and legal sector or workplace violence faced by Nigerian legal practitioners especially the women. Is it that the lawyers are not vulnerable to sexual harassment or they also suffer in silence like other professionals? as reported by some researchers (Amazue et al., 2014;(Ezichi et al., 2013) that victims of sexual harassment suffer in silence especially the bankers. It was further argued that it can be easily found in entertainment industry, government offices, and private organisations, though some professions are more prone to it (Gupta, 2014). Therefore, should legal profession be added to the list of professions that are more prone to sexual harassment? All these gaps prompted the authors to embark on this survey, in order to statistically and empirically justify whether sexual harassment exist within the Nigerian legal profession. In our study, we examined the prevalence of sexual harassment among the Nigerian legal professionals, causes, frequencies of occurrence, duration, their level of awareness and the inability of the NICN to address sexual harassment cases, as well as consequences of sexual harassment.

Research Questions
 Does sexual harassment (SH) occur within the Nigerian legal sector?  What is the prevalence of sexual harassment among the Nigerian Legal Professionals by gender?  Do Nigerian Legal practitioners fall victim of sexual harassment at workplace due to low level of knowledge of the act?  Is there a need for legal protection of the Nigerian legal professionals (NLP) from sexual harassment in the workplace?

Research Hypotheses 1.
There is no effective policy that maintains and sanctions employers/employees against sexual harassment in the workplace or court. 2. There is no relationship between awareness of the lawyers about the empowerment of the National Industrial Court of Nigeria and its ability to prevent the workplaces from sexual harassment. 3. Prolonged exposure to sexual harassment has led to the development of coping mechanism which masks its true nature and consequences on the victim. 4. There is no relationship between the prevalence of sexual harassment in the legal profession and the necessity for legislative protection.

Participant and Procedure
To ensure a nigh accurate response, a pilot study was conducted on 40 subjects within February to April, 2017, afterwards, a few minor changes were made on the original research instrument (questionnaire) based on the respondents' feedback (Joubert et al., 2011). It is worth noting that the questionnaire was structured in anonymity due to the calibre of the participants surveyed and the sensitivity of the topic. The revised structured online or internet questionnaire was displayed or uploaded on google drive and disseminated to the target population via different Nigerian legal social groups, such as-collective email, WhatsApp, LinkedIn, and Facebook (Clancy et al., 2014). Due to the low response of the respondents through on-line survey, the paperand-pencil method was subsequently adopted for the completion of data collection (Loughnan et al., 2013). We approached the Abuja residence lawyers at legal gatherings, offices and court rooms for the data collections within the period of August 2017 to January 2018. Of about 780 questionnaires distributed, only 561 Nigerian lawyers provided the necessary information for this survey (Vosylis et al., 2012). The sampling was selected randomly through a purposive and stratified sampling technique due to the variables and objective of the study, as well as the various locations that the data was collected. The sample size was drawn from selected population of Federal Capital Territory, Abuja Nigeria due to the fact that it is the seat of power and sexual harassment have been criminalized since 2015 by ViolenceAgainstPersonsProhibitionAct (2015) in this region and still, there is neither a significant report nor empirical study on sexual harassment and its effect on the people.

Measure
The analysis of the data collected was done by the use of IBM Statistical Package for Social science (SPSS) 20. The 29 questions contained in the questionnaire were sectionalized into eight parts according to the (4) research questions and (4) hypothesis raised. Descriptive statistics involving frequencies and percentages was used to compute the participants' demographics and the research questions. While the first and second hypotheses were measured by partial correlation, third by Pearson chi-square and fourth by regression analysis (Haas et al., 2009;Ismail et al., 2007;Berdahl, 2007a).

The Participants' Experiences
The focus group discussions and the open-ended session of the research instrument (questionnaire) revealed the following information: "'I was subjected to torture, and emotional blackmail. I was made to believe I was not good at any other thing than sex. In order to keep my job, I had to play to the tunes of my head of chambers. He can even come to my house at odd hours and I could not say no, all because I wanted to keep my job. When I started refusing his sexual advances, it got so bad that he almost assaulted me. Started picking on me, and ended up giving me an indefinite suspension' 'I know of a friend who resigned from her work place because she has been harassed by her boss and the office is in his house, she was so scared at the fact that if he rapes her or does something worse, that there will be no one to help her.' 'Yes, I was a victim of sexual harassment and my employer sleeps with almost all the employees including the interns. He also creates enmity amidst all employees in order to divide and rule us. I got tired of dancing to his tune since he places the official benefits on the employee's ability to subject herself to his demands, I revolted by confronting him, then he first suspended me and while the suspension was going-on, he directed I'm served with termination letter at home. A year after, he terminated another colleague because she also got tired of messing with him.' 'I am a victim of sexual harassment, but when it is coming from a superior which is mostly the case, how should I cope with it?' 'My experience took place years ago, when I was still very young and single. I really had nobody to report to, but a senior colleague and my pastor. 126 offenders will put a lot of men and women in check and give courage to the victims to speak out…' Table 1. The occurrence of SH among participants in terms of forms experienced-range from unwanted deliberate touching, turning work discussions to sexual topics, asking personal questions on sexual life, sexual comments about the person's clothing or look, to unwanted sexual looks or gestures; Frequency of SH ranges from very occasionally to rarely; Colleagues' experience and the impact of SH on the growth of the profession is shown in Table 2 below. This indicates that there is high occurrence of SH in the Nigerian legal profession.  Figure 1: shows that 68.0% of female participants in the study experienced Sexual Harassment as compared to 32.0% male that experienced same. This suggests that female lawyers are more vulnerable or prone to sexual harassment in the profession.  Table 3 depicts that there is a high level of knowledge of sexual harassment among the professionals, but the knowledge of the participants does not secure them from being harassed.  Table 4 depicts that mandatory provision of internal official provision, amendment of legal practitioner' Act/Rules and setting up of a body with confidential procedures to address issues of sexual harassment could serve as long-term solution to SH in the legal profession, and there is need for law to prohibit/sanctions sexual harassment at workplace base on the total percentage (91.1%) participants in agreement to this. There is no effective policy that maintains and sanctions employers/employees against sexual harassment in the workplace or court. 5.1.5 Table 5: reveal that the partial correlation (r=0.044, p=0.152) between the variables suggests that there is no effective control of the prevalence of sexual harassment among the legal professionals in the workplace or court. Therefore, the null hypothesis suggesting that there is no effective policy that sanctions employers/employees against sexual harassment in the workplace or court can be accepted (p>0.05). there is no relationship between awareness of the lawyers about the empowerment of the National Industrial Court of Nigeria and it ability to prevent the workplaces from sexual harassment.

5.1.6
The chi-square test χ2=281.512, p-value=0.000 (p<0.05) revealed that there is a significant association between the awareness of the lawyers about the empowerment of the National Industrial Court of Nigeria and its ability to prevent the workplaces from sexual harassment ( Table 6). Based on the evidence above (p<0.05), the null hypothesis stating that there is no relationship between awareness of the lawyers about the empowerment of the National Industrial Court of Nigeria and its ability to prevent the workplaces from sexual harassment can be rejected.  Table 7, adjusted R-square is 62.8% variance of the participants' feelings when sexually harassed in the workplace and its consequence majorly signifies (endurance/tolerance). Based on the 62.8% prolonged exposure to sexual harassment, there is likelihood that it would have impacted the victims' feelings and their reactions towards being indifferent or mask its true consequences. Also, since p<0.05 implies that applied regression model is statistically significant, the null hypothesis stating that the prolonged exposure to sexual harassment have neither led to the development of coping mechanism nor mask its true nature on the victim is rejected. Hypothesis 4: There is no relationship between the prevalence of sexual harassment in legal profession and the need for law prohibiting it.

5.1.8
The chi-square test χ2=43.132, p-value=0.010 (p<0.05) on (Table 8) revealed that there is a significant association between the prevalence and the need for law prohibiting sexual harassment in the workplace. Based on the evidence above (p<0.05), the null hypothesis stating that there is no relationship between the prevalence of sexual harassment in the Nigerian legal profession and the need for law prohibiting it can be rejected.  (Tengku and Maimunah, 2000) noted that 78% males and 85% females experienced one form of sexual harassment in the profession. Likewise, (Laband and Lentz, 1998) reported that 26% of 604 male attorneys and 66% of 140 female attorneys, working in law firms experienced one form of sexual harassment from their colleagues, supervisors, and clients. In some American surveys observed by (Rhode, 2001), around half to two-thirds of female lawyers, and a quarter to half of female court personnel reported to have experienced sexual harassment and approximately three-quarters of female lawyers saw it as a challenge in the profession. (Lazar, 2016) noted that sexual harassment is a discriminatory and unprofessional practice among the American advocates.
Meanwhile, these sexually harassing behaviours are gradually reducing due to the help of trainings, policy enforcement and the adoption of (resolution 302-which is provided to support the 1992 anti-harassment policy of the American Bar Association, to combat retaliation after reporting sexual harassment, as well as to create zero tolerance of sexual harassment in the American legal profession), when compared to the 90s studies.
Most Indian female lawyers also experienced sexual harassment at some point in the profession (Mishra, 2015). Sexual and experiences of gender discrimination permeate the Canadian legal profession (Kay, 2002). Brockman revealed that one-third females of 600 and 10% males of 1,798 British Columbia lawyers admitted to have encountered unwanted sexual advances from other lawyers (Brockman, 1992b). In another study conducted by Brockman, it was reported that within a space of two (2) years, 34% women and 10% men in law practice observed their female colleague being subjected to unwanted sexual advances in their workplace (Brockman, 1992a). In fact, sexual harassment was perceived majorly as a form of discrimination against women in the profession (Laband and Lentz, 1998). English female lawyers revealed that sexual harassment is fact of life at United Kingdom law firms; of 1000 lawyers surveyed, 42% experienced sexual harassment at work, from suggestive comments to propositioning and unwanted physical contact (Financial Times, 2018). Nicolson reported that some writers argued that sexual harassment rife in English law practice. In another study of Brockman reviewed by (Unikowsky, 2001) it was settled that sexual harassment is a perpetual act that demoralises the professional relations in law practice, and what is expected of this noble profession is zero tolerance for sexual harassment.
Regarding the perception of sexual harassment and gender, we found that there is a significant difference in the perception of sexual harassment by gender. The data suggest that female participants perceived sexual harassment more than the male participants. This finding is in contrast with that of Bello who found that 58.38% male and 53.51% female Nigerian bank employees view gender harassment, sexual coercion and sexual harassment in a similar manner (Bello, 2016). In consistent with this finding, (Ekore, 2012) revealed the difference in gender perception in his study that 39.6% female respondents perceived sexual harassment more than the 38.1% male respondents. Likewise, some other researchers found that gender differs in experience, awareness, and definition of sexual harassment but, highly predominant on the female (Banerjee and Sharma, 2011;Rotundo et al., 2001). This could be due to the inequality in gender employment and believe that women are sex objects undermining their level of intelligence and knowledge. It could also be due to unequal number of gender participants selected for the survey, a need for further research.
From the study, Nigerian legal practitioners have a high level of knowledge about sexual harassment. This finding is similar with other previous studies which found that their participants have a high knowledge of factors that constitutes sexual harassment (Apaak and Sarpong, 2015). In contrast with our finding, some studies stated average knowledge of sexual harassment among their respondents (Gabriel and Panahon, 2017;Aditi et al., 2016) while some participants displayed a low knowledge of sexual harassment (Das and Rath, 2015). Nevertheless, with the high level of knowledge of sexual harassment exhibited among the Nigerian legal professionals, the subjects were neither secured nor prevented from being sexually harassed.
The first hypothesis demonstrated that there is no effective policy that sanctions employer/employee of sexual harassment in the workplace or court. This suggests the likely reason the participants' experience one form of sexual harassment to the other and the limited reported cases (about '9' sexual harassment cases have been decided in Nigeria since the NICN's constitutional empowerment). 1 This probably indicates that the lack of report by the victims is not due to protection of reputation or importance of personal relations and culture, but absence of organisational structure with zero-tolerance for sexual harassment and punitive measures. Past research argues that organisational tolerance of sexual harassment determines response to such issue and the victim's perception or approach (Willness et al., 2007;Wasti and Cortina, 2002;Hulin et al., 1995).
This aligns with the open-comment of one of the participants; 'My experience took place years ago, when I was still very young and single. I really had nobody to report to, but a senior colleague and my pastor. Eventually, I was 'sacked' by my then boss. If there is a proper framework in place, no young lawyer should have to experience what I went through, which included near rape. Those responsible for strategizing against sexual harassment in the legal profession should see it as a serious calling'. Hence, a preventive and reactive measures, ensuring safe and healthy work environment with emphasis on official code of conduct, ethical behaviours, operative complaint channels, monitoring occurrences of sexual harassment, and punishment of policy violators will not only encourage victims to report issue of sexual harassment, but serve as an effective policy that sanctions sexual harassment in the workplace Ramsaroop and Brijball, 2007). This finding is in contrast to previous studies which found that the reason for not reporting was due to fear of double victimization, importance of reputation, and personal relations, lack of courage, fear of disgrace, retaliation etcetera (Thomas, 2015;Buchanan et al., 2014).
On the second hypothesis, there is a legal platform where victims of sexual harassment violation can seek redress in Nigeria, but our data suggest that it is an inadequate social structure and cannot ensure effective enforcement. To buttress this finding, since the empowerment provisions of section 254C-(1) (f), (g), (h) and section 254C-(2) of the 1999 Constitution of the Federal Republic of Nigeria, Third Alteration Act, 2010 which conferred jurisdiction upon NICN to adjudicate on sexual harassment matters, and use ratified international treaties to that effect respectively , very few participants are aware of this jurisdictional power. So how can the public seek redress when majority of the lawyers are not aware of this fact? The probable reasons for this is; the basis of such power which is on mere guidelines from international treaties: CEDAW and ILO conventions, without local legislation nor precise punishment for violators, discretional-based decisions, no clear legislations, no organisational structure that tolerates zero harassment, employers are not mandated to provide internal policy, no complaint platform other than the NICN, no trainings, workshops, seminars etcetera, yet the Government believed to have created an avenue to bring cases of sexual harassment before the law.
In line with this finding, the Ministry of Human Resources of Malaysia provided the organisations with code of practice regarding the prohibition, prevention and redressal of sexual harassment in the workplace but, majority are still not aware because it lacks legal backing and cannot serve as law (Spencer and Barnett, 2011). Likewise, Chaudhuri found that 50 of 77 victims of his survey are not aware of the Complaints Committee for Redressal of sexual harassment grievances after the 1997 Vishaka's guidelines of the Supreme Court of India, which was based on mere international treaties and could not reprimand the perpetrators (Chaudhuri, 2007). This result was reiterated by Yadav, although the participants were medical professionals as compared with this study that deals with legal practitioners (Yadav, 2007). In spite of the provisions of the Vishaka's guidelines, educational officials who were supposed to be the guidance of the pupil were neither aware nor include the issue of sexual harassment in their school cirruculum (Leach and Sitaram, 2007). This signifies that awareness was lacking and could contribute to the prevalence of sexual harassment among professionals.
With respect to the effect of prolonged sexual harassment on the participants, the data suggest that the major coping mechanism adopted was endurance/tolerance to mask the true effect of sexual harassment. This indicates that the longer the duration of harassment, the decrease in feelings of the victims, consequently encouraging the perpetrators (Page and Pina, 2015). Some see the option as the only way for career building or a part of life (Akhtar, 2013), and some English lawyers left such issue unchallenged due to the importance of personal relations, reputation and other common factors (Sommerlad, 2016;Nicolson, 2005). This indicates that the legal professionals suffer in silence like other professions. Meanwhile, the fact that they submit to or tolerate this sexual demand does not certainly mean that it is satisfactory. Behaviour may be tolerated and yet unwelcome at the same time (Fitzgerald, 2004). The likelihood for submitting to such conduct may be closely related to the power differential between the parties and the implied understanding that lack of co-operation could result in some form of disadvantage.
In line with this finding, 69.7% of 447 private sector and 52.0% of 300 university samples surveyed reported 'just put up with it' as the coping strategy adopted for management of sexual harassment (Schneider et al., 1997). Corroboratory, it was reported that sexual harassment is a norm for majority of New-Zealand female lawyers to put up with in other to rise to the top in the profession (Tapaleao, 2018). Likewise, the survey conducted among selected Nigerian bank workers revealed the tolerance of distress as a ground for coping, which might further lead to workplace deviances and high attrition rate (Amazue et al., 2014). In disparity with our finding, the main coping strategies adopted by their respondents were to report to the authority (Arulogun et al., 2013). This research finding is also consistent with some previous studies which found that the culture of silence rather than speaking out is the major means of managing sexual violence within the Nigerian community (Awosusi and Ogundana, 2015;Fapohunda, 2014).
On the fourth hypothesis, our result supported the postulation that the prevalence of sexual harassment in the profession has a relationship with the need for law. Majority of participants agreed to the need for law prohibiting sexual harassment in the profession. In support of this assertion, most of the participants further agreed that the long-term solution to sexual harassment in the legal profession should include; mandatory provision of internal official policy, amendment of the legal practitioners' Act/Rules to classify sexual harassment as a punishable professional misconduct and setting up a body with confidential procedure to address issues of sexual harassment in the profession.

Conclusion
The current research provides the first empirical evidence-based survey on sexual harassment in the Nigerian legal sector. It highlighted the prevalence of sexual harassment among the advocates and solicitors of the Supreme Court of Nigeria. This study found sexual harassment to be a major challenge in the Nigerian workplaces which should not be left unaddressed. If not nationally addressed by the country, it is suggested that it should be urgently addressed professionally; by classifying such deviant act as a professional misconduct that is punishable under the G. N. No 69, Legal Practitioners Act, Chapter 207, LFN. Rules of Professional Conduct, 2007. These Rules should expressly prohibit lawyers from sexually harassing their colleagues just like the United Kingdom 1 , Canada 2 , and US 3 that prohibits and provides tackling guides on sexual harassment for all chambers to further protect and better help the lawyers defend themselves as well as others. Although, behavioural patterns or social misconduct of some lawyers might be difficult to tame, because of their manipulative act and ability to maximise the loop holes in Rules. However, categorization of sexual harassment as a professional misconduct with provision of punitive measures will be a good start and further create fear of being disbarred from the profession in the lawyers. Individually and collectively, we can eradicate sexual harassment from this profession, victims should learn to build their evidence, speak to friend or colleague or report to higher authority and others. Also listening, being patient and not blaming victims of sexual harassment will help support their confidence in speaking out. With emphasis, enacting a national law or prohibiting sexual harassment might not totally eradicate sexual harassment from the profession, but it will undoubtedly put a check and provide means of seeking redress for victims. In addition, the recent provision of secretariat for lodging gender-biased offenses in Abuja (Edokwe, 2018), Federal Capital Territory, Nigeria is applaudable, but when the lawyers lack basic internal protection how can they help the society? Hence, lawyers should be secured, equipped and trained on sexual harassment.
Finally, Nigeria as a party to CEDAW and ILO, has subjected itself to passing legislation and providing adequate policies which practically prohibit sexual harassment in the workplace. So, the mere empowerment of the NICN to adjudicate on issues of sexual harassment is inadequate and cannot fill the lacuna of local legislations with the prevalence of sexual harassment in the Nigerian work-setting. We therefore say, it does appear that there is not only a need for legal protection of the Nigerian legal professionals from sexual harassment in the profession, but there is also an urgent need for a comprehensive local legislation with clarity and explicit procedures for prevention, management, and protection of employees in employment, educational institutions and training workshops against sexual harassment in Nigeria.

Limitation of study
The strength of this study is that it fills the gap of no empirical survey in the Nigerian legal sector vis-a-vis sexual harassment. Drawing sample from an urban part of the country makes the generalisability high, as the fraction drawn, are saddled with the responsibility of defending the masses. Lawyers practicing in other urban parts were not included in the sample frame which is a limitation; a gap is recommended for further research. Due to the sensitivity of the topic, the questionnaires structured anonymity of respondents, the mixed-methods used in data collection might have hindered the paper-and-pencil participants from disclosing the accurate picture since they were approached one-on-one. Further research could be done by using a more effective method. Also, the participants were not asked the position of the main perpetrators of the sexual harassment they experienced-a colleague, head of chambers, principal partner or client, though some specified that in the open comment section.
Another possible limitation of this study could be the use of all genders for the survey, although numerous researches (Lazar, 2016;Toohey, 2012;Kay and Gorman, 2008;Rhode, 2001) settle that female lawyers are more likely to be sexually harassed than their male counterparts. Therefore, a further research is recommended to be conducted on a particular gender especially the females. This research did not address the issue of the rank of lawyers more prone to sexual harassment nor at what year of post-call vis-à-vis duration of being subject to sexual harassment in the workplace. Although we recognized that age or level of education and legal experience does not prevent a person from being sexually harassed (Reena and Saheab, 2014), and harassment mostly occurs at the early stages of employment (Toohey, 2012), hence we recommend a further research and also on the positive impact of sexual harassment as this study focused more on the negative impact of sexual harassment in the profession.

Recommendations
 The President of the Nigerian Bar Association should address/communicate to all chambers urging a zero-tolerance approach to sexual harassment within the profession.  Mandatory provision of comprehensive internal official policy for all workplaces and national domestication of all the International treaties ratified by the Federal Government of Nigeria regarding sexual harassment in the workplace.  Amendment of the legal practitioners' Act/Rules to accommodate a section to prohibit and address sexual harassment in the legal profession.  A body with confidential procedure should be set-up by all organisations to address issue of sexual harassment when reported in the organisation and they should be subject to check by external higher authority.  If the harasser is the main employer, or principal employer, there should be an external complaint committee or body to entertain issue of such rather than saddling the NICN with the sole responsibility of adjudicating on sexual harassment matters.  The employers should be burdened with the responsibility of ensuring a workplace free from all forms of harassments with emphases on self-control and modest dress sense, by organising trainings, workshops, seminars and different awareness measures to sensitize employees in other to create a zerotolerance organisational structure.  Nigerian Bar Association, Legal Disciplinary Committee, in collaboration with the NICN should make it a priority to rid the profession of sexual harassment by organising diverse professional development programs to sensitize/encourage the victims to report or speak out and bringing to book those who indulge in such act.

Conflict of Interest
Authors declare that there is no conflict of interest regarding this research.

Compliance with Ethical Standards
All procedures followed in this survey involving human participants were in accordance with the ethical standards of Research Training Development Centre, Sharda University, Greater-Noida, Uttar-Pradesh, and also in conformity with the 1964 Helsinki declaration (as amended).

Acknowledgement
We extend our heartfelt appreciations to the following solicitors and advocates of the Supreme Court of Nigeria (Sawyerr E., Omole, S., Agboneni, O. and Okene, H.) for their support in data collection, and we appreciate Oloketuyi, S. for her constructive comments on earlier drafts.