weeks ago, the Big Brother Nigeria reality TV show ended, and one youth (who
may or may not be lazy, depending on how you look at it) has emerged N25
million naira richer. Also newsworthy, but maybe not as much as the Big Brother
finale: the 113 plus Chibok girls still in captivity along with Leah Sharibu;
the Benue people still being killed; Lai Mohammed still being Lai Mohammed;
Senator Dino Melaye doing Jackie Chan-like stunts; thugs casually visiting the
National Assembly; and oh yes, Buhari still remains our president.

all those take second place to Big Brother; such is the power of mindless
reality TV shows. Personally, I have never understood what the fascination is
with the Big Brother show, and I never will.

you might be wondering what the correlation is between the topic above and Big
Brother? Well to those who were regular viewers of the show and are lawyers,
such might be obvious; but to others like myself who couldn’t be bothered about
it, but were forced to receive updates and information on it thanks to social
media and the show’s numerous fans, that link might not be so obvious. The link
between the two is none other its ex housemate, Cynthia Nwadiora aka Cee-C. Still
not clear? A little background then.

Nwadiora aka Cee-C is, presumably, a lawyer. That is all the background you

article aims to look at the propriety or otherwise of conduct of persons who
are presumably practising lawyers, in relation to the relevant sections of the
Legal Practitioners Act . Our case study on this discourse will be Cee-C.


will be working on a set of presumptions. This is solely because of the fact
that I don’t personally know Cee-C, and thus I cannot factually speak about
anything concerning her; inference and presumptions will only be made here.

chief presumption and the foundation of this discourse is that the now ex
Big-Brother housemate is a lawyer. I say presumption because I don’t know for a
fact that she is one, but all the information from social media and news outlet
claim that she is learned. Till it is rebutted, Cynthia Nwadiora aka Cee-C is a

next step now is the question: when was she called to the Nigerian Bar?

year of call will help in achieving the goal of this article: an earlier year
of call will bring about a different analysis from a later one. So, for the
sake of this article, we will presume, again, that she was called sometime
before she entered for the Big Brother reality show. Let’s say some 4 years
before; so, 2014 would be  her year of
call, hypothetically.

is the crucial question: what was Cee-C doing in the ‘4 years’ since she was called
to the Nigerian Bar? Was she a practising lawyer, or was she engaged in some
other  profession? Again, we must presume
here. Let us go with the former supposition, i.e., that she was a practising
lawyer. Let us also presume that she was practising up to the moment before she
got into the Big Brother house.
that we have all our ‘facts’ in place, let us take stock:

Cee-C is a lawyer

Cee-C was called to the Bar in 2014

Cee-C was a practising lawyer before getting in the Big Brother House
let’s look at the law in relation to this topic.

The Law

relevant law to this discourse is the Legal Practitioners (LPA) (Amendment) Act
1994, with specificity to its section 12 (2).

12 (2) states that:

a person whose name is on the roll is judged by the Disciplinary Committee to
be guilty of misconduct not amounting
to infamous conduct, which in the opinion of the Disciplinary Committee is
incompatible with the status of a legal practitioner,
the Disciplinary
Committee may, if it thinks fit give such direction as is authorised by
paragraph (c) (II) or (III) of subsection (1) of this section…”

have highlighted the relevant portion of that section to our discussion.

my unlearned friends, the above section is simply saying that where the
disciplinary body of our profession finds any lawyer to be guilty of conduct
which they judge to be unbecoming of a legal practitioner, such a lawyer will
be punished either by being suspended from practising law for a period of time,
or by being admonished by the body [section 12 (1)]. Pretty straightforward
right? Alas, like with all things law, it isn’t so, and there are

understand these complications, one must first of all understand the true
meaning of the section. And to do this, reference must be made to subsection
(1) (a) of the same section 12. Section 12 (1) (a) states:

“Where a person who is a member of the legal
profession is judged by the Disciplinary Committee to be guilty of infamous
conduct in any professional respect…”

phrase “… infamous conduct in any professional respect” simply
means conduct rendered in a professional capacity, which is at variance with
the rules and norms of the profession; it seeks to ensure that lawyers act
uprightly while rendering their professional services. In the case of NBA v
(2006) 14 NWLR (Pt. 1000) 841, the Disciplinary Committee defined the
phrase to mean “infamous conduct in any professional respect is an act or
omission which in the opinion of the Legal Practitioners Disciplinary Committee
is such that will bring the legal profession into disrespect.” In that
case, the lawyer in question failed to remit to his client money given to him
for the client. In another case, Chike v LPDC (2005) 15 NWLR (Pt. 1026)
1, the lawyer misappropriated money given to him for his client. Such was held
to be an infamous conduct in a professional respect. In several other cases,
the Committee ruled against lawyers who acted unscrupulously in their
professional dealings.

that we know that section 12 (1) (a) has to do with the lawyers’s conduct  in their professional capacity, we turn back
to section 12 (2). This section is the direct opposite of section 12 (1) (a).
This is so because its provisions make no reference to conduct in a
“professional respect,” rather the conduct which it seeks to prohibit
is that which “is incompatible with the status of a legal
practitioner.” What would then amount to such conduct? Unfortunately, the
Act does not specify; it leaves that question unanswered and open to one’s
discretion, and there lies the problem. Our case law is also rather lean in
this respect, as most of the disciplinary cases have bordered on conduct in a
professional respect (I found none which touched on conduct incompatible the
status of a legal practitioner.) Despite the dearth of materials on this issue,
I will refer to the textbook, Law In Practice in Nigeria (Professional
Ethics and Skills)
2nd Edition by A. Obi Okoye, for a better understanding
of such conduct as stated under section 12 (2). In pages 384 and 385  under the heading “Conduct not amounting
to infamous conduct, but which is incompatible with the status of a legal
practitioner,” the author lists out certain types of behaviour, that in
his opinion may be held to be conduct incompatible with the status of a legal
practitioner. He mentions: “the use of obscene language by a legal
practitioner in public, habitual drunkenness, fighting in public, seduction of
a client or his wife.”

now know the law and its problem; we can now proceed to the last part of this


our earlier presumptions on Cee-C (stated above) under the heading
“facts,” that she is lawyer and she was a practising one up until she
entered the Big Brother house? Good.

sure you can now see my destination with all this, but before we arrive there,
let us indulge ourselves in one more presumption. For the sake of this
discourse, let us presume that Cee-C’s conduct in the Big Brother house was terrible
and full of shocking behaviour. In any case, the updates and reports on social
media during the show showed that this was the case. Still, as I didn’t watch
the show, I cannot confirm that.

this last presumption and taking into consideration others mentioned, the
question then is: can section 12 (2) of the Legal Practitioners (Amendment) Act
1994 be invoked against Cynthia Nwadiora aka Cee-C?

her conduct in the house be sufficient 
grounds for the Disciplinary Committee to try her, and if found guilty
suspend her from practising law or admonish her? Can Cee -C’s conduct in the
house be held to be conduct which is ‘incompatible with the status of a legal

I don’t have the answers to those questions. So, I will leave them to you and
the LPDC to ponder on.

to say, it is obvious that section 12 (2) and other sections of the Legal
Practitioners Act need to be reviewed and amended. There is currently a bill before
the National Assembly seeking to replace the existing Act, but I don’t know if
it contains an amendment to that section.

To my
learned friend Cee-C: Not all of us were made to suffer adjournments and the
like… I applaud your hustling spirit. You know what you want, keep chasing
I remain a Minister in the Temple of Justice.

L. Attoh Esq. [2018] All rights reserved.