Opinion

The Oracle: Critiquing Judges and Judgments: The Dividing Line (Pt. 5)

Published

5 months ago

April 27, 2023

Eric

By Mike Ozekhome

INTRODUCTION

In the last outing, we discussed instances in which lawyers have been sanctioned in the United States for crossing the ethical line in criticism of judges. Today, we shall conclude it and, move on to the situation in the largest democracy in the world – India – with emphasis on contempt of court (what it is and what it is not, in that jurisdiction), concluding with fair criticism as a shield or subterfuge to attack the judiciary. Kindly, read on.

CASES IN WHICH LAWYERS HAVE BEEN SANCTIONED (continues)

In re Bank, 20-90010-am (2nd Cir., May 3, 2021), the court publicly reprimanded an Attorney whose conduct included responding to an appellate Judge’s questions during oral argument, by stating, “Are you serious, Judge?” He had also sarcastically commented, “I see that you read the briefs thoroughly”. The court rejected as unsupported and irrelevant, the lawyer’s defence that his contumacious comments were triggered by the Judges’ poor treatment of him.More serious and more likely to end in discipline are situations where lawyers directly accuse Judges of corruption, or politically motivated behavior. See, e.g., Matter of Dinhofer, 257 A.D.2d 326, 328 (N.Y. 1st Dept 1999) (three-month suspension was slammed on a lawyer for calling a Federal Judge “corrupt” during a telephone conference).

POSITION IN INDIA

Moving on to India, Vanya Verma writes that “while the Constitution of india recognizes the right to freedom of speech and expression in Article 19(1)(a), Article 19(2) states that laws can put reasonable restrictions on this right for a variety of reasons, including “in relation to contempt of court”. He then references another scholar (Sathe, 2001), as outlining “the historical inter-relationship between contempt of court and free expression” as follows:”since the early 1970s when the Supreme court found Keralas’ then Chief Minister, E.M.S. Namboodiripad, guilty of contempt of court for his critical comments on the judiciary as an institution, acrimony has existed between the Judiciary’s power to punish for contempt of court and citizen’s fundamental rights, freedom of speech and expression, the court has subjugated the most crucial of the fundamental rights- freedom of speech- to the Judiciary’s power to penalize for contempt of court. The freedom of speech had been trivialized by a broad contour of contempt of court. As a result, he advised, “Freedom of expression is the most fundamental of the fundamental rights, and constraints on it must be kept to a minimum”. Only the restrictions necessary to maintain the legitimacy of judicial institutions can be imposed under the legislation of contempt of court. The Judges are not required to be protected by the law. Only the Judiciary must be protected. A contempt notice issued without due diligence could put those in positions of public trust in jeopardy. The rule must be freedom, and the exception must be a constraint”

Under Article 19(1)(a) of the Indian Constitution, every person (including municipal councilors) has the right to free speech and expression, which includes reasonable criticism of the law or any executive action. In India, freedom of speech and expression is guaranteed both in the legislature and in local bodies. This is why a lawmaker or a municipal councilor can legitimately voice out his opinions on what he considers to be in the public good. A reasonable exercise of one’s right to free speech and expression, which includes fair criticism, is not to be suppressed for any reason.

Indeed, Section 5 of the Contempt of Courts Act, 1971, provides that a person is not punishable for contempt of court if he or she publishes a reasonable comment on the merits of a matter that has been heard and determined; or if a person publishes a fair comment on the merits of a matter that has already been heard and determined.

WHAT IS CONTEMPT OF COURT

Contempt is the power of the Court to safeguard its majesty and respect, as stated by Smita Chakraburtty (2017). This power is inherent, and it is recognised in the High Court’s and Supreme Court’s Constitutions. The Contempt of Courts Act of 1971 regulates but does not limit this power.Both civil and criminal contempt is defined under the 1971 Contempt of Courts Act. Civil contempt refers to willful disobedience to any court judgement, whereas criminal contempt can be invoked if an act tends to scandalise or lower the authority of the court or tends to interfere with or obstruct the administration of justice.The effect on the judicial process and the authority of the courts are used to determine whether conduct is contemptuous. According to S P Sathe (1970), the intent of the accused in a contempt action is irrelevant. What matters is the impact of his act or the likelihood of it having an impact on the administration of justice. Any conduct that undermines the administration of justice, or otherwise interferes with or tends to corrupt it, must be avoided.

P Chandrasekhar (2002) went on to say that actual scandalization or lowering of the court’s authority is not required. It suffices if it has the potential to cause controversy or undermine the court’s authority.The Supreme Court of India has insisted that reasonable criticism of decisions is always permitted and that defaming a Judge is distinct from contempt of court. That was so held held in the case of Brahma Prakash Sharma v State of Uttar Pradesh LAWS(SC)-1953-5-18Under to Section 5 of the Act, “fair criticism” or “fair comment” on the merits of a final decision does not constitute contempt. The judgement of what is “fair” is, however, left to the Judges’ decision.Before 2006, even the truth could not be used as a defence in a contempt case. According to Rahul Donde (2007), “truth has been included as a defence with the enactment of the Amendment Act of 2006, but with the restriction that it can be used as a defence only if it is in the “public interest.” The Judge has complete discretion over what constitutes public interest. The truth cannot be used as a defence unless the supposedly contemptuous behaviour was both genuine and in the public interest.

CRITICISM OF A COURT: WHEN IT DOES NOT AMOUNT TO CONTEMPT

Vanya Verna opines that it is the duty and obligation of lawyers to criticise the courts. He sees this as one of their most essential societal responsibilities. He insists that informed criticism of the courts and their rulings, is not only a right, but also an ethical obligation put on every member of the Bar.He lists two methods to criticise the Supreme Court in general. They are as follows:

Firstly, critic can present some fundamental principles and argue that the pattern of decisions or a particular decision is inconsistent with these principles. For example, he might argue that constitutional decisions should be based entirely on the document’s terms and the framers’ intent; that the Court should make decisions based on prevalent opinions about core values, or that antitrust rules should be read to promote allocative efficiency. Decisions that are contradictory to these initial principles may be labelled as incorrect or misguided by the critic. The critics who use this strategy base their arguments on documents, proceedings, and norms that are not related to the court.
Secondly, a critic can critique the court’s performance as an institution. This is the subject of the second type of criticism.He argues that the critic can argue that the court is too frequently divided; that it fails to sufficiently explain its rulings; or that it makes decisions that contradict one another. In other words, he could claim that the court is divided or that precedent is ignored. The duty on the part of lawyers is to identify and discuss incorrect actions by the courts, subject only to the condition that the criticism is motivated by a good-faith desire to improve the law and the legal system. Malicious or false statements about a Judge, or disruptive or contemptuous conduct in the courtroom, of course, cannot be tolerated.

FAIR CRITICISM AS A SHIELD TO CRITICIZE THE JUDICIARY

Fair criticism of the position stated in a judicial pronouncement, or even other types of judicial activity, is consistent with the public interest and public welfare that Judges are sworn to serve and uphold in such circumstances. As a result, awareness among Judges that they can or have erred in their judgements would provide much-needed fuel to the judicial system. Verna believes that another perspective, a new dimension, or insight must always be welcomed; and that a realization that would enhance the majesty of the rule of law will only be possible if the doors of self-assessment, in the light of the opinions of others, are kept open by Judges.

This is why in the case of Lalit Kalita and others v. Unknown, decided on 4th march 2008, it was held that the Judiciary is not overly sensitive to criticism. Indeed genuine criticism may be welcomed because it allows for self-reflection. After all, Judges are not infallible because they are people, and they frequently make mistakes unintentionally and as a result of their preconceptions. Thus, to Krishna Iyer, J. in Baradakanta Mishra v. Registrar of Orissa High Court, (1973) “if judges decay, the contempt authority would not save them”.

In the case of Rama Dayal Markarha v. State of Madhya Pradesh, (1978), the court held that fair and reasonable criticism of a judgement that is a public document or a public act of a judge involved in the administration of justice is not considered contempt. It held that such reasonable and honest criticism should be encouraged because no one, including Judges, can claim infallibility. It held further that such criticism could reasonably claim that the judgement was erroneous; or that an error was made, both in terms of law and known facts.

However, alleging that the Judge had a predisposition to convict, or purposefully took a turn in the discussion of evidence, because he had already made up his mind to convict the accused; or has a wayward bent of mind; attributing motives; a lack of dispassionate and objective approach and analysis; and pre-judging of the issues. All these would bring the administration of justice into disrepute. A criticism must be measured by the criterion of whether it ridicules the administration of justice; or hinders it. For example, allegations of bias, predisposition, subtle prejudice, and prejudging the issues and that an investigation into the conduct of the judge will be conducted who delivered the judgment as he is to retire within a month; and a wild allegation that Judiciary has no guts, no honesty and is not powerful enough to punish wealthy people, all could bring the administration of justice into ridicule and disrepute. (To be continued).

THOUGHT FOR WEEK

“I much prefer the sharpest criticism of a single intelligent man to the thoughtless approval of the masses”. (Johannes Kepler).

Opinion

Voice of Emancipation: Yoruba National Day: Lessons from the Kiriji War

Published

6 days ago

September 23, 2023

Eric

By Kayode Emola

As we Yoruba descendants all over the world celebrate today the end of the Kiriji war that happened on this day in 1886, we remember those who sacrificed their lives for the freedom we all enjoy today. Many people in our generation may not appreciate the sacrifice our ancestors paid to give us the freedom, liberty, and peace we enjoy today. Many of them back then did not live to see the peace and freedom they fought for, nor did they know they were going to pay the ultimate price, however, that did not deter them from pursuing freedom with all that they had including their lives.

As we celebrate 137 years to the end of the Kiriji war today, I would like to dedicate this column to those who paid the ultimate price for the freedom we Yoruba have enjoyed so far. Although the war brought freedom to the entire Yorubaland and its people; especially those towns and villages that were under Oyo rule, the end of the war brought in a new master (the British overlords) over our affairs.

Shortly after the war ended, the British capitalised on our frailty and war fatigue to gradually colonise our land and take our inheritance by stealth. We did not suspect the actions of the new colonisers because we thought they had our best interest at heart. The rest they say is left to the history books and the journey to freedom continues.

Those who fought to see us free would be mad in their graves to see that the freedom they fought to gain from Oyo who is their neighbour was eventually lost to the British colonisers. They would be asking those of us around this day what we are doing to liberate Yorubaland from the corruption of Nigeria passed down by the British colonisers, since that was what led them to fight the Oyo rulers.

I do not believe that we have an excuse today not to stand up for Yorubaland and her over 50 million population who are being subjected to Nigeria’s misrule. The Yoruba people never signed any document anywhere with her eastern and northern neighbours on becoming one country, therefore we have no business being in Nigeria.

For some people who say that a Yoruba man is now the president of Nigeria, therefore we have the upper hand in directing its affairs. I will say being the president of Nigeria does not translate to development in Yoruba land. This is because Nigeria as a broken nation has gone beyond repair and cannot be mended. Not especially with the disoriented system of government that it currently practices.

Just like Slovenia and Croatia left Yugoslavia before they started reaping the benefits of nationhood. Yoruba, Igbo, Hausa, or any other nationality in Nigeria cannot enjoy the goodness of a nation unless the people come together to decide their future. It would be better if this were to happen sooner rather than later to avoid the impeding danger the country may face.

We all know that Nigeria is living on borrowed time and those still behaving like they have a country to call home are just living in fools’ paradise. The only solution for Nigeria is complete dissolution, and any outcome short of this is just applying a sticking plaster to a gushing wound.

As we celebrate the peace we enjoy in Yorubaland today, may I use this opportunity to appreciate those who have kept the flames of peace burning bright. I also want to thank those individuals who have organised this year’s celebration and those who have volunteered their time and resources to see that the event is celebrated in style.

I also thank many of our diasporan Yoruba who are visiting Yorubaland, especially for the first time from places like South and Latin American countries, and elsewhere around the world. We appreciate your efforts in coming down to the homeland to celebrate this year’s event. May the peace of God be with us all and deliver the total freedom and liberty we all desire and grant to us our independent Yoruba nation sooner rather than later.

Opinion

Soliloquy: Between Big Brother Naija and Tastee Spelling Bee Competition

Published

6 days ago

September 23, 2023

Eric

By Michael Effiong

This past Thursday, I was privileged and honoured to attend the Tastee Spelling Bee Competition organized to commemorate the 10th Remembrance anniversary of Mr Oluwabunmi Adedayo, who we used to fondly called gentle giant.

Oluwabunmi who was the Executive Director of the famous quick service restaurant, Tastee Fired Chicken (TFC) made quite an impact while on earth. He was warm and humble, and always willing to help others, little wonder that his dear parents: Pamela and Kunle Adedayo decided to turn their personal tragedy to a force for good by establishing the Bunmi Adedayo Foundation.

As I sat down to watch the primary school pupils wow us with their knowledge of English pronunciation and spelling, my mind wondered to my days as member of the St Joseph’s Boys High School, Surulere Literary and Debating Society, and a smile spread across my face.

Then my mind again meandered to the video of the quiz competition that occurred at the Big Brother Naija House which has since gone viral, my reaction this time was that of disgust.

In case you missed it, in the said video, the contestants were asked a pot pourri of questions ranging from mathematics to current affairs. What really caught many people’s attention was the scandalous answers that emanated from theses “celebrity” contestants.

One was asked who was Nigeria’s first president, the contestant did not know! How embarrassing was that.

Another was asked what was the meaning of CAC. She went : ” CAC (she pronounced it kak), CAC”, she looked so shocked as if she had been asked to climb Mount Everest and then blurted some gibberish as answer. All they wanted her to say was CAC is the acronym of Corporate Affairs Commission. How difficult can that be?

It was, therefore, a huge paradox and heart-warming to see these pupils, including a contestant from Pacelli School for the Blind, show their proficiency in the English language.

They lapped up their questions with effortless ease, in fact, some of them were spelling words that I, with my over 30 years’ experience in journalism, was encountering for the first time.I was really impressed.

When one juxtaposes the wondrous performance of these kids to the woeful performance of the Big Brother Naija Housemates, it is not hard to see why our country is where we are at the moment.

When I expressed my angst to an older friend on the Big Brother Housemates show of shame, he laughed and asked me what I had expected

He went on to explain to me that the criteria to be a housemate and win over 100 million naira, juicy prices and endorsement deals did not require any intellectual rigor.You are not expected to be intelligent or take any aptitude test. Just fill out a form, upload a video saying something about yourself and a photo!

Then, you must be articulate, interesting and willing to share your must private thoughts in an open forum to strangers and also be ready to cavort ceaselessly! That’s all!

He therefore affirmed that expecting any seriousness from the Big Brother Naija housemates was like Waiting for Godot.

I believe it is time for us to begin to change our mindset for the betterment of our country. What exactly is our priority as a nation? What are the things that interest us? What are the things that we spend our money on and what are the things that we spend our time on?

In contrast to the huge advertising and sponsorship that is poured on big brother naija, knowledge-based shows like the Spelling Bee, debate shows and quiz compettions never get any traction or attention by Nigerians. Winners hardly are appreciated with the kind of cool cash and media frenzy associated with big brother.

This kind of mentality has to change. If we are to turnaround the fortunes of our country, we have to change our attitude to knowledge and education in general.

It is time for corporate Nigeria to stop paying lip service to talent shows that are intellectually-focused, yes, not everyone has to be educated, but the large number of a country should rank up on that index especially even if to just showcase your talent, if Nigeria wants to take its rightful place at the top table of world prominence.

It is said that “Ideas rule the world” and that soft power is the new gold. How can we compete if we do not invest in our kids and youths like the Bunmi Adedayo Foundation.

Indeed, BAF has taken education as its focus. It has been in the forefront of training teachers and improving the learning experience of pupils.

According to the Foundation “It’s not about building schools, it’s also about building teaching and learning. That’s how communities flourish. They’re agent of change”

The Foundation is devoted to changing lives of children, by innovatively improving the quality of teaching and learning in Nigerian public primary schools.

The Foundation has so far organized 103 trainings, intervened in 1300 plus schools, built one state-of-the-art library, upgraded 5,200 plus teachers, donated one 40-seat ICT laboratory, worked in 56 plus Local Government Education Areas and impacted 15,000 plus pupils.

There is no doubt that we have to catch them young, feed them with the right ideals and ideas that will build them into worthy citizens.

On the day of the spelling Bee, which was won by my name sake, Michael Ofiemum, with Toluwani Toluwani and Janet Oseni taking second and third respectively, the Adedayo’s again showed that their milk of human kindness never runs dry when they extended full scholarship to six pupils of Navy Primary School.

Just like the Spelling Bee winners, contestants and their teachers went home with many prizes, gifts and loads of joy, the smile on the faces of the parents and relations of the scholarship recipients was indescribable.

There is no doubt that the impact of the Spelling Bee Competition and Scholarships by the Bunmi Adedayo Foundation will be etched on the hearts of these pupils and many years later, they will grow up to discuss how this rare opportunity shaped their lives and trust me, at that time, no one will be talking about who won Big Brother Naija 2023.

Let us all decide to invest wisely today by touching lives one child at a time!

Opinion

The Mastery of Strategic Alignment

Published

6 days ago

September 23, 2023

Eric

By Tolulope A. Adegoke

“You need a plan to reach your goals. It is your plans that take or get you to a place, not just your dreams. Dreams without an active plan will take you to nowhere. It is a plan that empowers and exposes you to the discipline and responsibilities required to achieve your dreams or set goals. A plan teaches you “HOW” to get there, it is your blueprint. This is your time to set in place some plans that lead you to an ‘expected end’. By the time you get to the ‘end’, you shouldn’t be surprised, because success is intentional; it is deliberate. It is plans that takes you to success, and it is planning that helps you succeed for greatness. Therefore, set it up and step it up!”

– Tolulope A. Adegoke, PhD., FIMC, CMC, CMS, MNIM, CIV

There should be synergy between your actions and ambitions. You should be able to look at your actions and tell your ambitions. From your ambitions, I will be able to tell where you are going by what you are doing. If what you are doing doesn’t tell or prophesy where you are going, then you are doing the wrong things. Since you are a limited resource, then you are not enough to go round; that means, you have to choose where you have to expend your energy. You cannot tackle everything at the same time. What you are doing must reveal or prophesy where you are going.

A plan is important, not just a dream. A lot of institutions teaches about dreams and vision, but they tend to dish the real deal in parts or halves. You need to understand that getting your plan lined up (to align) with where you are going is far more important. You need a plan to reach your goals. It is your plans that take or get you to a place, not just your dreams. Dreams without an active plan will take you to nowhere. It is a plan that empowers and exposes you to the discipline and responsibilities required to achieve your dreams or set goals. A plan teaches you “HOW” to get there, it is your blueprint.

This is your time to set in place some plans that would lead you to an ‘expected end’. By the time you get to the ‘end’, you shouldn’t be surprised, because success is intentional; it is deliberate. It is a plan that takes you to success, and it is planning that helps you succeed.

The Book of Life says: “write the vision, make it plain, so that whosoever that reads it may run with it.” Somewhere in your life, there ought to be a perfectly Mission Statement: your Vision, Purpose and Goals. That’s what is done in business, and you are in a business to earn a living. What’s your vision? What’s your purpose? What are your goals? With the aforementioned, you are able to choose what is yours wisely. Such that when people offer you things that are not in your Mission Statement, you can say NO because that’s not what you do. A lot of things can be very good, but if they are not in alignment with where you are going, you just have to let them go because you are a limited resource, which is specifically wired for a purpose or calling.

The Book of Exodus 25:1-9 unveils so much: “And the Lord spoke unto Moses, saying, speak unto the children of Israel, that they may bring me an offering: of every man that giveth it willingly with his heart ye shall take my offering. And this is the offering which ye shall take of them; gold, and silver, and brass, and blue, and purple, and scarlet, and fine linen, and goats’ hair, and rams’ skins dyed, red and badgers’ skins, and shittim wood, Oil for the light, spices for the anointing oil, and for sweet incense, Onyx stones, and stones to be set in the ephod, and in the breastplate. And let them make me a sanctuary; that I may dwell among them. According to all that I shew thee, after the pattern of the tabernacle, and the patterns of all the instruments thereof, even so shall ye make it.”

Could God have designed a tabernacle? He is a Master-planner, but He invited His people into the process and planning, and gathering the raw materials. You can quickly tell or deduce by what they are gathering that they are getting ready to build something. Also, one of the most profound statements spoken by God to Moses in the above verses is “Build according to pattern”. In other words, you should have a pattern for living. What God meant by the above is that: “I want you to build according to what I have showed you, do not build outside my plan.”

What you need is that you should get your vision from the Lord; this is simply the vision of where you are going, and this is “WHY” I put you on Earth; this is the purpose I have for you to do. Your job or duty on Earth is to build on Earth what God has already shown you. So what has God shown you? whatever God has shown you is your purpose and vision. A plan simplifies the process of tasks for an easy accomplishment of set targets. Pattern helps you grow; it builds you and gives you a niche. You are here to build on Earth as Man according to purpose and pattern which has been revealed by God.

Most people have no pattern. This is where mentoring comes in to lead you to act according to a designed pattern or system. Mentoring is about giving somebody a pattern to operate with; it is about giving or revealing and availing to somebody what they can see: walk the way I walk, step the way I step. Ask yourself, genuinely, “do you have a pattern?” Do you have a pattern for a successful career, marriage, business or ministry? Have you ever been around someone who is succeeding? You cannot imitate what you have not seen! People who don’t just hear the word, but do the word prospers and keep going up, challenges notwithstanding, but they continue to succeed because they are obedient and attentive to a laid out pattern of success.

A plan is a clear strategy which is usually documented for the purpose of succeeding, leading, conquering and achieving set-targets or goals in any facet of human endeavours. If you must prosper, then you must not fail to plan!

You must understand that success is always intentional, though many people act as if it isn’t, but it really is. You do not graduate from College and be surprised how it happened; you don’t lose weight by accident; you don’t run a marathon and say you do not know how you did it! The authentic truth is that nobody succeeds by accident.

The next thing you must not fail to understand here is that, you need to forgive yourself for making mistakes. You may have done something so foolish. Success isn’t a magic pill, but an intentional act for a change to occur via the renewing of your mindset, it is a process, it is going to take a little time, but it will work if you work it.

Invest Extra Income

Any unexpected income that is beyond your budget is the kind of money you should invest. Stop engaging in lavish spending. Understand that you do not need to buy what you do not need at all! Other people are investing in the idea that you will spend; that’s why they built a mall; that was their investment, expecting you to spend your money in it so that they can save it. You open up streams of income by investing your extra income, and you don’t start spending like the prodigal son (a fool). Don’t spend beyond your limits again. Now, you have understood that there is need for added investment pockets. In the Book of Matthew 25:14-30, Jesus Christ taught the same concept about investment. Even if He didn’t teach it, you still need to know these concepts of investment because you need to do it for your own good!

One of the biggest errors or mistakes we make is that whenever we a get a lump-sum of money, the first thing we try to do is to pay off all our bills, and what you do not realize is that when you are trying to pay off all your bills, you have bills again. You need to maximize opportunities. Gradually continue to pay your way out of debts by using the measure called DISCIPLINE. Keep the money by saving it; Grow the money by investing the money!

The Book of Life says, “you should bring forth fruits, so that your fruits may abide.” God implies that: “I am interested in getting you to a place that you stop losing everything I am giving you. What you know now will change the next five years of your life.

How can you love somebody and not have a life insurance? So you leave them struggling, evicted and uncared for? It isn’t about the luxuries or the expensive gifts or items. I charge you to convert them into assets, and get an insurance! Set your priorities straight in-line with what makes sense!

Stop accepting what keeps depreciating, and stop ignoring what keeps appreciating. Stop paying for your emotions! Even if you love a thing or luxury or property, don’t buy it if it is beyond your financial means or budget. Quit the emotion, where motion is required for your legs to step back. Stop spending too much on what is not necessarily important for you. Buy the basic needs and invest the rest so that as you rest, the profit yields!

A plan makes you a planter (sower). The idea is the seed; the plan makes you the planter. Every planter (sower) is eligible for the harvest of whatever he or she sows or plants! Ensure that you update your plan on a regular basis, because things change, so that you can make this year your year of effective and sufficient productivity. You must have things in order. Every of your steps must count! Are you positioning yourself in the line of your dream? You need to get ready to do it before you do it! You need to look like it before you are it! Remember, God anointed David to be king while he was still a shepherd boy. God was gradually positioning David into Royalty. God told Samuel in the Book of 1Samuel 16:13 (paraphrased), “I have got a Man in the House of Jesse, find him, I want you to anoint him to be king.” At first, after David was anointed to be king, he was still a shepherd boy, but rumour heard it all across the territories in his time that David was going to be king. You need to realize and understand that God is much more interested and focused on “WHERE” you are going than where you are, at the moment; and He is committed to plan and ride with you, if you will be reasonable enough to take responsibilities and endure the processes required to arrive at the successes that leads to greatness through a PLAN or pattern (strategy) that is well detailed for shifts and positioning to prosper and prevail in your areas of calling or purpose.

…to be continued.

Dr. Tolulope A. Adegoke is an accredited ISO 20700 Effective Leadership Trainer