LEGAL FRAMEWORK ON PETROLEUM OPERATIONS IN NIGERIA



CHAPTER THREE
3.0       LEGAL FRAMEWORK ON PETROLEUM OPERATIONS IN NIGERIA
3.1     The Petroleum Act1
            It should be noted that Nigeria’s petroleum legislation evolved gradually through what can be classified as the colonial, post – colonial, and post oil boom phases. Prominent among the colonial legislations were the Mineral Oils Act2, the Mineral Oils Act3, the Mineral Oils Act (Amendment) Ordinance 1959, and the Petroleum Profits Tax Ordinance 1959. Not only did these laws cede Nigeria’s mineral rights to the British Crown; they also reserved exploration and production rights to only British companies which for the mere payment taken rental due and royalties, acquire proprietary rights over all mineral deposits in the country.

            Upon attaining independence in 1960 certain numbers of petroleum related laws were enacted within the first decade of independence. The most significant of these laws was the Petroleum Act promulgated as4.
            The Act repeated the existing legislations relating to petroleum. The Petroleum Act and the (Petroleum Drilling and Production Regulations) and other regulations made there under laid down the foundation of the legal framework for the regulation of the oil industry in Nigeria.


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            It has been suggested by some expert that the Act is deficient in many ways, but this was the nation’s first comprehensive petroleum legislation, which covered among other things the definition of petroleum, land surface rights and rents, and compensation and many other things.
            The Petroleum Act inter alia provides for the vesting of petroleum in the state. This is done by stating that “the entire ownership and control of all petroleum in under applies shall be vested in the state”5 This provision applies to all land (including land covered by water) which is in;
a.         Nigeria: or
b.         Under the territorial waters of Nigeria
c.         Forms part of the continental shelf; of
d.         Forms part of the exclusive economic zone of Nigeria.6
            The Act also provide the oil exploration licence, oil prospecting licence and the oil mining lease which are the three types of licenses and lease that could be obtained on oil operation in Nigeria7. The Act further states the provision for refining oil in Nigeria by stating that “no refinery shall be constructed or operated in Nigeria without license granted by the minister”.8
            The licenses granted under the section shall be in the prescribed form and shall be subject to the prescribed form and shall be subject to the prescribed terms and conditions or where no form is prescribed or no terms and conditions are prescribed such form or subject to such terms and conditions as may be decided or imposed by the minister.9 There shall be charged in respect of every license granted under this section such are additional to the provisions of the Hydrocarbon Oil Refineries Act.10
            The Act Provides for the control of petroleum products in Section 4.11 By Subsection (1) of the Act, no person shall import store, sell or distribute any petroleum products in Nigeria without a licence granted by the minister. If treats the modes of strategies sate or distribution of petroleum products that cannot be done without the license granted by the minister. But by subsection (2)13, the requirement for obtaining a licence shall not apply in respect of:
(a)       The storage, sale or distribution of not more than 5 liters of kerosene and such other categories of petroleum products as categories of petroleum products as may be exempted from the application of subsection (1) of the section by the Minister by order published in the Federal Gazette.
(b)       Storage of petroleum products undertaken otherwise than in connection with the importation, sale or distribution of petroleum products. Any license granted by the minister under the section shall be subject to the prescribed terms and condition where no form is prescribed or no terms or conditions are prescribed, in such form and on such terms and conditions as may be decided or imposed by the Minister14.
            There is a penalty for failure to comply with the provisions for the licence and any person that does any act which requires licence without Obtaining appropriate one shall be guilty of an offence and shall be liable on conviction to imprisonment for two years or a fine of N2000 or both and in addition, the petroleum products in respect of which the offence was committed shall be ferteited.15
            The Act similarly, creates offences in connection with the distribution of petroleum products which include inter alia the relationship between oil marketing companies in the sale and distribution of petroleum products e.t.c.16
In section 7 17 of the Act the right of pre-emption is provided for the minister that in the event of a state of emergency or war the Minister shall have the right of pre-emption of all petroleum and petroleum products obtained, marked or otherwise dealt with under any licence or lease granted under the Act.18 A penalty and punishment is prescribed for failure to conform to or obey a direction issued by the minister.
            Furthermore, the minister may advise the president to declare a state of national emergency if the minister is satisfied that as a result of the low level of availability of Petroleum and its product:
(a)       There is an actual breakdown of public order and public safety in the federation or any part therefore; or
There is a clear and present danger of actual breakdown of public order or public safety in the federation or any part thereof.19
            The Act states that the minister may make regulations prescribing anything to be done for the purpose of the Act. Consequently, even different regulations have been made at various times and for a variety of purposes. Some of the regulations were made under laws that have been repeated but these regulations have been retained having been deemed to have been made under the petroleum Act which succeeds the previous legislations.20
            The seven regulations existing under the Act up till date are:
1.         Mineral Oils (Safety) Regulations.
2.         Petroleum Regulations.
3.         Petroleum (Drilling and Production) Regulations.
4.         Petroleum Refinery Regulations.
5.         Crude Oil (Transportation and Shipment) Regulations.
6.         Deep Water Block Allocations to Companies (Back in rights) Regulations.
7.         Oil Prospecting Licence (conversion to Oil mining lease etc) regulations.
            The petroleum Act has four schedules each of the schedules contain provisions relating to oil exploration and prospecting licenses and the oil mining leases; the prerequisite for the grant of each of these license or lease; the conditions for assignment of same; termination and the revocation. It also contains provision for the fees, rents and royalty payable. The second schedule deals with the rights of preemption of the Minister; the third schedule is on the repeals made to certain precious statutes on minerals oil etc. the fourth schedules relates to transitional and savings provisions.
            The Act essentially reduced the duration of an oil mining lease from the previous 30-40 years to 20 years.
            However, the Act was still seen by many as a bonanza to foreign operators. But after entering into membership of OPEC in 1971 and having established joint venture participation, production sharing and risk service interest with the oil companies.21
            Between 1973 and 1974, the NNOC, which was later changed to the NNPC in 1977, negotiated participation in all the Major companies, thus acquiring large percentages in the operations of these companies.
            The cash of oil prices in the world in 1986, to below 10 dollars per barrel, rendered further exploration totally unprofitable to the foreign operators. The need, therefore, arose to offer them a new package of generous in this strategic sector of the economy. This package is the membranous of understanding which guarantees to the oil companies a notional margin of 2.3 to 2.50 U.S dollars per barrel and a royalty of 2 U.S dollars 8 per barrel. Oil companies operating under the various agreements include Shell, Exxon Mobil, Chevron, ELF, Nigeria Agip, Texaco Overseas, Express Petroleum/Conoco, Addax, Atlas, Amni International, consolidated oil, Pan-ocean, Nigeria Petroleum Development Company, and Dubri oil.
            Currently, the Nigeria’s oil and gas industry in priority regulated by the Petroleum Act and the Petroleum Profits Tax Act,21a(“PPTA”). In addition there are other laws that are directly relevant to the oil industry in Nigeria.
These includes the Petroleum Equalization Fund(Management Board etc)Act22 , the Petroleum Production and Distribution (Anti-sabotage)Act23 , Petroleum (Special) Trust Fund Act,24  Petroleum Technology Development Fund Act25 Petroleum Training Institute Act,26 other laws that have direct bearing on the petroleum industry the Oil Pipeline Act27, Associated Gas Re-injection Act,28 Oil in Terminal Dues Act29 , NNPC30 Act , and the Oil in Navigable Waters Act31 . All these laws regulate various aspect of the oil industry in Nigeria and have been made such as the Nigerian liquefied Natural Gas Act32, the Niger Delta Development Commission Act33, and lately the Nigerian local content Act for the oil industry.
3.2     Associated Gas Re-injection Act Cap A26 Laws of the Federation of Nigeria 2010 34.
This Act was promulgated in response to the criticism against gas fearing in Nigeria. Under section 3 (2) of the Act35, oil operators are required to submit detailed preliminary programmes and plans for the implementation of gas re-injection in the their various fields. Furthermore, the Minister is vested with the power to issue certificate to any oil company to continue to flare gas if such a company pays the sum prescribed by the Minister.
This Act was followed by the Associated gas Re- injection (continued Flaring of Gas) Regulation 1984, Law of the Federation 1990(now Law of the Federation 2010)36.
Under this regulation, the Minister may allow gas flaring:
a.         Where mare than 75 percent of the produced gas is effectively utilized
or conserved;
b.         Where the produced gas contains mare than 75 percent imparities              
            rendering it unsuitable purpose,
c.         Where an ongoing utilization programme is interrupted by equipment failure, provided that such failures are not considered too frequently by the Minister and that the period of any one interruption is not more than there months;
d.         Where the ratio of the volume of produced per day to the distance of the field from the nearest gas line or a possible point is less than 50,000scf/km.                                                                              Provided that it is not technically advisable to re- inject the gas in the field.
e.         Where the Minister, in appropriate cases as he may deemed fit, orders the production of oil from a field that does not satiety any of the conditions specified in this regulations.
One striking feature of the above Act and the accompanying       Regulation is the permission given to oil companies to continue to flare gas on the payment of minimal fees. Oil companies would rather pay the prescribed fee for gas re-injection of produced gas.
3.3     Oil Pipeline Act Cap 07 LFN 2010 37
            In the law of Energy and Natural Resources, the complementary sections in the petroleum industry are the mineral oil and natural gas. In these two gas areas, other wise called the upstream sector on the one hand, and the post production stages, such as refining, marketing and distribution, other wise known as the down stream sector on the other hand, have both legislative and regulatory frameworks.
            In relation to the gas industry, the down stream consists of the post –production stages of gas, until the various products derived from the natural gas passes to the consumer.38
            The Federal Government has exclusive legislative powers to make laws in relation to matters connected with or arising from natural gas39.
All the explanations given above are actually pointing out the
Oil Pipeline Act40 and its aims and obligations find itself within the downstream petroleum sector of Nigeria petroleum industry.
The Oil Pipeline Act,41 governs the transmission of natural gas. The minister charger with the responsibility for matters relating permits to survey routes for oil pipelines and may grant licenses on application to construct, maintain and operate oil pipeline for the transmission of gas42.
            Although the Act is Oil Pipeline Act, it encompasses both oil and gas, having regard to the definition of “Oil Pipeline” which the Act itself defines as, “A pipeline for the conveyance of mineral oil, natural gas and any of their derivative or components and also any substance (including steam and water) used or intended to be used in the production or refining or conveying of mineral oils, natural gas and any of their derivatives or components”.
            Such license may be granted for such period not exceeding twenty years as the minister may direct. Should there be any despite as to whether any compensation is payable, or the amount so payable or as to person or persons to whom such compensation should be paid, as a result of the land used by for exploration activities, the competent Magistrate exercising civil jurisdiction in the area where the land is situate or the state High court 45shall have jurisdiction to entertain the matter.
In the above case, where the dispute between the parties elated to payment of compensation for the land used by the Nigerian Agip Company for petroleum activities, it was held that the high court of Imo state rightly assumed jurisdiction to entertain the claim.             
      As a subsidiary legislation, to the Oil and Gas Pipeline Regulation was made pursuant to the Oil Pipeline Act. Regulation1provides that no oil pipeline licence shall be granted unless the route to the pipeline has been surveyed and no survey shall be obtained from the minister. Application for a license to construct a pipeline for the transmission of gas shall be made during the validity.
             Where a licensee desires to change the nature of the fluid transmitted by the pipeline either from liquid petroleum to gas or from sweet gas to corrosive gas, he shall make an application to the Department of Petroleum Resources in the Ministry of Petroleum.
    A licensee who desires to discontinue the operation of the pipeline system or its ancillary facilities shall apply to the same Department stating his intention to do so.
  3.4  Petroleum Production and Distribution (Anti-Sabotage) Act57
            The combined effect of the provisions of Section 4 (1) and (2b)58 is that no person shall impact, sell or distribute gas, being a petroleum product in Nigeria without a license granted by the minister of petroleum Resources. Such license is subject to the prescribed terms and conditions as may be decided or imposed by the Minister59 and person who so imports, sell or distributes gas without the appropriate license shall be guilty of an offence and shall be liable on conviction to imprisonment for two years or a fine of N2000.00 or both, and in addition the gas in respect of which the offence was committed shall be forfeited.60
            Similarly, any person who willfully does anything with intent to obstruct or prevent the procurement of such product for distribution61 or who willfully does anything in respect of any vehicle or any public highway with intent to obstruct or prevent the use of that vehicle or that public highway for the distribution of gas shall be guilty of the offence of sabotage62 and shall be liable on conviction to be sentenced to death or imprisonment for a term not exceeding 21 years63under the Petroleum Production and Distribution (Anti-sabotage) Act64.
            The Federal High Court has exclusive jurisdiction to try the offence of sabotage committed under the Petroleum Production and Distribution (Anti-Sabotage) Act65.
Under the Nigerian National Petroleum Corporation Act66 (NNPC) is charged with the duty of purchasing and marketing petroleum products. It is equally responsible for refining, treating and processing of petroleum products and also of providing and operating pipeline and other facilities for carriage or conveyance of natural gas and its products.67 The petroleum products pricing Regulatory Agency68 is equally responsible for the regulation of the supply and distribution of gas product.
3.5     Petroleum Profits Tax Act69
The principal Act governing the taxation of profits form petroleum operations in Nigeria is the Petroleum Profits Tax Act70.
The basic principle employed in ascertaining the tax on the profit of a given accounting trading or business commonly apply to all companies irrespective of whether such companies engage in petroleum operations or not. The principles allow for deduction from the income of the period before tax is assessed and revived on the profits gained from the income.71
Ordinarily, one would have expected that the Petroleum Profit Tax Act (PPTA) 72would cover both the downstream and upstream sectors of the petroleum Industry. However, it is now selected that the PPTA only applies to the taxation of the incomes of companies engaged in the exploration and production of crude oil and liquefied natural”  73Hence the PPTA covers enterprises in the upstream sector of the petroleum industry. This position is discernable form the Act itself. It provides:
An act to impose a tax upon profits form the winning of petroleum in Nigeria, to provide for the assessment and collection thereof and for purposes connected therewith74.

            It is humbly submitted that the phrase “wining of petroleum” is no more than obtaining petroleum and this cannot be beyond the stages of exploration, exploitation and production (i.e. upstream) it is equally provides in that Act that:
There shall be levied upon the profit of such accounting period of any company engaged in petroleum Operation during that period, a text to be charged, assessed and payable in accordance with the provisions of this Act.75

The phase “petroleum Operation” is defined in the PPTA as follows:
            “The wining or obtaining and transportation of petroleum or changeable oil in Nigeria by or on behalf of a company for its own account by any drilling, mining, extracting or other like operations or process not including refining at a refinery, in the course of a business carried on by the company engaged in such operations, and all operations incidental thereto and any sale of or any disproval of chargeable oil by or on behalf of the company (Emphasis added)”.76
            From the above definition of petroleum operations it is submitted that “drilling, mining, extracting or other like operations or process” limit the application of the PPTA to the upstream sector. Furthermore, the exclusion of “refining at a refinery” is an indication that the Act excludes post-production operations. Thus, the taxation of companies like Shell Petroleum Development Company Nigeria LTD Chevron Nigeria Limited, Mobile producing Nigeria Unlimited, Nigeria Agip Oil Company Ltd, Elf Petroleum Company and all other upstream companies comes under the Petroleum Profit Tax Act regime.
            It can therefore be rightly said that the principles employed in ascertaining the tax on the profits of a given accounting tat commonly apply to all companies generally will apply to the for payable on profits of the companies involved in downstream sector such as Unipetrol, Mobil Nigeria Plc. Etc hence, such companies having downstream interest in gas will have their profits taxed under the Companies Income Tax Act (CITA)77
3.6 Oil in Navigable Waters Act78
            This legislation Act is not that popular or active in Nigeria because it deals with discharge of oil on international navigable waters. Its relevance is that it controls pollution within fifty miles from land and outside territorial waters of Nigerian.
            However, it is presently the most comprehensive legislation governing criminal liability in oil population cases. The primary aim of this legislation is to reduce the incidence of pollution of the world’s high seas, generally and Nigerian territorial waters, in particular. The legislation popularly known as ‘ONWA’ was made in compliance with and to implement the terms of the convention for the prevention of pollution of seas by oil79 and to make provisions for such prevention in the navigable waters of Nigeria.
            In Umudje v. Shell BP Petroleum Dev. Co. (Nig) Ltd80 the defendants operational activities relating to oil prospecting caused damages to the plaintiff. The Supreme Court in following the rule in Ryland v. Fletcher81 held the defendants liable.
            It is an offence under the Act of any Nigerian ship to discharge oil or any mixture containing oil into prohibited sea area designated under the Act as follows.
(a)      All sea area within 50 nautical miles from land and outside the territorial water of Nigeria; and
(b)       The whole of the designated sea areas in so far as they extend to 50 nautical miles from the nearest land, i.e, foreign lands and countries.
            The Act also prohibits the discharge of oil into Nigeria territorial waters and its adjoining navigable inland waters by ocean going tankers and sea faring vessels82 specifically, section 1 of the Act83 is only interested in Nigerian vessels within and outside her territorial waters. Interestingly, section 3 84 relates both to foreign and Nigerian registered vessels.
            It is worthy to note that the Act defines “Nigerian waters, “to include”.
(a)       The whole of the sea within the limits of the territorial waters of Nigeria; and
(b)       All other waters including inland waters which are within those limits and are navigable by sea going ships.
            According, to section 1 and 2 85 of this Act, the owners or master of ship or vessel where the discharge emanated can be instituted by the attorney General of the federal or with his consent pursuant to section 12(1) of the Act.86
            The occupiers of the land from where the discharge flows can be sued. Similarly, the operator or manager of the facility what the pollution is being discharged can also be sued.
            Actions can be brought to Nigeria. Courts especially for offences of discharge into Nigeria waters. In Shell Petroleum Dev. Co. (Nig.) Ltd v. Otoko87 the rule in Ryland v. Fletcher, was applied to make the defendants liable for the escape of crude oil form their operational base which caused some damages to the plaintiff.
            However, for discharge of oil into prohibited sea areas, action can be instituted in Nigeria or any adjoin state, whose laws are similar to the ones under the Act especially state parties to the international convention for the prevention of pollution of the sea by oil 1954.89
            Throughout the Act, there are no specific provisions for defences to this offence. Therefore, there is an implied heavy burden on the persecution to adduce sufficient evidence to establish the accused person’s guilt beyond reasonable doubt.90
            It is, however, a good defence if some reasonable and convincing circumstances beyond the vessel operators control made compliance impossible within the period of non-compliance. For discharge of oil into prohibited sea area, it is good defense that the discharge was done for the following reasons:
(a)       To save life as was the case in the Esso Petroleum co. Ltd v. South Port Corporation;91
(b)       To prevent damage or destruction to any vessel or cargo;
(c)       To establish that the oil or its mixture escaped accidentally as a result of either damage to the vessel or leakage and that all urgent and reasonable steps were taken to prevent the discharge and reduce its impacts on the environment;
            Also, a defendant charged with offence under this section can also plead in addition to the above that:
(d)       He discharged “dangerous petroleum” into water specifically designed by the harbour authority for such discharge and in such approved manner and procedure;
(e)       The discharge was not caused by he contained (express or implied of the occupier or owners) but a third party on his polices;
(f)        The discharge was continued in an effluent produced by operations for the preferring of oil, but it was not reasonably practicable to dispose of such waste, save by discharging the effluent in prohibited water having everything possible to save oil from the lot.       
            The Attorney General of the Federation or his representative should only bring a charge against defaulters.92
            The master or Owner (or both) of the offending vessel is a possible defendant. It is submitted that a belting third parties may also be joined in the action.
            A person guilty of an offence under sections 1, 3 and 5 of the Act are guilty of offences of
1.         Discharge of oil in prohibited sea areas.
2.         Discharged of oil in Nigerian waters, and
3.         Failure to install oil pollution prevention equipment shall on conviction by a high court or a superior court of record or any court that has summary jurisdiction (A magistrate) be shall be liable to a fine. If the conviction is in a magistrate court or any court inferior to a high court, the fine should not exceed, N200.00
For offences, under section 7, the defaulter shall upon conviction for failure to:
a.         Keep records in case of Nigeria ships: or
b.         Foreign ships and Nigerian vessels as well, to keep detailed record of oil transfer to and from their destinations.
            Shall be liable to a fine of not more than N1000.00 for the third offence under section 7 making an entry per record which he knows to be false or misleading he shall be liable on summary conviction to a fine not exceeding N1000.00 or imprisonment for a term not exceeding six months or to both, such fine and imprisonment.


1 Petroleum Act Cap P.10 Laws of the Federation Nigeria, 2010.
2 Mineral Oil Act No. 17 of 1914.
3 Ibid. No.17 of 1925 .
4  Petroleum Decree No.51 of 1969 (now Cap. P10 Laws of the Federation of Nigeria 2010)
5  Petroleum  Act, Cap P.10 LFN 2010.
6 Ibid, Section 1(1&2).
7 Ibid, Section 2.
8 Ibid, Section 3 (1).
9 Ibid, Section 2.
10Hydrocarbon Oil Refineries Act Cap H5, LFN 2010.
11 Petroleum Act Cap. P.10 LFN,  2010.
13 Ibid, Sub. 2.
14 Ibid, Section 4(3).
15  Ibid, Section 4(6).
16 Ibid, Section 5.
17 Ibid.
18 Ibid, Section 7(4).
19 Ibid, Section 7(5).
20 Ibid, Para.4 of the 4th Schedule.
21 Aja C. O., Should Nigeria quit OPEC? (Abakaliki; Itua Press,2003), P. 11
21a  Petroleum Profits Tax Act Cap P.13 LFN 2010.
22   Petroleum Equalisation Fund Act Cap. P. 11 LFN 2010.
23   Petroleum Production and Distribution (Anti-Sabotage), Act Cap. P. 12 LFN 2010.
24   Petroleum (special Trudt) Fund Act Cap. P. 14 LFN 2010.
25   Petroleum Technology and Development Fund Act Cap. P. 15 LFN 2010.
26   Petroleum Training Institute Act Cap. P. 16 LFN 2010.
27   Oil Pipeline Act Cap. P. 07 LFN 2010.
29   Associated Gas Re-injection Act Cap. P. A25 LFN 2010.
30    Oil in Terminal Dues Act Cap. P. 08 LFN 2010.
31   Oil in Navigable Waters Act Cap. P. 123 LFN 2010.
32   Nigerian Liquefied Natural Gas Cap. P. 06 LFN 2010.
33   Niger Delta Development Commission Act Cap. N 6 LFN 2010.
34  Associated Gas Re-injection Act Cap A25 LFN 2010.
35Ibid.
36 Ibid
37 Oil Pipeline Act Cap 07 LFN 2010.
38  Omorogbe M.V., Downstream Sector Reforms in the Nigerian Oil Industry: The role of the Legislature, http:www.nigerianewnsow.com, visited20/09/2012
39 See item 39 of the 2nd Schedule to the 1999 Constitution of the Federal Republic of Nigeria (as amended).
40 Oil Pipeline Act Cap 07 LFN 2010
41 Ibid
42 Ibid, Section 3 and 4.
45 Nkuma v. Odili, (2001) 15 NWLR (pt. 737) P. 570 at 581
57 Petroleum Production and Distribution (Anti Sabotage) Act Cap p12 LFN 2010.
58 Petroleum Act Cap P. 10 LFN 2010
60 Ibid
61 Section 1(1) (a) & (b) of the Petroleum Production and distribution At Cap P. 12 LFN 2010
62 Ibid, Section 1(1c).
63  Ibid, Section 2
64 Ibid.
65 Ibid, Section 3 Ibid, Section 2
64 Ibid.
65 Ibid,
66 Nigerian National Petroleum Corporation Act. Cap N123 LFN 2010
67 Ibid, Section 5.
68 Section 7(b) of the Petroleum Products Pricing Regulatory Agency Act No 8 of 2003.
69 Petroleum Profits Tax Cap P.13 LFN 2010.
70 Ibid.
71 Etikeventse G., Nigerian petroleum Law, 2nd e.d., (Lagos: Drewe Publishers 2004) P 250- 251.
72 Ibid, p.254.
73 Etikerentse; Op. cit, note 65, P.249.
74 See the Long Title to the Petroleum Profits Tax Act Cap P.13 LFN 2010.
75 Ibid, Section8.
76 Ibid Section 2. See also the Supreme Count case of Shell Petroleum Development Co. (Nig.) Ltd. V. FBIR [1996) 8 NWLR (Pt 466) P. 256 at 284-285, where the phrase “petroleum Operations” in relation to PPTA was defined.
77 Companies Income Tax Act Cap C 21 LFN 2010.
78 Oil in Navigable waters Act Cap 06 LFN 2010.
79 International Convention for the Prevention of Pollution of sea by oil, 1954.
80 Umudje v. shell BP Petroleum Dev. Co. (Nig) Ltd unreported suit No. Sc/254/75.
81 [1865] L.R.I Ex 265.
82 Oil in Navigable waters act cap. 06 LFN 2010.
83 Ibid, Section 1.
84 Ibid, Section 3.
85 Ibid, Section 1 and 2.
86 Ibid, Section 12 (1).
87 (1990) 6 NWLR Pt 159-693
89 International Convention for the prevention of Pollution of the sea by oil (as amended), 1962.
90 This is the standard of proof in criminal cases see section
91 Esso Petroleum Co. Ltd  v. South Port Corporation [1956] A.C 213.
92 Section 112 (1) of the Oil in Navigable waters Act Cap 06 LFN 2010




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