Danfulani v. E.F.C.C.  1 NWLR (Pt. 1493) 223 at 246 paras. C-D, per Adefope-Okojie, J.C.A.:
“I am in agreement with the 3rd Respondent that were a crime has been committed or suspected, an arbitration clause in a commercial contract may not be held to bind the aggrieved party. The lower court, I accordingly hold, stood on firm footing to have held that the 3rd Respondent had a right to make the complaint to the 1st Respondent.”
The above principle is understandable. Investigation of crime and subsequent prosecution of same is within the realm of criminal law and not subject to agreement of parties.
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