In an unanimous decision delivered on May 15, 2026, the five-member panel, led by Justice Jamilu Tukur, dismissed the application filed by Danyaro on behalf of his client, Jokolo, for being “frivolous and lacking merit”.
The other supreme court judges on the panel are Uwani Aji, Ibrahim Saulawa, Emmanuel Agim, and Chioma Nwosu-Iheme.
Jokolo was the 19th Emir of Gwandu before he was deposed by the Kebbi state government in 2005, and Muhammadu Iliyasu Bashar subsequently installed as the 20th emir in June 2005.
Dissatisfied with the development, Jokolo approached the Kebbi state high court, which in 2014, ruled in Jokolo’s favour and ordered his reinstatement.
The Kebbi state government and Bashar appealed the decision, and in 2016, the court of appeal sitting in Sokoto upheld the lower court’s ruling.
The appellants then took the matter to the supreme court.
In June 2025, the supreme court declared Bashar as the rightful Emir of Gwandu in Kebbi state, ending a 20-year legal battle over the traditional stool.
In a split judgment of three to two, the apex court ruled that Jokolo, who was dethroned in 2005, failed to follow due process before challenging his removal in court.
The apex court held that Jokolo’s case was filed prematurely because he did not submit a formal complaint to the Kebbi state governor before heading to court, as required under section 4 of the Kebbi State Chiefs (Appointment and Deposition) Law.
However, in a motion filed in October 2025, Jokolo, through his counsel, Danyaro, asked the supreme court to review and set aside its judgment “on grounds of fraudulent misrepresentation of law and violation of constitutional provisions”.
The applicant also asked the apex court to constitute another panel to review the appeal filed by the governor of Kebbi state and others against the judgment of the appeal court.
The applicant argued that the judgment of the supreme court was “procured by a fraud upon the court, stemming from the respondents’ misrepresentation of section 4(3) of the chiefs (appointment & deposition) law, cap, 21, laws of Kebbi State, 1996”.
The applicant’s notice was brought pursuant to order Order 20 Rule 4 of the Supreme Court, Rules 2024, and Section 6 (6) B and 36 (1) of the Constitution of the Federal Republic of Nigeria, 1999.
Countering the application, counsel to the 1st to 13th respondents asked the supreme court to dismiss the application of review.
The respondents are governor of Kebbi state; attorney-general, Kebbi state; Kebbi state council of chiefs, Gwandu emirate council; Abdullahi Umar (Wazirin Gwanda); Muhammad Sambo Aliyu (Magajin Rafin Gwandu); Aminullah Umaru (Magajin Gari); Muhammed Wanka (Sarkin Illo); Mainasara Zagga (Sarkin Zagga); Buhari Muhammad (Sarkin Aleiro); Mukhtar Abdullahi (Walin Gwandu); Ibrahim Bashar (Galadima Babba); and Aminu Ahmed (Sarkin Fada).
The respondents’ counsel argued that focus of the review is not “seeking to contest a clerical error or accidental slip under the slip rule” but attempting to review and set aside the apex court judgment delivered on June 2025.
The respondents also argued that the decision of the supreme court is “final, binding, and not subject to review” and no constitutional and statutory provisions allow review.
In the lead judgment for the application of review delivered by Tukur, the supreme court ruled that order 20, Rule 4 of the apex court is a “narrow procedural provision designed solely to preserve the accuracy and integrity of the Court’s judgments, not to reopen or reconsider them”.
The apex court held that order 20, Rule 4 is “strictly confined to the correction of clerical mistakes, accidental slips, or omissions that may have occurred in the process of recording the court’s decision”.
The supreme court ruled that the request for the apex court to re-constitute its panel on a concluded case is “quite frankly, an affront of the highest order to the authority, dignity, and institutional integrity of this Court”.
“It betrays not only a fundamental misunderstanding of the constitutional role of the Supreme Court, but also a disturbing lack of respect for the finality of its decisions,” Tukur ruled.
“This is not a mere procedural misstep or an overzealous argument. It is a direct invitation to this Court to repudiate its own authority and to descend into a cycle of endless self-review. Such a proposition is intolerable and strikes at the very heart of judicial finality.
“It must be stated in unmistakable terms that the supreme court is not a forum that can be invited to reconstitute itself because a party is dissatisfied with its judgment.”
The apex court described the application as “wholly unmeritorious, vexatious, and abusive”, while dismissing it in its entirety.
The court also condemned the applicant’s counsel for filing the application for a review of judgment in a concluded matter.
“Before I take leave of this application, I must express my profound disapproval of the conduct of learned counsel for the Applicant,” Tukur ruled.
“The filing of this application, in the face of clear and unambiguous provisions of the Supreme Court Rules and the settled principles governing the finality of this Court’s decisions, is not only misguided but falls short of the standards expected of a legal practitioner.
“Counsel, as an officer in the temple of justice, is under a solemn duty to uphold the law, act with candour, and refrain from advancing positions that are plainly unsustainable.”
The apex court ordered Danyaro to personally pay the sum of N50 million to the respondents within 90 days as cost for filing the application.
The court said Danyaro will not be allowed to appear before it until he pays the money to the respondents.
The lead judgment was supported by four other justices in the panel alongside their comments.
In a comment supporting the lead judgment, Nwosu-Iheme held that the application for review was filed by the “irresponsible counsel to ventilate his grievance over the outcome of the substantive appeal”.
The judge said Danyaro “degenerated to a level unprecedented in the history of application for review in this court and ended up not only exposing his ignorance and poor knowledge of the law but making a mockery of himself as a legal practitioner”.
The judge supported the N50 million fine imposed in the lead judgment.
“This Application and the unbecoming conduct of counsel for the Applicant is bereft of common sense, it is dismissed in its entirety,” Nwosu-Iheme said.
“The judgment of this Court delivered on the 4th day of June, 2025 in Appeal No. SC.266/2017 remain subsisting, final and binding on all parties.
“Sequel to the vexatious and unprofessional Application of this uncultured Counsel, S.M. Danyaro, intended only for causing annoyance when objectively evaluated, I also order that costs of N50,000,000:00 (FIFTY MILLION NAIRA) be paid personally by this recalcitrant Counsel, S.M. Danyaro personally for filing this trash.”
