From the time of Osawe & 2 Ors v Registrar of Trade Unions (1985) 1 NWLR Pt 4 Pg 755, till today, the Supreme Court of Nigeria, SCONA, has consistently held that section 45(1) of the Constitution of the Federal Republic of Nigeria, CFRN, is a limitation clause on fundamental rights entrenched in sections 37-41 of the CFRN.

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