Justice Bode Rhodes Vivour of the Supreme Court of Nigeria in April 2014, in the case of Lois Chituru Ukeje vs Mrs Gladys Ada Ukeje, wife and daughter of Mr. Lazarus Ukeje declared thus: “...no matter the circumstances of the birth of a female child, such a child is entitled to an inheritance from her late father’s estate. Consequently, the Igbo customary law which disentitles a female child from partaking in the sharing of his deceased father’s estate is a breach of section 42(1)(2) of the Constitution of the Federal Republic of Nigeria 1999, a fundamental Rights provision guaranteed to every Nigerian. This said discriminatory law is void as it conflicts with section 42(1)(2) of the said Constitution. In the light of what I have been saying, the appeal is dismissed” In April 2014, the Supreme Court nullified a custom that disinherited women as repugnant to natural justice, equity and good conscience in the case of Mrs. Maria Nweke vs Onyibor Anekwe and Anor. The claim was for a declaration for the right of occupancy over a parcel of land where the Plaintiff lived with her husband until his death. The Defendants were disinheriting the Plaintiff because she had only female children for her late husband. Justice Ogunbiyi did not hesitate to make this pronouncement: “I hasten to add that the custom and practice of Awka people upon which the appellants have relied is hereby out rightly condemned in very strong terms. A custom of this nature in the 21st century societal setting will only tend to depict the absence of the relatives of human civilization. It is punitive, uncivilized and only intended to protect the selfish perpetration of male dominance which is aimed at suppressing the right of the women folk in the given society. One would expect that the days of such obvious differential discrimination are over. Any custom that disinherits a daughter from her father’s estate or wife from her husband’s property by reason of God’s instituted gender differential should be punitively dealt with. The punishment should serve as a deterrent measure and ought to be meted out against the perpetrators of the culture and custom. For a widow of a man to be thrown out of her matrimonial home where she had lived all her life with her late husband and children by her late husband’s brother on the ground that she had no male child is indeed very barbaric, worrying and flesh skinning”. Also the Court of Appeal in Asika vs Atuanya (2008) 17 NWLR (Pt 1117) at 484 struck down the custom that portends to demean a woman merely because she is a person of feminine gender and declared such customary practices as unconstitutional. Pathetic situations witnessed in Shodipo v Shodipo (1990) WRN 98 where the court refused to consider the wife’s contribution to the 43-year old marriage and just awarded a lump sum of N200,000 equivalent of (1,800) U.S. Dollars to her, which was considered exceptionally discriminatory are now giving way to broader interpretation of 50-50 equitable distribution of marital property upon divorce. Both visible and invisible contributions of spouses must be taken into account before arriving at such decisions. This also extends to decisions in maintenance and custody of children which must be guided by overriding interest of the child. The following cases decided in Nigerian Courts within this reporting period will clearly strengthen the judicial bent. In LT. Adeyinka A Bibilari vs Ngozika B Aneke Bibilari —(2011) 13 NWLR (PT 1264) p. 207 intolerable behaviour was condemned by the courts. Also in Motoh v Motoh (2011) 16 NWLR (Pt 1274) 431-631, the court drew distinction between forms of marriages in Nigeria and the rights attendant to such marriage and held that photographs are clear proof of celebration of marriage. Clearly the Matrimonial Causes Act did not make cruelty a ground for divorce but by extension, Section 15(2)(c) which authorizes an aggrieved spouse to petition for divorce on the 46