The very nature of the adversarial system of litigation we practice means that, at the end of every case filed in court, there is a winner and a loser. The person who wins will look forward to reaping the fruits of her judgment. The first step the winner must take in order to enjoy the judgment is to file an entry of judgment. The purpose of filing an entry of judgment is to inform the losing party what judgment has been given by the court in favour of the winning party, the date of the judgment, the name of the judge, the name of the court, etc. Without filing an entry of judgment, the winner cannot enforce and enjoy the judgment. Since the entry of judgment is the formal record of the judgment of the court, its existence is the most cogent evidence that the judge pronounced judgment at or after the trial. It is drawn up (or simply put, prepared) by the lawyer for the successful party, known as the judgment-creditor, and served personally on the losing party, called the judgment-debtor, as a prelude to execution.
But in a recent case that was heard before the Supreme Court, the Court gave certain directives to the effect that, drawing up of entry of judgment must not be left in the hands of the winner’s (judgment creditor) lawyer. Rather, court registrars and judges must be the proper persons to state what judgment the court gave. The Supreme Court went as far as to suggest that the High Court rules of procedure must be amended to follow the provisions in the Supreme Court rules that state that, after a judgment is given, the registrar must issue a certificate on the judgment and it must be signed by the presiding judge and sealed.
In this article, the case of Asamoah v S.I.C is discussed. The directives that were given by the Supreme Court in the case are analyzed in detail. The reasons given by the Supreme Court for issuing the directives are examined and the Court’s preferred mode of drawing up entry of judgment is discussed. The article argues that, the Supreme Court did not have jurisdiction to make new ‘rules’ by way of directives to amend the High Court Rules of Procedure, a jurisdiction reserved solely for the Rules of Court Committee by the Constitution. The article concludes that, the current regime for drawing up entry of judgment by judgment-creditors or their lawyers under the High Court Rules is adequate and the Supreme Court’s directives in Asamoah v S.I.C are not only pointless, but they are unlawful.
B: The case of Asamoah v S.I.C
The facts: The appellant, an insurance company called State Insurance Company Ltd (S.I.C) insured the respondent’s (Asamoah) car under a comprehensive policy. The car was later snatched from Asamoah’s wife by robbers and Asamoah claimed the value of the car under his comprehensive insurance policy with S.I.C. S.I.C refused to pay and Asamoah sued at the High Court for the car’s insured value of GH₵116,200 plus interest.
Procedure: Asamoah won the case at the High Court. S.I.C was not happy with the judgment so they appealed against the judgment and applied for stay of execution pending appeal. The Court of Appeal granted the stay on terms and ordered S.I.C to pay the full judgment debt and interest into court within 30 days. The Court of Appeal directed the registrar to put the money into an income-yielding investment. S.I.C complied and paid the money into the High Court. When the appeal was heard, S.I.C won the appeal. Asamoah then appealed to the Supreme Court and he won. After winning his appeal at the Supreme Court, Asamoah applied to withdraw the money paid into the High Court plus the interest from the investment. The money was paid to him through his lawyer. Asamoah’s lawyer later filed two notices of ‘entry of judgment’ in which he calculated interest at the commercial rate on the money paid into court and already withdrawn by him. The lawyer argued that the new claim for interest was based on the Supreme Court’s order that Asamoah must be paid his money with interest. S.I.C opposed the application.
It is the claim for interest filed by Asamoah in the two new ‘entry of judgment’ in the High Court after receiving the money paid into court that resulted in the instant appeal before the Supreme Court.
Issue: The issue the Supreme Court had to resolve was whether after withdrawing the money plus interest paid into court, Asamoah was entitled to collect any further interest from S.I.C.
Decision: The Supreme Court held that, Asamoah was not entitled to any further interest beyond what was paid into court, invested and paid to him. The Court reasoned that, Asamoah had not been kept out of his money. He applied to the High Court and had the money, together with the interest from the investment, released to him. He had, thus, been indemnified from any loss by the investment made and interest accrued. Having gained access to the full value of the money, Asamoah would be unjustly enriched if he were to be granted further interest as was calculated in the subsequent notices of entry of judgment filed by his lawyer.
The Supreme Court added that, at the time the Supreme Court heard the appeal and decided on it, it was not aware of the Court of Appeal order for the payment of the judgment debt and interest into court. Therefore, the order of the Supreme Court for calculation of interest up to the date of final payment must be interpreted by the parties in the light of the reality on the ground as at the date of its delivery. That is to say, the amount and interest had already been paid into court.
Speaking on the legal effect of paying money into court, Amegatcher, JSC stated that, it is a way of protecting funds while the litigation is ongoing. Such payment into court is meant to satisfy any potential liability. For instance, if a defendant is found liable, the payment into court goes to the plaintiff. If the defendant is found not liable, then the defendant gets a refund of the payment made into court. In cases of appeal, such payments will remain in the court’s custody to ensure that, in the event of the failure of the appeal, the respondent will have his money without difficulty. In general, the procedure for ordering payment into court gives litigants assurance that they will be able to collect any judgment awarded in their favour.
In summary, once payment has been made into court and it satisfies the claim and the beneficiary accepts it, the payment discharges the debtor from any further obligation, be it the principal or interest. And any interest calculable on the debt due will cease to run from the date the full principal is paid into court.
C: The new regime conceived by the Supreme Court
In the course of giving its judgment in Asamoah v S.I.C, the Supreme Court bemoaned the tendency by some parties and lawyers to file entries of judgment that do not reflect the actual orders made by courts. The Court took the view that, Asamoah’s lawyer was wrong in filing the new entries of judgment since he knew the money was paid into court. The order made by the Supreme Court for payment of interest up to the date of final payment was of no moment as it was made without knowing the money was already in court, and in investment, too. Consequently, the Court gave several directives towards reforms in the rules on entry of judgment. It also called on the Rules of Court Committee to implement some of the directives.
According to the Supreme Court, drawing up the entry of judgment after trial should not be left to the judgment creditor or his lawyer alone as provided in C.I 47. Judges and registrars must make an input before the entry of judgment is filed. This is what the Supreme Court said:
“If … the judgment after trial is the formal record of the judgment and the most cogent evidence that the judge pronounced that judgment at or after the trial, we do not think it is appropriate for its drawing up to be left in the hands of one party to the litigation without any input from the judge who delivered the judgment.”
In making this assertion, the Court found fortification in the provision in the Supreme Court Rules which requires that a judgment or order made by the Supreme Court, to be enforced in a trial court, must be accompanied by a certificate stating the orders made by the Supreme Court, under the seal of the Supreme Court and signed by presiding Supreme Court judge. The Court prescribed that procedure for the High Court in place of the current procedure where the judgment-creditor or her lawyer draws up and file the entry of judgment.
D: The Supreme Court’s reasons for its preferred ‘new’ rules
It is trite learning that, under the High Court Rules, it is judgment-creditors or their lawyers who interpret the judgment and prepare or draw up a notice of entry of judgment and file it at the registry. The Supreme Court’s directives in Asamoah v S.I.C showing a preference towards judges and registrars, instead of judgment-creditors and their lawyers, to prepare entry of judgment were based on the following triumvirate of reasons. The first reason given by the Court was that, judgment creditors or their lawyers drafting and filing entry of judgment has posed problems for administration of justice in Ghana because some parties deliberately misstate the actual orders made by the court or the legal basis of their claim before the court. For instance, a party may claim compound interest when no such rate was part of the agreement between the parties or where the court made no such order. Secondly, a party can enter judgment for recovery of possession when no such relief was claimed and even if claimed, was not granted by the court. Thirdly, an entry of judgment may not state the actual effect of a declaratory relief made by the court and whether it is legal to enforce such declaratory reliefs, the Supreme Court reasoned.
The ‘orders’ given by the Supreme Court
In the light of the three reasons set forth above, the Supreme Court proposed several new ‘rules’ to regulate the drawing up and filing of entry of judgment in Asamoah v S.I.C. To experience the full force and effect of the proposals, they are quoted in detail below:
“1. Trial judges are to summarise and specifically state all enforceable orders made in their judgments at the end or at the conclusion of the judgments. This
summary is to be recorded in the Record Book as well. This will provide
guidelines to the parties, Counsel and the registrars regarding the drawing up
and the filing of notices of judgment after trial and the specific orders to be
enforced by way of execution. The Judicial Secretary is ordered to bring this
directive to the attention of all trial courts in the country and the Judicial Training
2. Registrars of all courts are to carefully review such notices of entry of judgment filed and satisfy themselves that the contents represent the orders made by the court in the suit. When in doubt, registrars should seek clarification from the judge who pronounced the judgment before executing any documents for the enforcement of the judgment. The Judicial Secretary is ordered to bring this directive to the attention of all registrars of the courts in the country and the Judicial Training Institute.
3. Counsel representing judgment-debtors must carefully scrutinise notices of entry of judgment filed by their colleagues and confirm that the contents are in line with the agreement of the parties and/or the final orders made by the court. If the notice has been misrepresented, it is the professional responsibility of the counsel to object timeously to the terms filed and to apply to the court immediately to set aside or rectify the notices. This is a duty owed their clients, the court and the profession to expose wrongdoing and protect the sanctity of the justice delivery system.
4. Counsel preparing and signing notices of judgment after trial should be wary of the rules of professional conduct which regulate their actions in court. We refer especially to Rule 63 (2) (e) & (f) of the Legal Profession (Professional Conduct and Etiquette) Rules, 2020, L.I. 2423 which provides as follows:
a. Rule 63 (2) (e) Where a lawyer acts as an advocate, that lawyer shall
not knowingly attempt to deceive a court or influence the course of
justice by offering false evidence, misstating a fact or law,
presenting or relying on a false or deceptive affidavit, supressing
what ought to be disclosed, or otherwise assisting in a criminal or
an illegal conduct.”
b. Rule 63 (2)(f) Where a lawyer acts as an advocate, that lawyer shall
not knowingly misstate the content of a document, the testimony of
a witness, the substance of an argument, or the provision of an
enactment or like authority.”
Any breach of these rules by misstating the orders made by a court in the
notices of entry of judgment should henceforth be referred to the Disciplinary
Committee of the General Legal Council for the appropriate sanctions.
5. The Rules of Court Committee is called upon to have a second look at the
provisions in the rules which vest the power to interpret and draw up the notice
of judgment after trial solely in the hands of the judgment creditor and their
counsel. Any review or amendments of the rules should be geared towards
averting injustices occasioned by misrepresentation of court orders for the
purposes of execution.”
E: An analysis of the ‘directives’
The directives, on their face, may not trouble anyone, even those familiar with legalistic eccentricities. This is so because they appear to have the imprimatur of law coming, as they are, from the highest and most revered court of the land. But a deeper analyses of the ‘orders’ reveal that, there is more to them than meets the eye. The orders are discussed in detail below.
a. Trial judges are to summarise and specifically state all enforceable orders made
in their judgments at the end or at the conclusion of the judgments.
This directive looks rather harmless as it accords with best practice. But any such practice must be introduced into the rules through the Rules of Court Committee, and not the Supreme Court. So, for the Supreme Court to order the Judicial Secretary to bring this directive to the attention of all trial courts in the country and the Judicial Training Institute is, with all due respect, unlawful. Neither the Constitution nor the Courts Act give the Supreme Court any powers to make rules to guide the procedures of trial courts. As stated earlier, that jurisdiction is exercisable only by the Rules of Court Committee and none other. It is submitted that, the Supreme Court cannot nibble at that jurisdiction that is constitutionally reserved for the Rules of Court Committee. For that reason, the ‘directive’ to trial courts and the Judicial Training Institute is an illegality parading on stilts.
b. Registrars of all courts are to carefully review such notices of entry of judgment
filed; if in doubt, they must consult the judge.
As noted earlier, the High Court Rules state that, the party seeking to have a judgment entered should draw up the judgment and present it to the registrar for entry. The ‘party seeking to have a judgment entered’ is the party who won the case, also known as the judgment- creditor. So the practice where a judgment-creditor or her lawyer prepares and files an entry of judgment after trial rooted in law, that is, C.I 47. The Supreme Court cannot, with the greatest respect, supplant the Rules with their preferred procedure and order the Judicial Secretary to carry it out. The Rule of Court Committee is the constitutionally mandated body with power to make the rules that guide the practice and procedures in all courts in Ghana. The Supreme Court’s role is to interpret and enforce the law, not to make the law. If, as the Supreme Court alleges, some of our citizens suffer injustice as a result of wrong information included in entries of judgment, it is the Rules of Court Committee that must address the allegations and make rules to cure the alleged mischief. But definitely not the Supreme Court, and most definitely, not the manner in which it seeks to do so.
At any rate, burdening our already over-burdened registrars and judges to scrutinise, nay, draw up entry of judgment after trial, is not an apposite counsel. The wheels of litigation grind slowly as it is already. Taking away the few processes – such as entry of judgment - that lawyers can prepare and file on their own outside the judicial bureaucracy, rather detracts from any desire to curb injustice in the judicial process. In any event, entry of judgment is filed whether the judgment given by the court is interlocutory or final, and whether it is final based on a default judgment or summary judgment or final based on a trial on the merits. Is it the Supreme Court’s expectation that every entry of judgment, qua entry of judgment, must be reviewed by a registrar, signed off by the judge and sealed by the registrar before filing? Will the judgment-creditor still pay filing fees on the entry of judgment she did not prepare? If the answers to these questions are in the affirmative then, it is submitted that, judicial ingenuity will be sorely taxed to address this conundrum.
This brings to mind the innovative procedure that was introduced by C.I 47 regarding injunction applications but was quickly killed by the judicial ‘system.’ Reference is made to the ‘system’ because nobody formally changed the rules but somehow, the rule was not honoured in observance. I am referring to the provision in the Rules on interlocutory injunction. The Rules provide that a party who applies for interlocutory injunction can attach a draft of the order sought to the application to facilitate speedy preparation and sealing of the order when the application is granted. When the Rules came into operation in 2004 and some of us sought to operationalize this rule, we were met with stiff resistance from the registrars because they preferred orders drawn up at the court. We did not insist on the law and we gave in. Judicial bureaucracy took over and the law maker’s intention ‘to facilitate speedy preparation and sealing of the order’ went with the wind. We are still living with the consequences. Aloofness has become the legal profession’s most recognizable trait, acquiescence its chief characteristic.
It is in this light that the Supreme Court’s benign attempt at usurping the practitioner’s last hope of speedy enforcement of judgment must be resisted and stopped in its tracks. If the Supreme Court’s directives are allowed to gain a foothold, or, if we look on for the Rules of Court Committee to pass some constitutional instrument to confer a semblance of legitimacy on the so-called orders, we will be mourning at our own funeral. In that case, we should not be surprised to awake to the news that, all writs and statements of claim must be submitted to registrars and judges to certify that, they disclose a cause of action against the intended defendant before they are filed. This may sound rather bizarre today but in all sincerity, who would have thought that a day would come when judgment-creditors’ lawyers will lose their lawful right to draw up entry of judgment on behalf of their clients? In law, just as in politics, there are no immaculate conceptions.
c. Counsel representing judgment-debtors must carefully scrutinise notices of entry of judgment filed by their colleagues and confirm that the contents are in line with the agreement of the parties and/or the final orders made by the court:
The law recognizes that mistakes do occur in the judicial process and that is why there are rules on amendment to correct any such mistakes. Indeed, in Akowuah v Amoo, the Supreme Court held that an error in an entry of judgment must be amended by an order of the court through an application on notice to the other party. The Court opined as follows:
“[a]ssuming … that there was an error in the initial entry of judgment, such error should be corrected by the judicial process. In my respectful view, a judgment-creditor, who discovers his error in filing such a vital process, should not be permitted to amend the process on his own motion without resort to the judicial process by invoking the court’s jurisdiction to correct the slip or omission through amendment with notice to the judgment-debtor who is the affected party.”
It is submitted that, this view taken by the Court accorded with the general principles for amendments in correcting mistakes in court pleadings and processes. Regrettably, this erudite opinion was not considered by the Supreme Court in its decision in Asamoah v S.I.C. Perhaps, if the Supreme Court had averted its mind to its previous decision in Akowuah v Amoo, it would have been slow in propounding new rules of procedure for drawing up entry of judgment, in contumelious disregard of the existing rules and usurping the power exclusively reserved under the Constitution for the Rules of Court Committee. If the Rules make provision for amendments to correct mistakes, it beggars belief that the Supreme Court will go to such an extreme to impute professional negligence to a lawyer who dares draw up an entry of judgment with mistakes.
d. Counsel preparing and signing notices of judgment after trial should be wary of the rules of professional conduct which regulate their actions in court… Any breach of these rules by misstating the orders made by a court in the notices of entry of judgment should henceforth be referred to the Disciplinary Committee of the General Legal Council for the (sic) appropriate sanctions.
Perhaps, of all the impugned orders made by the Supreme Court in Asamoah v S.I.C, this the most bizarre order of all is the one that exposes a lawyer to disciplinary proceedings for mistakes in drawing up an entry of judgment. For the Supreme Court to affix a mistake made by a lawyer in an entry of judgment with professional irresponsibility is beyond belief. Now, in a case in which the judgment-creditor represents herself, what will be her sanction if she makes a mistake in drawing up an entry of judgment? The Supreme Court’s latest fondness for the Disciplinary Committee of the General Legal Council borders on the pathological. Will a mistake in making a claim in a writ and statement of claim also attract quasi-criminal sanctions? If the same argument is made that a judge who makes a mistake in a judgment or order must be sanctioned, how fair will that be?
e. The Rules of Court Committee is called upon to have a second look at the
provisions in the rules which vest the power to interpret and draw up the notice
of judgment after trial solely in the hands of the judgment creditor and their
Counsel. Any review or amendments of the rules should be geared towards
averting injustices occasioned by misrepresentation of court orders for the
purposes of execution:
This ‘order’, it is submitted, should have been the order made by the Supreme Court. It recognizes that the Rules of Court Committee is the only legitimate body to make rules of procedure to guide the courts. It is submitted that, if the Supreme Court goads the Judicial Secretary to carry out the first four unlawful orders, this last but important directive will be rendered useless. Be that as it may, the Supreme Court’s appetite for an amendment in the Rules to side-step judgment-creditors and their lawyers regarding entry of judgment is not a healthy one, as noted above. When, and if, any such amendment is presented to the Rules of Court Committee, the members must be bold and tell the sponsors: ‘Procul O! Procul este profani.’
F: Must trial courts follow the procedure in the Supreme Court Rules?
To proffer a solution to the so-called ‘problem’ of leaving entry of judgment preparation in the hands of judgment –creditors and their lawyers, the Supreme Court suggested that Rule 28 of the Supreme Court Rules must be adopted instead of the procedure in Order 25 rule 7 (1) C.I 47. The Supreme Court rules provide that the registrar must issue a certificate signed by the presiding judge and sealed before a judgment will be enforced. I wish to state right at the outset that, do not share in the Supreme Court’s preference for the provision in Rule 28. The reason is simply this; the provision in Rule 28 of the Supreme Court Rules is suitable for the peculiar circumstances where a judgment given by the Supreme Court but can only be enforced in the trial court. Since the trial court will be enforcing a judgment that is not originating from that court, the Rules of Committee found it wise to demand that the presiding judge must sign the certificate and the registrar must seal it. This will leave no doubt in the trial court’s mind as to the nature of the judgment it is being called upon to enforce.
Contrary to the new ethos propounded in the Asamoah case, it is worthy to note that, in recent times, the Supreme Court has recognized the prominent role judgment-creditors play when it comes to execution of judgments. The apex Court has also held that, it has the power to enforce its own judgment under the Constitution by adopting any rules of procedure applicable in any court in Ghana. Therefore, it is not under any obligation to invoke Rule 28 of C.I 16 in order to enforce its judgment and orders. In Martin Alamisi Amidu v Attorney-General, Waterville Holdings (BVI) Ltd & 2 Others, Alfred Agbesi Woyome, it was noted that, the position taken by the applicant was based on the rather erroneous view that the Court should have applied Rule 28 of C.I 16 and asked the High Court to enforce the judgment in the case. The Court added that, “… it is not the duty or business of Counsel for a judgment debtor to tell this Court how to enforce or direct the enforcement of its decisions, judgments and orders. The mode of selecting an enforcement mechanism is the preserve of the judgment-creditor. Rule 28 is not mandatory for the Court to comply with; it may invoke it if it so desires. Thus, the fact that the Court did not refer the enforcement to the High Court is a matter of no consequence, as the Court has decided that it has the right, the means and the power to enforce its own judgments and orders applying any existing rules of practice available in any court in Ghana by virtue of Article 129 (4) of the Constitution, in the absence of rules of enforcement under the Supreme Court Rules, C.I. 16.” It is submitted that, if the Supreme Court does not feel itself bound to apply Rule 28 of C.I 16 but chooses to reach into the rules of other courts to enforce its judgments, then it is curious that the Supreme Court is now prescribing its Rule 28 (that it does not fancy that much) to the High Court that already has ample rules that the Supreme Court even prefers to adopt under Article 129 (4). If the Supreme Court itself seeks refuge in Article 129 (4) of the Constitution to escape applying the cumbersome procedure in Rule 28 of C.I 16 to enforce its judgment as happened in the Woyome case, then one is at a loss as to why the same Supreme Court will proffer that a similar rule must be introduced into the High Court Rules in the Asamoah case. Perhaps, a modern day Trojan horse of a gift to the Bar?
Under the High Court Rules, if a trial court hears a case and awards judgment in a party’s favour, the judgment will be enforced by that trial court. And the judgment- creditor or her lawyer who conducted the case and obtained the judgment is, and will be, the best person to draw up the entry of judgment and file it. Therefore, it will be wholly pointless to suggest that, after it has given its judgment, the trial court must be saddled with an extra workload of preparing a certificate, have it signed and sealed, and paid for, before the judgment creditor can go into execution as it is under Rule 28 of C.I 16. There must be an end to court procedures. At any rate, what will it profit a litigant if she wins a case in court but cannot enter judgment through her lawyer?
In conclusion, it is submitted that, the current regime for drawing up entry of judgment by judgment-creditors or their lawyers under the High Court Rules is adequate and the Supreme Court’s directives or orders in Asamoah v S.I.C are not only pointless, but they are unlawful. The new directives, if implemented, will only succeed in adding a further layer on the already congested judicial bureaucracy.
 Republic v Court of Appeal; Ex parte Ghana Commercial Bank Pensioners Association [2001-2002] SCGLR 883; dictum of Afreh, JSC
 Ken Kwame Asamoah v State Insurance Company Civil Appeal No. J4/55/2021, judgment dated 18th January, 2022, SC (unreported)
 High Court (Civil Procedure) Rules, 2004, (C.I 47)
 Supreme Court Rules, 1996 (C.I 16)
 Under Order 18 of the High Court (Civil Procedure) Rules, 2004 (C.I 47)
 See also the following cases: Ghana Consolidated Diamonds Ltd v Tantuo [2003-2004] SCGLR 1136. The plaintiffs sued their employers for the payment of their end of service benefits. The employers then paid into court the sum in satisfaction of the plaintiffs’ claim. The plaintiffs accepted and received the payment made into court but later filed a notice of acceptance of the amount paid as part satisfaction of their claims. It was held that the payment into court and acceptance ended the matter; Smith & Others v Blankson (substituted by) Baffour & Another [2007-2008] SCGLR 374
 Ken Kwame Asamoah v State Insurance Company Civil Appeal No. J4/55/2021, judgment dated 18th January, 2022, SC (unreported) at pg. 11
 1996, Rule 28 (C.I 16)
 Order 41 rule 7 (1) of C.I 47 on drawing up and entry of judgment or order provides thus: “The party seeking to have a judgment entered shall draw up the judgment and present it to the Registrar for entry.” And it is basic knowledge that, ‘the person seeking to have a judgment entered’ is the judgment-creditor
 Article 128 to 135 of the 1992 Constitution
 Section 1 – 9 of the Courts Act, 1993 (Act 459)
 Order 41 rule 7 (1) of C.I 47
 See: Article 157 (2) of the Constitution, 1992; Section 80 of the Courts Act, 1993 (Act 459)
 Even in cases where the Supreme Court has found that the law has not made adequate provision for safeguarding citizens’ rights, the Court has interpreted the law to “avert a denial of justice and enhance the realisation of a constitutional right.” See: James David Brown v National Labour Commission & Ahantaman Rural Bank Ltd Civil Appeal No. J4/74/2018, judgment dated 19th June, 2019, SC (unreported). The Court has not, with respect, usurped Parliament’s power and made laws on its own as it seeks to usurp the Rules of Court Committee’s powers to make rules of procedure for trial courts as it seeks to do in Asamoah v S.I.C.
 See: Order 25 rule 1 (5) of C.I 47
 See: Order 16 of C.I 47
  1 SCGLR 261 (Coram: Georgina Wood, C.J (presiding), Brobbey, Rose Owusu, Yeboah and Bafffoe-Bonnie, JJ.SC)
 Ibid. See: Dictum of Anin Yeboah, JSC (as he then was) at 268 - 269
 Civil Appeal No. J4/55/2021, judgment dated 18th January, 2022, SC (unreported) (Coram: Anin Yeboah, CJ (presiding), Pwamang, Amegatcher, Amadu and Kulendi, JJ.SC.
 Amegatcher, JSC, who delivered the opinion of the Supreme Court (and one other justice of the Supreme Court) sits as a member of the Disciplinary Committee of the General Legal Council
 Order 28 of the Supreme Court Rules, 1996 (C.I 16) states: “Where the Court directs any judgment or order to be enforced by any other court, certificate in the Form 12 set out in Part I of the Schedule to these Rules under the seal of the Court and the hand of the presiding justice setting out the judgment or order shall be transmitted by the Registrar to that other court, and the latter shall enforce the judgment or order in the terms of the certificate.”
 Civil Motion No. J8/115/2017 ruling dated 4th July, 2017, SC (unreported) (Coram: Benin, JSC, sitting as a single judge)
 Dictum of Benin, JSC
 See footnote 13 above