Introduction
In the course of carriage of
persons, baggage and cargoes by airline carriers, the delay, damage or loss of
baggage and cargoes and sometimes loss of lives or personal injuries do occur
due to human omissions or commissions, natural factors and accidents. This
edition of Akintunde Esan’s Legal Illuminations is focused on the on the
international and domestic laws governing the rights and liabilities of
airline carriers, passengers, consignors and consignees in Nigeria in the
context of remedies for delayed, damaged or lost baggage and compensation for
death or injury of airline passengers in Nigeria.
A. Legal
Framework
Aviation Law is body of
international and domestic laws governing various aspects of civil
aviation.
1. International
Conventions
The rights and liabilities of
airline/carriers, passengers, consignors and consignees in Nigeria are regulated
by International Conventions. These Conventions have as their objective
the unification of certain rules relating to International Carriage by air in
order to ensure uniform standard, the orderly development of international air
transport operations and the smooth flow of passengers, baggage and cargo in
accordance with the principles and objectives of the Convention on International
Civil Aviation. The ultimate purpose and intention of these Conventions is to
remove those actions governed by them from the uncertainty of the domestic laws
of the member States. Thus, all countries that are signatories apply them
without recourse to their respective domestic Laws. See Cameroon Airlines v.
Otutuizu (2011) 4 NWLR (Pt. 1238) 512, per Rhodes-Vivour,
JSC
a. Warsaw Convention
1929
The Convention for the
Unification of Certain Rules Relating to International Carriage by Air 1929
commonly known as the Warsaw Convention as amended by the Hague
Protocol 1955 is an international convention which regulated liability for
international carriage of persons, luggage, or goods performed by aircraft for
reward. It was signed in Warsaw on 12 October 1929, and became effective on 13
February 1933.
b. Montreal
Convention 1999
The Montreal Convention
(formally, the Convention for the Unification of certain rules relating to
International Carriage by Air). It is also termed the Agreement Relating to
Liability Limitation of the Warsaw Convention and Hague Protocol. The
Convention is a multilateral treaty adopted by a diplomatic meeting of the
International Civil Aviation Organisation (ICAO) member states at Montreal on
28th May, 1999. By September 5, 2003 , the Montreal Convention was ratified by
31 states including Nigeria. It became effective on November 4,
2003.
The Convention retained the core
provisions of the Warsaw Convention , it however, reviewed upward the
limitation on liability for death and personal injury cases, waived the
airlines’ due care defences and made the carrier’s liability an absolute
liability in the absence of passenger’s negligence.
2. Domestic
Applications of International Aviation Laws
The International treaties
particularly the Warsaw and Montreal Conventions which govern the rights and
liabilities of airline/carriers, passengers, consignors and consignees
have been domesticated in Nigeria and made applicable to both
international and non-international air carriage
contracts.
a. Carriage by Air
(Colonies, Protectorates and Trust Territories) Order,
1953
The Warsaw Convention was
domesticated as a Nigerian Law by the Carriage by Air (Colonies,
Protectorates and Trust Territories) Order, 1953, Vol. XI Laws of the Federation
1958. It came into operation on the 1st day of January 1954. This
law is no longer part of the existing law in Nigeria contrary to as held
in the case Ibidapo v. Lufthansa (1997) 4 NWLR (pt.498) 124 which was
held before the commencement of the 2006 Civil Aviation Act, as it has
been repealed by Section 77 (1) of the Civil Aviation Act, 2006
which provides that:
“1. Subject to the provisions of subsection (2) of this section, the following enactments are hereby repealed;a) Carriage by air (Colonies, Territories and other Trust Territories) Colonial Order 1953;b) Civil Aviation Act, Cap. 51 LFN 1990;c) Civil Aviation (Amendment) Act, 1999; andd) )Nigerian Civil Aviation Authority (Establishment) Act, No. 49 1999.2. All regulations, by‐laws, orders and subsidiary legislation made under the Civil Aviation Act, 1964 Cap. 511. FN 1990) shall continue to be in force until new regulations, by‐laws, orders and subsidiary legislation are made pursuant to this Act.”
While Section 77 (1) Civil
Aviation Act, 2006 repealed the Carriage by Air (Colonies, Protectorates
and Trust Territories) Order, 1953, Section 48 (1) of the Act made
the Montreal Convention applicable to international carriage by air in
Nigeria. Section 48 (1) provides as follows:
“The provisions contained in the Convention for the Unification of certain rules relating to International Carriage by Air signed at Montreal on 28th May, 1999 set out in the Second Schedule of this Act and as Amended from time to tune, shall from the commencement of this Act have force of law and apply to international carriage by air to and from Nigeria, in relation to any carriage by air to which those rules apply irrespective of the nationality of the aircraft performing the carriage, and shall, subject to the provisions of this Act, govern the rights and liabilities of carriers, passengers, consignors, consignees and other persons.”
b. Carriage by Air
(Non-International Carriage) (Colonies, Protectorates and Trust Territories)
Order 1953
The Warsaw Convention
was made applicable to non-international carriage/flights in Nigeria by
virtue of the Carriage by Air (Non-International Carriage) (Colonies,
Protectorates and Trust Territories) Order 1953.See Kabo v. Oladipo
(2000) 4 KLR (Pt.102) 1413. However, by virtue of Section 48 (2) of
the Civil Aviation Act, 2006 as from the date of commencement of the Act
the Montreal Convention shall apply to non-international carriage by air
within Nigeria. For ease of reference Section 48 (2) of the Act is
reproduced below:
“The provisions contained in the Convention for the Unification of Certain Rules Relating to international Carriage by Air signed at Montreal on 28th May, 1999 has been modified and Set out in the Third Schedule of this Act and as amended from time to time, shall from commencement of this Act have force of law and apply to non‐international carriage by air within Nigeria, irrespective of the nationality of the aircraft performing the carriage and shall subject In the provisions of this Act, govern the rights and liabilities of carriers, passengers, consignors, consignees and other persons.”
c. Civil Aviation
Act, 2006
The Montreal Convention
was incorporated into Nigerian law by virtue of Section 48 of the
Civil Aviation Act, 2006 and from the date of commencement of the Act, the
Montreal Convention became the basis for establishing of an airline’s liability
for both international and non-international carriages or flights in
Nigeria. See Section 48 (1) and (2) Civil Aviation Act, 2006;
Emirate Airline v. Tochukwu Aforka & Anor. (2014)
LPELR-22686(CA).
It is instructive to note
that, the Montreal Convention prevails over any rules, which apply to
international carriage, by air including the Warsaw Convention. See Article
55 of the Montreal Convention. In Nigeria, Civil Aviation Act,
2006 domesticated the Montreal Convention by repealing the
Carriage by Air (Colonies, Protectorates and Trust Territories) Order, 1953
which domesticated the Warsaw Convention.
The Act also domesticated
other international treaties to which Nigeria is a party, including
(among others) the Chicago Convention 1944 and the Cape Town
Convention 2001.
d. Conflict between
International Laws and Domestic Aviation Laws
The Montreal Convention and
other Conventions to which Nigeria is a signatory are international treaties,
international agreements and compromise principles, which the high contracting
States have submitted to be bound by the provisions. They are therefore an
autonomous body of law whose terms and provisions are above domestic
legislation. Thus, any domestic legislation in conflict with the Conventions is
void.
The law is that, where
domestic/common law right has been enacted into a statutory provision, it is to
the statutory provision that resort must be had for such right and not the
domestic/common law. Hence, an air passenger is not at liberty to choose as
between the provisions of the convention and the domestic/common law for claims
for damages against the carrier. Such claims have to be asserted only in
accordance with and subject to the terms and conditions of the convention and
cannot be pursued under any other law. Cameroon Airlines v. Abdulkareem
(2003) 11 NWLR (pt.830) 1; El Al Israel Airlines Ltd. v. Tseng 919 F. Supp 155
S.D.N.Y. 1996 ; Sidhu v. British Airways (1997) 1 All ER 193; Air France v. Saks
105 S.C. 1338 470 U.S., 392 84 L.Ed 2d 289 (1985).
B. Contract of
Carriage by Air
1. Contract between
Airline Carriers and Passengers
On the purchase of airline ticket,
by a passenger, a contract is established between the passenger and the
airline. See: Cameroon Airlines v. Mr. Mike Otutuizu (2011)2 KLR
(Pt.291) 373. An airline or carrier of passenger by air is under a duty to
deliver a passenger ticket to a passenger which shall contain the following
terms or particulars:
a) The place and
date of issue;
b) The place and
date departure and destination;
c) The agreed
stopping places, provided that the carrier or airliner may reserve the right to
alter the stopping places, in case of necessity;
d) The name and
address of the airline or carrier; and
e) A statement that
the carriage is subject to the rules relating to liability established by the
Convention.
An airline or carrier is also under
a duty to deliver a luggage ticket for luggage other than “hand
luggage”.
2. Contract between
Consignors and Consignees
Under the Convention, the air
waybill or the cargo receipt is prima facie evidence of the conclusion of
the contract, of the acceptance of the cargo and of the conditions of carriage
mentioned therein. The air waybill or the cargo receipt shall
include:
a) an indication of the places of
departure and destination;
b) if the places of departure and
destination are within the territory of a single State Party, one or more agreed
stopping places being within the territory of another State, an indication of at
least one such stopping place; and
c) an indication of the weight of
the consignment.
3. Breach of
Contract of Carriage by Air
a. Alteration of
Route
Where the agreed route is altered,
it amounts to a breach of contract, unless there is justification for such
alteration. In the case of Cameroon Airlines v. Mr. Mike Otutuizu (supra),
Mr. Otutuizu desired to travel from Lagos to Manzini, Swaziland on a
business trip, he bought two tickets endorsed with the agreed stopping
places. The tickets were routed as follows: Exhibit A. The flight shall commence
from Lagos, Nigeria, with stops in Doula, Cameroon, and then on to Harare.
Zimbabwe. Exhibit B is from Harare to Manzini and back to Harare.
Contrary to the agreed route, the airline carried Mr. Otutuizu though South
Africa. As he had no visa for South Africa to the knowledge of the airline, he
was arrested and detained. His $20,000 was taken by Immigration Officials. He
was subsequently deported to Lagos. There was no evidence before court that
there was any reason to deviate from the agreed stopping places. The court held
that, in the absence of justification for flying to Johannesburg, South Africa,
there is a clear breach of contract since Mr. Otutuizu was never flown to
Manzini, Swaziland.
The trial court found that breach of
contract was established by the respondent who was awarded the sum of N80,
000.00 being the value of the tickets and N500,000:00 general damages but
declined to award the sum of $20,000.00 claimed by the respondent. The Court of
Appeal confirmed the awards made by the trial court and in its wisdom, awarded
the respondent the sum of $20,000:00 as claimed by the passenger. The Supreme
Court affirmed the judgment of the High Court as affirmed by the Court of
Appeal.
b. A Transit
Visa
A transit visa is issued to a
passenger by a country through which a plane would fly/land enroute the final
destination. Transit visa is not issued by the country in which the passenger's
journey terminates. It is true that it is the duty of the passenger to get a
transit visa, and it is also the duty of the airline to refuse to take a
passenger on board who has not got a transit visa.
Airlines insist on passengers
having transit visas, but that only applies if the airline informs the passenger
on the stops that would be made before the final destination of the aircraft,
(and in effect the passenger). Cameroon Airlines v. Mr. Mike Otutuizu
(supra)
C. Liability of
Airline Carrier
1. An airline's liability to its
passengers or customers could arise as a result of:
a) Injury sustained on board an
aircraft or
b) Death arising from the course of
a journey or
c) Damage or loss of goods
d) Delayed or denied boarding
or
e) Interactions in the course of
preparing for or the actual conduct of flight operations.
See Harka Air Services
(Nig.) Limited v. Keazor Esq. (2011) 6 KLR (Pt.298) 1771 at 1786,para. A, per
Adekeye, J.S.C
2. The Liabilities for
the carrier are contained in Articles 17 to 30 of Montreal Convention which is the applicable Convention in Nigeria on the subject of illumination and
the subject of the references in this Legal
Illumination.
a. Liability for
Death or Injury of the Passenger on Board an Aircraft (Articles 17 and
21):
Under the Aviation Law, an
aircraft accident is an occurrence associated with the operation of an aircraft
which takes place between the time any person boards the aircraft with the
intention of flight until such time as all such persons have disembarked in
which a person suffers a fatal or serious injury as a result of being in the
aircraft. See:Annex 13 to the Chicago Convention, dealing with Aircraft
Accident and Incident Investigation and Harka Air Services (Nig.) Limited
v. Keazor Esq. (supra) at page 1786, paras. B-C.
Advance Payments: In
any case of aircraft accident resulting in death or injury of passengers the
carrier shall make advance payments of at least US $30,000.00 (thirty
thousand United States Dollars) within 30 (thirty) days from the date
of such accident to the natural person or such natural persons who are entitled
to claim compensation in order to meet the immediate economic needs of such
persons and such advance payments shall not constitute recognition of liability
and may be offset against any amounts subsequently paid as damages by the
carrier. Section 48 (3) of the Civil Aviation Act, 2006
and Article 28.
The Montreal Convention
eliminated the limits of liabilities set in the Warsaw Convention by introducing
a two-tiered liability regime in cases of death or injury to the
passenger on board an aircraft:
i. In Nigeria, where
the claims of the victim does not exceed 100,000 USD, the carrier
shall not be able to exclude or limit its liability.
ii. Where the claim
exceeds 100,000 USD the liability of the air carrier is unlimited except
there is evidence that the death or injury was not as a result of the
negligence or wrongful act or omission of the carrier or its agent or was
solely due to the negligence or other wrongful act or omission of a third
party.
b. Liability for
Delay in the Carriage of Persons:
The liability of the carrier
to each passenger in respect of damage caused by delay is limited to 4150
USD. (Article 22, Paragraph 1)
c. Liability for
Carriage of Baggage:
The liability of the carrier in the
case of destruction, loss, damage or delay of baggage is limited to 1000
USD. (Article 22,Paragraph 2)
The liability of the carrier
in respect of damage suffered by a passenger caused by delay or destruction,
loss, damage or delay of baggage will be unlimited, if it is proved that
the damage resulted from an act or omission of the carrier, its servants or
agents, done with intent to cause damage or recklessly and with knowledge
that damage would probably result; provided that in the case of such act or
omission of a servant or agent, it is also proved that such servants or agents
was acting within the scope of its employment. Paragraph 5 of
Article 22.
d. Liability for Carriage of
Cargo:
i.Undeclared
Interest:
The liability of the carrier in the
case of destruction, loss, damage or delay in the carriage of cargo is limited
to 20 USD per kilogram, if the value of the cargo is not declared at the
time when the package was handed over to the carrier (Article 22, Paragraph
3)
It is instructive to note that, paragraph 5 of Article 22 of the Montreal Convention excludes
paragraph 3, which deals with liability in the case of carriage of cargo.
The clear intention to exclude carriage of cargo is confirmed by Article 30
which deals with actions brought against a servant or agent of the carrier,
who are also entitled to the limits of liability under the Convention just as
the carrier, thus in the case of Emirate Airline v. Tochukwu Aforka &
Anor. (2014) LPELR-22686(CA) per Iyizoba, J.C.A. held that “from the
exclusion of negligence and willful misconduct in the case of carriage of cargo
in article 22 (5) and Article 30 (3) I am of the firm view the Montreal
Convention did not intend that those concepts should affect the limitation of
liability with respect to carriage of cargo” and held further at
pages 28-30, paras. E-C, that, the learned trial Judge was wrong in holding
that there was no limitation of liability because the appellant was unable to
rebut the presumption of negligence or the doctrine of res ipsa
loquitor. Iyizoba, J.C.A. illuminated at pages. 33-34, paras.
B-C that:
"The concept of negligence or willful misconduct obviously cannot work in the case of loss of cargo. It is difficult to prove willful misconduct as the Plaintiff is not in a position to know how the loss came about and no help is likely to come from the carrier in that regard. That must be why carriage of cargo was excluded in the provisions. It appears the position may have been different under the Warsaw Convention because there are decided authorities where negligence and willful misconduct were considered in cases of loss of cargo.”
ii. Special
Declaration of Interest
The only way to escape the
limitation of liability with respect to damage or loss of cargo is where the
consignor at the time when the package was handed over to the carrier made a
special declaration of interest in delivery at destination and has paid a
supplementary sum if the case so requires. In that situation, the carrier
will be liable to pay a sum not exceeding the declared sum. Unless it proves
that the sum is greater than the consignor's actual interest in delivery
at destination.
In interpreting what constituted a
special declaration in the case of Emirate Airline v. Tochukwu Aforka & Anor. (supra) his Lordship Iyizoba, J.C.A. held at page 35-36
that:
“It is my view that the special declaration envisaged in Article 22(3) means more than just presentation of the sales invoice and the packing list. The declaration of value ought to be in writing on the airway bill. DW1 in Re-examination had stated categorically that they rely on the Airway Bill and that no value was declared on it. In the case of Rembrandt Jewellery v. Air Canada (1985) O.J. No. 1382, it was held that a verbal statement of value made on the telephone is not a special declaration of value within the meaning of the convention. There is consequently no convincing evidence that the Respondent made a special declaration of the value of the goods. The limitation of liability as contained in the Montreal Convention and the Conditions of Carriage of Cargo of the Defendant is applicable in the circumstances of this case.”
e. Destruction,
Damage or Loss that Occurs while a Baggage or Cargo is in the Charge of the
Carrier.
Article 18 (3) provides
that the carriage by air within the meaning of paragraph (1) of
Article 18 comprise of the period during which the cargo is in the charge
of the carrier. The fact that the cargo has not been air lifted is consequently
of no moment. Once the carrier has taken control of the cargo and issued the
airway bill, any loss from then on is covered by the Convention and the
limitation of liability clause subject to the stated exceptions as provided in
the Convention. Emirate Airline v. Tochukwu Aforka & Anor.
(supra)
f. Conversion of
Monetary Units
The liability sums mentioned
in Articles 21 and 22 shall be converted to Naira at the existing
official exchange rate. Article 23.
g. Review of Limits
of Liability by the Minister of Aviation
The Minister of Aviation is
statutorily empowered by Article 24 to review the limits of liability prescribed
in Articles 21, 22 and 23 upon the advice by the Nigerian Civil Aviation
Authority at seven year intervals, the first of such review is to take place at
the end of the seventh year following the date of entry in force of the Civil
Aviation Act, 2006.
h. Higher or No
Limits Clause
A carrier may stipulate that,
the contract of carriage shall be subject to higher limits of liability than
those provided for in the Convention or to no limits of liability whatsoever.
Article 25.
i. Lower or
Exemption from Liability Clause
Any provision tending to
relieve the carrier of liability or to fix a lower limit than that which is laid
down in this Convention shall be null and void, but the nullity of any such
provision does not involve the nullity of the whole contract, which shall remain
subject to the provisions of the Convention. Article
26.
j. Punitive,
Exemplary or any other Non-Compensatory Damages
In the carriage of passengers,
baggage and cargo, any action for damages, however founded, whether under the
Convention or in contract or in tort or otherwise, can only be brought subject
to the conditions and such limits of liability as are set out in the Convention
without prejudice to the question as to who are the persons who have the right
to bring the suit and what are their respective rights. In any such action,
punitive exemplary or any other non-compensatory damages shall not be
recoverable. Article 29 - See Emirate Airline v. Tochukwu Aforka & Anor.
(supra) pages 49-50, paras. A-A ,per Augie,
J.C.A.
k. Receipt of
Baggage or Cargo without Complaint
The receipt by the
person entitled to delivery of checked baggage or cargo without complaint
is prima facie evidence that the same has been delivered in good condition and
in accordance with the document of carriage. Article
31.
l. Time within which
to make Complaints
In the case of damage, the person
entitled to delivery must complain in writing to the carrier forthwith
after the discovery of the damage, and, at the latest, within:
a) two days from the date of
receipt in the case of checked baggage;
b) seven days from the date
of receipt in the case of cargo; and
c) fourteen days from the
date on which the baggage or cargo have been placed at his or her disposal, in
the case of delay.
If no complaint is made within the
times prescribed, no action shall lie against the carrier, save in the case of
fraud on its part.
3. Avoidance of
Liability
An airline carrier can avoid or
escape liability under or in the following circumstances:
a. Defence
of Due Diligence: A carrier shall not be liable for damage occasioned by
delay if it proves that it and its servants and agents took all measures
that could reasonably be required to avoid the damage or that it was
impossible for it or them to take such measures. Article
19.
b. Contributory
Negligence: Where the damage, death, or injury was caused or contributed to
by the injured or dead person's negligence. The carrier shall be wholly or
partly be exonerated from its liability to the claimant to the extent that such
negligence or wrongful act or omission caused or contributed to the damage or
death. Article 20.
c. Effluxion of
Time: The right to damages shall be extinguished, if an action is not
brought within a period of two years, calculated from the date of arrival
at the destination, or from the date on which the aircraft ought to have
arrived, or from the date on which the carriage stopped. See Article 35 ;
Ibidapo v. Lufthansa Airlines (1997) 4 NWLR (Pt. 498)124 at
161.
4. Unlimited
Liability of Carrier
There are situations in which a
passenger will be entitled to damages for breach of contract of carriage by an
airline more than the limit set under the Convention , these situations include
:
a. Willful
Misconduct :
In the case of: Harka Air
Services (Nig) Ltd. V. Keazor (2011) 13 NWLR (Pt.1264) 320 at 342,para. A; 360
H. His Lordship, Rhodes-Vivour, JSC stated at page 364 C – D,
that:
"Willful misconduct is a deliberate wrong act by a pilot airline staff or its agent which gives rise to a claim for damages by passengers. When staff of an airline act with reckless indifference. Such unacceptable behaviour especially by a professional person amounts to willful misconduct."
A carrier shall not be
entitled to avail itself of the provisions of paragraphs 1 and 2 of Article
22 which exclude or limit its liability, if it is proved that the
damage resulted from an act or omission of the carrier, its servants or agents,
done with intent to cause damage or recklessly and with knowledge that damage
would probably result; provided that, in the case of such act or omission of a
servant or agent, it is also proved that such servant or agent was acting
within the scope of its employment. Article 22
(5).
Where the breach occasioning
loss is as a result of willful misconduct by a carrier, it loses its entitlement
to rely on statutory limitation of liability.In Cameroon Airlines v.
Mr. Mike Otutuizu (2011)2 KLR (Pt.291) 373, it was held that the carrier
committed willful misconduct, thus the respondent was entitled to more damages
than the limit set in Article 25 in the Warsaw Convention now
Article 22 (1) and (2) in the Montreal
Convention.
In the case of Oshevire v.
British Caledonia Airways Ltd. 1990 7 NWLR 507, it was held that where a
parcel containing valuable cargo is stolen as a result of concerted action taken
within the scope of their employment by one or more employees of the carrier who
also most probably stole the documents, the plaintiff would be entitled to more
damages than the limit in Article 22, since the carrier had committed
willful misconduct. The court held further that, in all other cases spelt out
in the Convention the limits on liability must be followed but where there is
breach of contract of such a magnitude that it amounts to a willful act, a
willful misconduct the limits are no longer applicable.
5.
Jurisdiction
An action for damages must be
brought, at the option of the Claimant , either :
a. before the court of the
domicile of the carrier ; or
b. of its principal place of
business; or
c. where it has a place of
business through which the contract has been made or before the court at the
place of destination.
In respect of damage resulting
from the death or injury of a passenger, an action may be brought
before:
a. one of the three courts mentioned
in above ; or
b. in the territory of a State Party
in which at the time of the accident the passenger has his or her principal and
permanent residence and to or from which the carrier operates services for the
carriage of passengers by air, either on its own aircraft, or on another
carrier’s aircraft pursuant to a commercial agreement, and in which that carrier
conducts its business of carriage of passengers by air from premises leased or
owned by the carrier itself or by another carrier with which it has a commercial
agreement.
In Nigeria, the Claims for
damages under the Montreal Convention can only be made in the Federal High
Court which in Nigeria has exclusive jurisdiction over Aviation related
causes of action. See Section 251 (1) K of the Constitution ; Article
33.
Conclusion
All is well that ends well,
an air carriage that, ends in the delay,damage or loss
of baggage/cargo or death or injury of airline passengers cannot be said to
have ended well. Given the fact that, the right to compensation or damages for delayed,damaged or lost baggage/cargo or death or injury of an airline passenger has a time limit,it is advisable
that, the affected passenger,consignor or victim promptly consult with a lawyer
sound in aviation law.
Akintunde
Esan, Legal Practitioner/Consultant, Legal Blogger and Chartered Mediator -
Managing
Partner,Ase Olodumare
Chambers.
For further illuminations on the
right of an airline passenger or consignor in Nigeria to compensation or damages
for the delay,damage or loss of baggage/cargo or death or injury of passenger on
board , you are advised to contact Akintunde Esan.
AVIATION LAW: REMEDIES FOR DELAYED,DAMAGED OR LOST BAGGAGE /COMPENSATION FOR DEATH OR INJURY OF AIRLINE PASSENGERS IN NIGERIA is a legal illumination of AKINTUNDE ESAN known as The LEGAL ADVISER ONLINE. Akintunde Esan is the Managing Partner & Principal Consultant @ ASE OLODUMARE CHAMBERS (Legal Practitioners/Consultants & Chartered Mediators)
