Reviewed Article 57 EVALUATING THE ROLE OF A NON-DOCTRINAL LEGAL RESEARCH METHOD ON LEGAL EDUCATION AND PRACTICE IN COMMON LAW AFRICA: NIGERIA AS A CASE STUDY Emeke N. Chegwe, Department of Public Law, Taraba State University, Nigeria Michael A. Akatugba, Faculty of Law, Delta State University, Nigeria* This study was sponsored by the management of Taraba State University, P.M.B.1167, Jalingo-Nigeria, with the fund provided by the Tertiary Education Trust Fund (TETFUND) of Nigeria ABSTRACT This paper presents the results of a study examining the relationship between a non- doctrinal legal research method (NDLRM) and the quality of legal education and practice, with a view to determine the reason for the increasing poor quality of law graduates from common law African countries. Consequently, in this study, faculties of law offering NDLRM in Nigerian universities were investigated as a case study and the challenges of doing so. To achieve the objective of this study, an experimental research design was formulated. Interviews were conducted and a NDLRM challenges questionnaire developed and administered amongst a selected population * The authors appreciate the technical support of Adeniji Adewale Taiwo of the Federal University Oye-Ekiti Nigeria, who analysed the data. 58 of law teachers and law students across the six geo-political zones of Nigeria. Data collected from the respondents were analysed using descriptive statistics. The results of the analysis showed a positive co-relationship between NDLRM and legal education and practice. Law students were not taught NDLRM in Nigerian universities and their teachers were not taught NDLRM as students in Nigerian Universities. In the conclusion of this paper, compulsory training on inter-disciplinary research for all law teachers in Nigeria was recommended. Further, the provision of adequate funding for research in all faculties of law and adequate training facilities such as smart boards and software for teaching empirical research in all law faculties should be a priority. KEY WORDS: Non-Doctrinal, Legal Research, Impact, Education, Nigeria. Introduction This paper is structured as follows. It begins with an introduction in part one. Part two consists of a brief explanation of the history of legal education in Africa, including the quality of African law graduates, which forms the research background, and provides justification for the research area. Parts three, four and five constitutes the research methodology, explains the choice and implementation of data collection methods, sampling aspects of the study and discussions of ethical considerations. Part six provides a review of the literature review before presenting the primary data 59 collected and facilitated through tables in part seven. The paper continues to the discussion and analysis of these data in part eight before conclusions are drawn and recommendations are presented. Historical Background to Legal Education in Africa The idea that law students may need formal instruction in legal research may meet with little argument today from law librarians, practising attorneys and even some law faculties. Yet, a century ago, it was considered revolutionary. Lawyers and law teachers of the early 1990s were not far removed from the time when a lawyer was expected to own or be familiar with all the materials needed for the practice of law. As legal issues became more complex and the quantity of legal materials increased, formal instruction for lawyers became accepted, and attending a law school became a primary method of preparing for a legal career. In Nigeria (see Chegwe 2016), Kenya and South Africa, prospective lawyers of the pre- independent era did not attend university but were trained, apprentice-style, and learned whatever they knew about legal research by familiarising themselves with all the materials needed for the practice of law, and nothing else. For example, until 1945, lawyers trained in Britain had no law degree, let alone knowledge of empirical legal research. No British university was offering a law degree at that time (Ojukwu 2013). To qualify as a barrister, a person needed to join one of the four inns of court (law 60 chambers), read for the Bar exam, keep 12 compulsory dinner terms and be called to Bar – all without necessarily obtaining a law degree (Fabunmi & Popoola 1990). This and other challenges inherent in British trained lawyers led to the establishment of the Unsworth Committee by Nigeria in 1959 (Elias 1965) and the Lord Denning Committee of Kenya in 1960 (Okere 2009). Based on the recommendation of these Committees, the University of Nigeria, Nsukka established the first Faculty of Law in 1962 while the Lord Denning Committee in Kenya recommended the establishment of a Law School in Dar-as-Salaam to serve East Africa. The development of legal education in Zambia followed a similar pattern. Legal education commenced in 1966 (Chipasha 2018) with the establishment of University of Zambia as the only institution offering a degree programme in law until the monopoly was broken in 2006. Since 2006, various public and private universities have emerged offering law programmes at degree levels. Prior to this period Zambian lawyers were trained apprentice-style like their Nigerian colleagues. Expressing the desirability of university legal education to apprentice-style legal education, (Chipasha 2018, 2) espoused: Legal education has a fundamental part to play in society. Excellence in legal education helps to shape the quality of the rule of law while the experiences it offers to future lawyers are invaluable. Primary among them is exposure to a wide range of legal subjects that are essential in the practice of law. It also offers law students a supervised, 61 rigorous and disciplined opportunity to learn practical legal skills through clinics, trial practice and negotiation courses amongst others. This represents a superior way to compensate young lawyers who are often confined to run the errands of established lawyers who are often too busy to teach these young lawyers. In a nutshell, legal education is a form of human science that offers beyond techniques, skills and competencies, basic philosophies, ideologies, critiques, and instrumentalities, all addressed to the creation and maintenance of a just society.”1 Quality of African Law Graduates Most countries now operate two stages of legal education for prospective members of the legal profession namely a university legal education and a vocational/professional legal education. University legal education consists of four to five-years of study in the law faculties of designated universities, during which law students are exposed to theoretical knowledge of legal norms, principles and other inter-related disciplines leading to the award of a bachelor of law (LLB) degree which qualifies the law student to be admitted to the second stage of legal education. The second stage involves one to two years of practical training for aspiring legal practitioners. Since the LLB degree is the only academic qualification 1 For a comparative analysis of systems of legal education in Africa, see Okere (1990), ‘The Legal Education in Kenya’ Journal of African Law 33(1) 78-90. 62 required to practice law, the quality of university legal education directly affects the quality of legal practice. There is a general consensus amongst legal academic and practising attorney communities on the dwindling quality of law graduates from former common law countries.2 In Nigeria for example, efforts to maintain the standard of legal education remain problematic despite the threat of withdrawal of accreditation of many Law Faculties by the Council of Legal Education. Various reasons have been adduced for the situation. Idem and Halimat (2019) blames the falling standard of law graduates in Nigeria on over population of students, lack of adequate funding, lack of curriculum synergy between the faculties and the Nigerian Law School, inadequate teaching facilities, and indiscipline on the part of students who are often distracted by social media, resulting on shorter attention span which rubbed students of the benefit of actual study to assimilate as they now merely memorise. They recommended that the Council of Legal Education, in the exercise of its regulatory powers must review its current accreditation system to ensure that prescribed standards are maintained across the two levels of legal education. Collaborations should also be reached with international law societies and legal bodies such as the African Bar Association and 2 See generally, Thomas F. Geraghty and Emmanuel K. Quansah, “African Legal Education: A Missed Opportunity and Suggestions for Change: A Call for Renewed Attention to a Neglected Means of Securing Human Rights and Legal Predictability” Loyola University Chicago International Law Review, (2007) Vol.5, Issue 1: Samuel O. Manteaw “Legal Education in Africa: What type of Lawyer Does Africa Need” University Of The Pacific Mcgeorge Law Review ((2016) Vol.39, Issue 4:Okechukwu Oko,“Legal Education Reform In Africa: Time to Revisit the Two-tier Legal Education System” University of Miami International and Comparative Law Review, (2021) Vol. 29,Issue 1. 63 the International Bar Association, who can help in ensuring the sustenance of global benchmark (Idem and Halimat 2019). There is a similar concern in the quality of law graduates in South Africa. Franny (2022) reports how the South African Law Deans Association recommended a five- year degree programme as replacement for the four-year degree introduced in 1998 pursuant to the Legal Practitioner’s Amendment Act 78 of 1997. Though the anti- apartheid reason for the introduction of the programme was justified, the four-year degree did not only reduce the quality of the degree, but more than 75 per cent of the students did not finish the programme within four years. According to Franny (2022, 2), the recommendation was based on research “including the findings that only 35% of LLB students actually graduate within five years and that, of all those who register at tertiary level, only 55% ever graduate at all”3. Types of Legal Research The study of law could either be doctrinal or non-doctrinal. Doctrinal Research Doctrinal research involves analysis of case law and statutory provisions, arranging, ordering and systematising legal propositions and the study of legal institutions through legal reasoning or rational deduction. Doctrinal research involves research 3 The recommendation was made in January 2014 by Campbell. 64 into law as a normative science which, as Gain (1975) identifies, lays down norms and standards for human behaviour in a specific situation or situations through the sanction of the State. It is this normative character that distinguishes law from other related disciplines of the social sciences (Myneni 2017). Doctrinal research is regarded as speculative in the sense that the various viewpoints which are admissible within it cannot be empirically verified (Gasiokwu 2014). According to Salim et al (2017), the main advantage of library or ideological research as they choose to call doctrinal research is that it saves time: “…the busy practitioner tends to be concerned with the law ‘as it is’ and rarely has the time to consider research that does not fit within that paradigm and timeframe”. The disadvantages of doctrinal research are that it is very narrow and restricts the choice and range of topics which increasingly withdraws the legal profession from the greater social context (Salim et al 2017). Non-Doctrinal Research Non- doctrinal, such as socio-legal, research is research into law in the context of other inter-related or dependent factors. It facilitates examination of the relationship between law and other behavioural sciences. Of course, while most laws are found and developed in legal texts, they do not operate in vacuum. They influence and are influenced by social values, attitudes and ethos. An investigation into the dynamics of such a complex phenomenon involves the collection of data outside the conventional legal sources. This type of research usually involves field work. In most developing 65 countries including Nigeria, doctrinal research constitutes the dominant research approach while non- doctrinal research techniques are unfortunately regarded as subversive by most law teachers; while others believe that such approach represent the indulgence of those who do not understand what the study of law truly entails (Gasiokwu 2014). Problem Statement Law students, unlike students in the social sciences, are often unable to present dissertations in their chosen area of law as required in partial fulfilment of their law degrees. They are not provided the training necessary to undertake empirical research, at least with the necessary level of sophistication. After graduation, lawyers are unable to undergo a transformation from passive consumer of academic knowledge into active co-producers of societal reform. This situation also has cyclical effects on the quality of legal practice in Nigeria. Hence, this study on non- doctrinal legal research addresses the practical evidential gap created by pure doctrinal research. Research Objectives 66 The specific objectives of this study are as follows: • Determine how many universities in Nigeria teach a non-doctrinal legal research method. • Determine the challenges of teaching a non-doctrinal legal research method in Nigerian universities. • Determine the relationship between a non- doctrinal legal research method and the quality of legal education and practice in Nigeria. Research Questions In accordance with the above objectives, the following research questions are addressed in this study: • Do universities in Nigeria teach a non-doctrinal legal research method? • What are the specific challenges of teaching non-doctrinal legal research? • Does a non-doctrinal legal research method impact the teaching and practice of law in Nigeria? Literature Review 67 According to Everwijn, G. et al (1993), ability or competence-based education is the only way of bridging the gap between knowledge acquisition and the ability to apply same. The ultimate goal of legal education should be to teach students to apply that same knowledge. Discipline specific knowledge and skills are, singularly, insufficient to enable the lawyer to respond adequately in a situation of discipline transcending (inter-disciplinary) knowledge and problems.4 Solomon (2017), who was interested in improving the quality of legal education in Nigeria, recommends skill in effective legal research report writing, with the general assumption that prior legal research has been effectively and methodologically conducted. Knowledge acquired as a fundamental requirement of every enterprise should be adequately transferred and prudently applied for solving societal problems. Legal knowledge is transferred and acquired through legal education. Solomon (2017, 1) examined how to write an effective legal research report and identifies lack of empirical research methods, especially at the undergraduate level, as a major impediment on the aptitude and quality of legal writing by the country’s legal academics, as well as judges, legal draftsmen and law advocates. Further, Solomon criticised the system of legal education in Nigerian universities for its inefficient pedagogy, focusing more on pure theories of “substantive law without the sufficient application of skills” as well as the deficit in teaching and research facilities in the law faculties of Nigerian universities. It is worth noting, however, that there was no 4 In the last decade the National University Commission, (Nigerian university regulatory body), recommended a compulsory diploma certificate in education for every university teacher in Nigeria, including law teachers, but the policy was not followed through. 68 statistical data presented on which the author could rely when arriving at this conclusion. Becher’s work (1981) on the quality of research by law teachers continues to represent an accurately deleteriously account of how academic lawyers are viewed by their counterparts in the social sciences. Accordingly, academic lawyers are regarded as not really academic, arcane, distant, alien, an appendage to the academic world. They are sometimes vociferous, untrustworthy, immoral, narrow and arrogant. Their research fares no better in this assessment, dismissed as it is as being unexciting, uncreative, and comprising a series of intellectual puzzles scattered amongst large areas of decryptions. Empirical facts impact positively on legal scholarship and legal research. For example, there are existing rules of evidence in many jurisdictions such as Australia and the United States (Burns and Hutchinson 2009) allowing for a formal use of empirical data within the doctrinal analytical framework. In Nigeria for example, courts are required to apply the doctrine of judicial notice and other provisions of the Evidence Act5. However, these existing rules of evidence do not appear to adequately cater for the wide variety of ways in which empirical facts are utilised in judicial decisions. The way these materials find their way into judges’ decisions appears to primarily rest upon judicial discretion and when they are used, social science materials relevant to empirical fact assumptions are not always adequately acknowledged by judges. The 5 See Section 18(3) Evidence Act 2011 Laws of the Federation of Nigeria (LFN) 2011. 69 recognition of the judicial use of empirical facts as part of judicial reasoning raises the need for new approaches to legal research and legal research training based in the social sciences. It suggests that lawyers need better training in non-doctrinal methodologies. The evolution of legal education in Nigeria seems to have negatively impacted the nature and quality of legal research that is carried out in Nigerian Universities. There is currently no empirical data on non-doctrinal legal research in Nigerian universities. The result of this study will be of benefit to other researchers and policy makers especially the National Universities Commission (NUC), aiming to improve the quality of legal education and practice in Nigeria. Methodology of the Research Population and Sample. Due to practical constrains, a sample of the population consisting of eighteen universities selected across the six geo-political zones was studied. The selected numbers were extracted using the probability sampling techniques. The research participants consist of law teachers and students in different levels of undergraduate studies. Few Post graduate students also formed part of the studied population. For ethical reasons, the names of the universities are not disclosed. 70 Method of Date Collection Instrumentation Data was collected using a questionnaire instruments and interviews. The questionnaire instrument adopted a Likert 5-point rating scale (ordinary scale), with response options ranging from “To a very great extent”, to “to a small extent”. The instrument consisted of two sections. Section A provided demographic information, while section B extracted response on the impact of empirical legal research training on the learning and teaching of law in Nigerian universities. Method of Data Analysis The data collected from the respondents were coded and analysed, and presented in Tables 1, 2, 3 and 4. The demographic data was analysed using descriptive statistics. Responses to the copies of the instrument was tallied on a five-point scale, and the null hypothesis processed with the appropriate computer statistical packages for social sciences (SPSS). Results and Discussions The information sourced from the respondents was subjected to descriptive and inferential statistics. The demographic characteristics of the respondents presented in 71 Table 1 showed the majority (54.55%) of the respondents are within the age bracket 31 to 40 years indicating that the respondents are young and qualified to provide information on the subject matter. Next to this age bracket are respondents within the age group 20 and 30 years. A majority of the respondents are male, accounting for 64.5% of the respondents. A majority (81.18%) of the respondents had undergraduate qualifications while the remainder are those with postgraduate qualification in law. The Chi square goodness-of-fit test showed that the classes for age distribution, gender and educational attainment were significantly different from each other at a 0.01 level of probability. Table 1: Demographic and institutional characteristics of the respondents Age Frequency Percentage (%) Degree of freedom Chi square 20 - 30 years 60 27.27 3 42.56 31 – 40 years 120 54.55 41 – 50 years 30 13.63 50 years > 10 4.54 Total 220 4.54 Gender Male 142 64.5 1 51.11 Female 78 35.45 Total 220 Educational attainment Undergraduate 180 81.81 1 60.21 72 Postgraduate qualification 40 18.18 Information on the preponderance of non-doctrinal legal research in the universities surveyed is presented in Table 2. Findings showed that the majority of the lecturers and students were unaware of non-doctrinal legal research training. The respondents indicated that they had not registered for, nor attended, courses in non-doctrinal legal research at undergraduate and postgraduate levels. This observable data demonstrates the reason Nigerian law undergraduates were unable to carry out non- doctrinal legal research of their own as law students and their inability to impact same as teachers. Also, the respondents who were taught doctrinal legal research during the 400 level, followed 100, 200 and 300 levels. However, 10% of the respondents indicated that non-doctrinal legal research was taught in their university for a period spanning 5 and 10 years (10%) while 90% of the respondents indicated otherwise. The 10% who were taught using non-doctrinal legal research studied abroad during their undergraduate degrees. The Chi square goodness-of-fit test showed that the variables tested were significantly different from each other at 0.01 level of probability. Table 2: Preponderance of non-doctrinal legal research in the universities Variables Frequency Percentage (%) Degree of freedom Chi square 73 Are you aware of empirical law research Yes 80 36.35 1 43.11 No 140 63.64 Total 220 Have you been taught or took courses in non- doctrinal legal research in the university Yes 30 13.63 1 56.24 No 190 86.36 Total 220 At what level in the university were you taught non- doctrinal legal research 100 level 1 0.45 5 62.18 200 level 1 0.45 300 level 1 0.45 400 level 27 12.27 500 level 00 0.00 Not at all 190 86.36 Total 220 For how long has non- doctrinal legal research being taught in your 74 university Not at all 200 90 86.11 1 5 – 10 years 20 10 15 years > 0 00 Total 220 Challenges of Empirical Legal Research in Nigerian Universities The information received through the survey on the challenges of empirical legal research was subjected to a four-point Likert scale test, with a mean of 2.00±0.50 declared as important. The challenges faced in the teaching of non-doctrinal legal research in Nigerian universities are presented in Table 3. Findings indicate that the lecturers were not taught non-doctrinal legal research during their training in the universities, and this had direct and severe effects on legal research at university. This is based on the premise of the total score of 3.44 out of 4.00. There is an assumption in certain quarters that non-doctrinal legal research is not necessary (Gasiokwu 2014). This investigation equally acknowledged the existence of phobia for mathematics and statistics by law respondents. There is also the challenge of inadequate time devoted to the study of research methodology in Nigerian law faculties. Unlike other regions such as the United States where legal research and writing are integral parts of the student’s curriculum (Booth, 2009), legal research is offered only in the fourth year of a five-year program in Nigerian universities. Law students are therefore unable to 75 grapple with the rudiments of research methodology, data collection and analysis in time to adequately prepare for their long research essays at 500 level of study, with the consequence that law students frequently engage in plagiarism. Inadequate resources in the universities to teach non- doctrinal legal research courses limit easy deployment and teaching of non-doctrinal legal research courses in the universities. Also, inadequate training facilities and software for teaching this course limit teaching of non- doctrinal legal research courses in the universities. All the variables evaluated recorded mean scores in excess of 2.50, indicating the how severe these variables are. Table 3. Challenges in teaching non-doctrinal legal research in the universities Variables Highly severe Severe Moderate Not severe Total Lecturers were not taught empirical research during their training at undergraduate and postgraduate schools 160 (2.90) 20 (0.27) 20 (0.18) 20 (0.09) 3.44 Assumption that non- doctrinal legal research is not 150 (2.73) 30 (0.41) 20 (0.19) 20 (0.09) 3.42 76 necessary in law. Phobia of statistical reasoning by lecturers 190 (3.45) 10 (0.14) 10 (0.09) 10 (0.05) 3.73 Inadequate of qualified manpower 180 (3.27) 20 (0.41) 10 (0.09) 20 (0.05) 3.82 Inadequate training for non-doctrinal legal research training 140 (2.55) 30 (0.41) 30 (0.27) 20 (0.09) 3.32 Inadequate software for non-doctrinal legal research training 160 (2.55) 20 (0.41) 40 (0.36) 20 (0.09) 3.41 The Impact of Non-Doctrinal Legal Research on the Practice of Law The impact of non-doctrinal legal research on the practice of law was investigated among the respondents. Findings indicate that non-doctrinal legal research has a high impact on legal practice, logical research and the presentation of client’s cases, client management, scale forensic assessment and probable sifting of evidence by lawyers and judges. The legal profession is probably the profession which is most oriented towards research in literature Chunuram (2021). A major portion of the work which lawyers do is legal research and the application of the findings of this research to 77 problems at hand. Proper non-doctrinal legal research skills therefore have a positive relationship with the practice of law in Nigeria. These findings are consistent with high mean scores which range from 3.47 to 3.63 (Table 4). Table 4. Impact of doctrinal legal research on legal practice in Nigeria Variables Highly impact Moderate impact Low impact No impact Total Non- doctrinal legal research practice has positive influence on the practice of law. 170 (3.09) 30 (0.40) 10 (0.09) 10 (0.05) 3.63 Non- doctrinal legal research practice in Nigerian legal system will influence scientific case presentation and client practice 150 (2.70) 30 (0.40) 20 (0.18) 20 (0.09) 3.37 Knowledge of non- doctrinal legal research will 160 (2.90) 40 (0.54) 10 (0.09) 10 (0.05) 3.58 78 scale forensic assessment of cases and investigation by lawyers Doctrinal research makes law research very efficient 137 (2.49) 60 (0.81) 13 (0.12) 10 (0.05) 3.47 Conclusions There has been growing concern about the failing standard of legal education and practice, a situation that has been traced to the quality of university graduates. Since lawyers are required to acquire legal education in universities before being allowed to practice (Chioma 2015) there are growing demands for reforms in legal education. According to the NUC,6 academic legal education should first be interdisciplinary to expose the student to analysis of the socio-political and cultural environment of legal rules and secondly, as an intellectual exercise aimed at challenging the individual to creativity and problem-solving skills through empirical research. Against this background, this study set out to investigate the challenges of conducting non- doctrinal legal research in Nigerian Universities against an initial presumption that 6 National University Commissions’ (NUCs’) Benchmark Minimum Academic Standard for Undergraduate Programmes in Nigerian Universities, Nov., 2014 pp.ii-iii. 79 they do not, and that non- doctrinal research affects the quality of legal education and practice in Nigeria. Based on the evidence presented by this study, Nigerian law students are still unable to carry out non-doctrinal research in other to acquire critical thinking skills, with the challenge that they are unable to impact same to their students if they eventually become law teachers. This challenge is historically linked to the pioneer faculty members who were trained apprentice – style in the English “Inns of Court” thus it was only natural to introduce the system with which they were familiar Fabunmi and Popoola (1990:40). The consequence on the standard of legal practice is that the young practitioner, though “qualified,” is ill-equipped and unable to define their role in the society or cope with the pressure of global legal practice. They are eventually converted from a legal practitioner to a businessman with profit rather than principle as the basis for legal practice. Recommendations Arising from the foregoing findings and conclusions, the following recommendations are suggested as a way of encouraging non-doctrinal legal research in Nigeria. 80 1. Training on NDLRM for all law teachers in Nigeria: Law teachers who are already employed should be trained on NDLRM. An advantage of this research method is the exposure to inter-disciplinarily research. There are some common features and similarities of research methodologies across the social sciences from which legal researchers can benefit 7. The social science environment is an interdisciplinary field linking the disciplines of management, economics and law. This position is consistent with an earlier study which contend that the system of legal education in Nigeria suffers from a pre-conceived restricted view of the role of the lawyer in society , Fabunmi and Popoola (1990: 45).They wondered if the scope and content of the legal curriculum in use at law faculties, which are excessively and unduly rule-oriented, can really equip the lawyer with the breath of vision required of him in his later-day professional life; whether the duties of the law faculties are discharged in teaching the ‘pure law’ (law of the statute book) or whether they should help the students to relate the law to its social effects. It is contended that compulsory training in interdisciplinary research methods will fill a yawning gap between the logically arranged legal norms in the textbooks and the stark reality that surrounds lawyers’ practical operation. This gap can only be filled with the injection of non-legal subjects which have bearing on the understanding of the society like economics, philosophy, psychology and some other relevant subjects in 7 Already, there is an evolving global research practice towards a unified citation/ referencing style for all social sciences research, including legal research. 81 the sciences and humanities. Non-doctrinal legal research is implicit in interdisciplinary legal education. 2. Provision of adequate funding: Depending on the methods of data collection, research is generally expensive to carry out. For example, the cost of experimental research design is significantly higher than what an individual researcher can afford: questionnaires may have to be administered and retrieved amongst a selected population by the researcher. These cost money. We are all aware of the challenges of unverified electronic legal research sources, hence the preference for Westlaw and Lexis in legal research. These have sophisticated functionality that can ease the pain of legal research, but these systems are very expensive to acquire, install and maintain against the backdrop of the poor funding of public universities in Nigeria. Non-doctrinal legal research will benefit extensively if university education is adequately funded. 3. Provision of adequate research facilities: It is one thing to provide funding for empirical research and entirely another to strategically and effectively deploy the funds provided to achieve the desired goals. For example, Kanayo (2021) indicates that over the last 10 years the Federal Government of Nigeria, through the Tertiary Education Trust Fund (TETFUND), has injected more than N2.5 trillion into Nigerian universities in support of empirical research. But judging from insistent 82 strike by members of the Academic Staff Union of Nigerian Public Universities, these funds did not get to the targeted beneficiaries. The following are suggested ways of ensuring that funds meant for research are appropriately applied for that purpose: i. Direct procurement of modern research facilities such as adequate classrooms fitted with smart boards, software for collecting and statistically analysing numerical data for faculties by government and donor agencies; ii. Direct subscription to online research journals; iii. Provision of adequate electricity and data for universities and faculties; iv. Sponsorship of law teachers to academic conferences and exchange programmes; and v. Restructuring of existing student curriculum with an emphasis on narrowing the gap between theory and practise. One major way of achieving this goal is the provision of hard and soft infrastructure for legal aid clinics for all faculties of law in Nigeria’s Universities. 4. The compulsory teaching of non-doctrinal legal research and writing at all levels of study in law faculties in Nigeria. 83 5. Prior credit pass in mathematics: A credit pass in mathematics and statistics should be made a compulsory requirement for admission into law programmes in Nigerian Universities. This will eliminate the phobia for mathematics and statistics amongst law students and teachers. Alternatively, law should only be studied as a second degree: only candidates with a prior degree in other social sciences should be admitted to read law in Nigerian Universities. This recommendation will go a long way in resolving the phobia for mathematics and figures by law students earlier identified. References Books Chegwe, E. N., (2016) Legal Research Methodology and Project Writing (Ekpoma-Nigeria: Ambrose Alli University Press). Elias, O., (1965) Makers of Nigerian Law (London: Sweet and Maxwell). Ojokwu, E., (2013) Legal Education in Nigeria: A Chronicle of Reforms and Transformation (Council of Legal Education). Gasiokwu, M.O.U., (2014) Legal Research and Methodology (Jos – Nigeria; Fab Educational Books). 84 Journal Articles Burns, K., and Hutchinson, T., (2009) ‘The Impact of "Empirical Facts" on Legal Scholarship and Legal Research Training’ The Law Teacher 43(2) 153-178 (Queensland Australia, Griffith University Press). Available online http://www.informaworld.com> accessed Nov. 6th’ 2021. Becher, J., (1981) ‘Towards a Culture of Disciplinary Culture’ Studies in Higher Education 2(2) 109-122. Chegwe, E. N., (2015) ‘Politics and Intrigues of Accreditation in Nigeria: The NOUN/CLE Conflict in Retrospect’ Current Issues in Nigerian Law 5 (NOUN, Abuja Nigeria), 2. Chunuram, S., (2021) ‘Legal Research Methodology: An Overview’ Journal of Emerging Technologies and Innovative Research (JETIR), 18 (10) 442. Chipasha, M., (2018) ‘Enhancing the Standard of Legal Education in Zambia; Challenges and Prospects’ Journal of Commonwealth Law and Legal Education, Everwijn, S. E., Bomers, G. 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Salim, I., Zuryate, M., and Zainal, A., (2017) ‘Legal Research of Doctrinal and Non- Doctrinal’ International Journal of Trend in Research and Development 4 (1) 493-495. News Papers and Magazines Chioma, U., (2015) Oct.17, ‘Future of Legal Education in Nigeria’ The Nigerian Lawyer Magazine accessed January 5. 86 Cambell, J., (2014) ‘Quality of Law Graduates Preferred to Large Numbers of Ill- equipped Graduates’ Rhodes University Newsletter published online at https//www.ru.ac.za/latestnews/quality/lawgraduatespreferred.