Crime/Justice

On Inibehe Effiong’s Plight Amid The Stalking-Horse Argument

Published

4 years ago

October 4, 2022

These are not the best of times for Nigeria’s Law profession! A story for another piece.
Meanwhile, my Lord, Hon. Justice Maurice Eneji, rtd was reported to have written thus on a platform that goes by the name, Confederation of Bekwarra Lawyers:
“But we must realise that the law empowers the Chief Judge to assign cases to all other Judges within her state. Thus, any application for transfer of a case is subject to the Chief Judge’s discretion. The Chief Judge can decide to transfer or not to transfer. He/she cannot be forced to do so, else it will amount to disarming the judicial power of the court. Now, if the Chief Judge refuses to transfer, then the case must go on before the Chief Judge or any court it was pending the end of hearing, if the case goes against the applicant, then the applicant has right to appeal. It is wrong for anyone to wrestle with an authority such as a court to exercise discretion in favour of any one particular person(s) or party/parties to a case. That will amount to commanding the court! May that day never come.
Respected Hon Justice Maurice Eneji (rtd), Sir, with the greatest respect to you, I think you have turned upside down all of law, equity, justice, reason and common sense.
1. You say the Chief Judge cannot be forced to transfer the case. You missed it, Sir. Such does not arise and does not apply in the present case. Under professional legal ethics, there appear to be four options available to any party who thinks he has a proper cause for complaint against a judicial officer:
(I). Send a petition to the Chief Judge of the court, for transfer of the case to another judge; or
(II). File a formal Application for Recusal, this is by Motion on Notice, Affidavit and Written Address; or
(III). Wait and make such a complaint a ground of appeal (see Sunday Okodua V. State); or
(IV). In extreme cases, report to NJC for disciplinary action.
Now, dear Hon Justice Eneji, rtd, from available reports, it appears that the option relevant to the Inibehe Effiong scenario is point Number (II), not point number (I) as you have erroneously suggested. As reported, and no one has refuted this, Inibehe Effiong as a counsel in the case, had filed a formal application praying the Hon Chief Judge to recuse himself from the case. Whether the Chief Judge likes it or not, the Chief Judge has/had an obligation to hear and determine the application, one way or another. It is on record that when Inebehe Effiong drew the attention of the judge to the Application for Recusal, instead of taking the application (which was the proper thing to do in the circumstances), at least to either dismiss or grant it, the judge had rather waved it aside, directed that the application be kept one side while trial should proceed. Inibehe complied. Thus, the lawyer, Inibehe Effiong, was ready to move the application but the judge refused to take the application.
With due respect to the Chief Judge, this is a very wrong procedure, perhaps a further testimony to his alleged personal interest or bias in the case.
Dear Hon Justice Eneji rtd, Sir, with due respect, your argument is premature; the judge had a duty to hear the application for Recusal, even if the judge planned to dismiss it. In exercising this all-important duty, the judge who happens to be the Chief Judge of Akwa Ibom State, failed woefully, leading to so many implications, imputaions, inferences and then raising so many questions, two of which are:
(A). Did the Hon Chief Judge of Akwa Ibom State forget his professional duties as a presiding judge? A presiding judge should always appreciate that he is an umpire and as such should never enter into the arena of conflict – so that he does not have a befogged vision of the case. The presiding judge must also bear in mind the need to not be a “Hippy Harliet”. See Uso v. The Police (1972) 11 S.C. 37; Okoruwa v. The State [1975] ANLR 262 See also Onuoha v. The State (1989) 2 N.W.L.R (Pt. 101) 23; Ayub-Khan v. The State (1991) 2 N.W.L.R (pt172). 127.
(B). What then becomes of Nemo Judex In Causa Sua?
“The court looks at the impression which would be given to other people. Even if the judge was as impartial as could be, nevertheless if right-minded persons would think that, in the circumstances, there was a real likelihood of bias on the part of the judge/adjudicator/arbiter, then he should not sit. and if he does sit, his decision cannot stand. It is irrelevant whether he was in fact biased, because justice is rooted in public confidence, and confidence is destroyed when right-minded people go away thinking that the judge was biased”. See: “The Suspension Of NBA General Secretary By The National Executive Committee: Corollary Legal Issues” By Sylvester Udemezue (TheNigeriaLawyer: 15 August 2022).
2. Hon Justice Eneji (rtd’s) argument over the Akwa Ibom State Chief Judge’s non-release of record of proceedings in Inibehe Effiong’s case: Hear Justice Eneji (rtd):
“Concerning the delay in providing records of proceedings, it must be borne in mind that:
1. Soon after the unpleasant episode, the court proceeded on vacation. So his Lordship will not be expected to stay back to vet and issue the records of proceedings. To do so during vacation will clearly be illegal!! It is only a Vacation Judge that has the power to treat only urgent applications during vacation!! No other person can! Therefore, if counsel had been diligent, they would have approached the Vacation Judge to reach out to the Hon Chief Judge to speed up issuance of the requested record of proceedings, and even better still, approach the vacation court for bail of the convict/contemnor pending appeal.
My Lord, Sir, with due respect, you missed it. In a commentary titled, “It Is A Violation of Litigants’ Fundamental Right for A Court to Make Litigants Pay to Obtain A Copy of the Court’s Judgment” (see: Barrister NG: 6 August 2021), I wrote, ‘Section 294(1) of the Constitution of the Federal Republic of Nigeria, 1999, provides that “Every court established under this Constitution shall deliver its decision in writing not later than 90 days after the conclusion of evidence and final addresses and furnish all parties to the cause or matter determined with duly authenticated copies of the decision within seven days of the delivery thereof”. Similarly, Section 36(7) of the same Constitution requires that “… the accused person or any persons authorised by him in that behalf shall be entitled to obtain copies of the judgment in the case within seven days of the conclusion of the case”. It is submitted that the court has a duty to make a copy of the judgment available to the parties free of charge either in the open court on the date of judgment or through the bailiffs within seven days of the judgment, or through email or other virtual platforms (the last is most preferable)’.
Continuing, I said, “This being the case, the court has a duty to make available to the parties, duly authenticated copies of the judgment. This must be done free of any charge and within the time stipulated by law, or where no time is stated, within a reasonable time. Time is of the essence here. Failure to do this is a gross breach of the fundamental rights of the affected parties and a violation of due process, rule of law and the interest of justice…. By the way, why not the court sends a copy of the judgment through the court’s official email to (all the litigants and) the lawyers in the case? Why not we expect to see a copy of every judgment of court posted on the court’s website within 24 hours or not later than seven days from the date of the judgment? Why not? Are these not where the world is at present? Why are we left behind in everything? Is it that we do not have funds to get things done right or that we do not have the foresight to see that only the right things should be done, or that “fantastic” corruption has taken away the money we need to have things done right? Where in a civilised, developed 21st century compliant country, are parties still queuing up in the court’s registry to apply for, pay through the nose (typical of Nigeria) to obtain a copy of judgments of court in their own case? Should we not at least upgrade– even if it is one step forward? What does it take the court to send a copy of its own judgement to litigants?’
My Humble Opinion:
The delay by the Chief Judge of Akwa Ibom State (who happens to be the presiding judge in this case) in releasing the record of proceedings in the Inibehe Effiong scenario is a deliberate ploy to frustrate Inibehe Effiong’s lawyers’ efforts to get justice. It is a violation of Inibehe Effiong’s fundamental rights. It is a violation of the Chief Judge’s oath of office and the code of conduct for judicial officers. Further, it is a gross breach of the Chief Judge’s duty of impartiality as an adjudicator. Such is also irregular and amounts to a gross deceleration of the Constitution. Section 36(1) of the Nigerian Constitution provides that “In the determination of his civil rights and obligations, including any question or determination by or against any government or authority, a person shall be entitled to a fair hearing within a reasonable time by a court or other tribunal established by law and constituted in such manner as to secure its independence and impartiality”. While section 36(6)(b) requires that “Every person who is charged with a criminal offence shall be entitled to be given adequate time and facilities for the preparation of his defence”.
With due respect, as I suggested, Hon Justice Eneji (rtd), is muddling issues up, instead of facing relevant issues and calling a spade by its name! I see the argument as a poor excuse for a gross desecration of law, justice, ethics and procedure by a judicial officer from whom a high standard of professional discipline was expected. Justice Eneji may well be described as a stalking-horse, looking more as one advanced to becloud the mode relevant and serious questions bordering on these gross violations of law, justice and procedure.

By: Sylvester Udemezue

Crime/Justice

‘The Scholar of Evidence, Integrity and Community Leadership’

Published

1 week ago

May 6, 2026

The Tide

In legal philosophy, silence is often romanticized as wisdom. But within the law of evidence, silence may carry a very different implication — it can amount to an admission. This thought-provoking paradox forms part of the intellectual reflections of Professor Chris C. Wigwe, SAN, an accomplished legal scholar whose contributions to legal education and jurisprudence continue to shape conversations within Nigeria’s academic and professional legal circles.

Professor Christian Chizindu Wigwe stands among the distinguished figures produced by Nigeria’s legal academy. A Senior Advocate of Nigeria and seasoned scholar, he built a reputation for intellectual rigor, disciplined scholarship, and principled leadership in the study and teaching of law.

His academic journey reflects the making of a global legal mind. Wigwe obtained his Bachelor of Laws degree from Ahmadu Bello University, Zaria, before proceeding to the Nigerian Law School where he qualified for the Nigerian Bar. His quest for deeper scholarly engagement later took him to the United Kingdom, where he earned a Master of Laws degree from Middlesex University and subsequently a PhD in Public International and Economic Law from the University of Leeds.

These academic attainments did not merely decorate his curriculum vitae; they laid the intellectual foundation for a career that has consistently bridged theory and practice within the legal profession.

Over the years, Professor Wigwe has distinguished himself in the fields of jurisprudence, international law, criminal law and the law of evidence. His scholarship reflects a deep interest in how legal systems respond to economic realities, international cooperation and evolving global norms.

Within Nigeria’s university system, his name became closely associated with the Faculty of Law at Rivers State University in Port Harcourt, where he served as Dean from 2022 until November 2025. His tenure coincided with renewed conversations about strengthening legal education and positioning the faculty for global competitiveness.

Under his watch, the faculty intensified efforts to deepen research culture, strengthen postgraduate training and pursue partnerships capable of elevating the institution’s standing among law faculties in Africa.

Professor Wigwe also consistently emphasized the importance of institutional collaboration and alumni support in sustaining academic excellence. In public engagements, he urged graduates and stakeholders to support universities in building research centres and scholarship opportunities for students.

That perspective reflects his broader understanding that legal education must go beyond classroom instruction. For Wigwe, the development of law faculties must be anchored on strong research infrastructure, vibrant intellectual discourse and international engagement.

Beyond administrative leadership, he has remained an active contributor to legal scholarship through books and research publications. His works cover diverse aspects of legal theory, international institutions and corporate law practice.

Among his notable publications are texts such as Legal Research Methodology and Practice, Introduction to Company Law and Practice, and scholarly works exploring the economic dimensions of international institutions and monetary law.

These contributions have become reference materials for students and scholars seeking a deeper understanding of legal research and the dynamics of international economic law.

What distinguishes Wigwe’s scholarship is his ability to situate legal principles within the realities of global economic systems. His writings frequently interrogate how international institutions exercise power and how developing economies can navigate complex legal frameworks within global trade and finance.

Such perspectives have increasingly become relevant in a world where international law influences domestic economic policy, cross-border transactions and global governance.

Within the classroom, colleagues and students often describe him as a meticulous teacher who believes that legal reasoning must be sharpened through intellectual discipline and ethical responsibility.

His academic philosophy emphasizes the importance of integrity in the legal profession. For him, legal education must produce not only technically competent lawyers but individuals whose character can withstand the ethical demands of justice.

This emphasis on integrity resonates strongly within the Nigerian legal system, where the credibility of institutions often rests on the moral courage of those entrusted with authority.

Indeed, Wigwe’s professional life reflects the principle that law is not merely a technical craft but a moral enterprise aimed at preserving fairness and order in society.

His elevation to the prestigious rank of Senior Advocate of Nigeria further affirmed his standing within the legal profession. The SAN rank, often regarded as the pinnacle of legal practice in the country, is reserved for practitioners and scholars whose careers demonstrate excellence and integrity.

Yet, beyond titles and accolades, his legacy lies in the countless students he has mentored over decades of teaching.

Across courtrooms, law firms, government institutions and international organizations, former students continue to carry forward the intellectual and ethical lessons instilled during their time under his tutelage.

Mentorship remains one of the most enduring contributions of any academic. Through it, knowledge is transmitted across generations, shaping the legal culture of a society.

Professor Wigwe has consistently viewed mentorship as a responsibility rather than a privilege. For him, the success of students represents the true measure of a teacher’s impact.

His leadership style within academia reflects calm authority rather than flamboyance. Colleagues often describe him as a scholar who prefers substance over spectacle, focusing on institutional growth rather than personal acclaim.

This disposition aligns with his belief that universities must remain centres of reason, inquiry and ethical reflection.

Beyond the walls of academia, Professor Wigwe’s influence extends meaningfully into community life. His dedication to secular and communal activities has earned him admiration within his hometown of Isiokpo.

Recognizing his contributions to community development, leadership and social cohesion, the people of Isiokpo honoured him with a traditional chieftaincy title — a cultural recognition reserved for individuals whose lives exemplify service and integrity.

The honour reflects the deep respect he commands not only as a scholar but as a community figure committed to the welfare and progress of his people.

Traditional institutions in many African societies remain important custodians of culture, identity and moral leadership. When communities confer chieftaincy titles, they are often acknowledging a life lived in service to collective advancement.

For Professor Wigwe, this recognition underscores a broader philosophy that scholarship should not exist in isolation from society.

Rather, knowledge must translate into service — guiding communities, strengthening institutions and inspiring future generations.

The influence of scholars like Wigwe becomes even more significant in societies navigating complex governance challenges. Legal scholars provide the intellectual frameworks through which institutions interpret constitutions, enforce rights and resolve disputes.

In this regard, the Nigerian legal system continues to benefit from the contributions of academics who combine scholarship with practical insight.

Figures such as Professor Wigwe represent a bridge between legal theory and real-world governance.

Such individuals are invaluable to both national and international institutions that require legal minds capable of navigating complex regulatory and diplomatic environments.

The global legal community increasingly recognizes that expertise in international economic law, institutional governance and evidence law is essential for addressing contemporary challenges.

From trade negotiations to international arbitration and human rights enforcement, the need for scholars with strong analytical foundations has never been greater.

Nigeria, like many developing nations, possesses a reservoir of intellectual talent within its universities. However, such expertise is often underutilized in global governance spaces.

Scholars with the depth of experience and credibility of Professor Wigwe deserve broader platforms where their insights can contribute to shaping international legal discourse.

Positions within multilateral organizations, international arbitration panels, global academic networks and legal reform commissions could greatly benefit from the perspectives of scholars who understand both local realities and global legal frameworks.

The strength of any legal system ultimately depends on the integrity and intellectual courage of those entrusted with responsibility.

When individuals who embody these virtues are elevated to positions of trust, institutions become stronger and public confidence grows.

Professor Chris C. Wigwe’s career illustrates the enduring relevance of scholarship grounded in integrity, intellectual discipline, community service and responsible leadership.

In a time when public institutions require credible voices capable of guiding policy with wisdom and ethical clarity, figures of his calibre stand out as valuable assets not only to Nigeria but to the wider international community.

Ultimately, the story of Professor Wigwe is not merely about academic achievements or professional titles. It is about the quiet but powerful influence of a scholar committed to the ideals of justice, knowledge, community service and ethical leadership.

And in the long arc of legal history, it is often such scholars — patient builders of institutions, mentors of generations, and respected sons of their communities who leave the most enduring imprint on the pursuit of justice.

Crime/Justice

Legal Consequences Of Baby Factory In Nigeria

Published

2 years ago

February 14, 2024

The Tide

Children are highly desired and parenthood is culturally significant in Africa. In Nigeria, infertility is a socially unacceptable condition, making victims embark on relentless quest for conception. In Vitro Fertilisation (IVF) is the only alternative but same is expensive.
Admittedly, this has contributed to the advent of illegal baby factories in Nigeria and consequently constitutes an emerging trend of human trafficking.
What is baby factory? This implies to a practice in which young pregnant and unmarried girls are given shelter by a proprietor i.e Oga or Madam of the home until they are delivered of their pregnancies and give up the new born for sale.
This illegal centres and homes are most times camouflaged as “maternity homes, orphanages, social welfare homes, and clinics and are operated by well organised groups”.
As an emerging phenomena in developing countries of the world, it is also prevalent in Nigeria particularly in States such as Abia, Imo, Enugu, Edo, Rivers and Lagos.
It is important as well as my concern to note that children have rights and these rights must be protected. This evil scourge of baby factory is an illegal business involving getting pregnant young girls and women without sanity who either are willing or not to give up their babies for financial gain and benefits without having any contacts with the buyer or ever seeing their baby again.
This category of persons are introduced into this business forcefully, by deceit of evaporated love and care or under the guise that the baby factories are clinics or homes where they can pay less or deliver freely with some promise of jobs, safe abortion or money after delivery.
The owners of the factory and their syndicate insist that babies be put up for adoption by childless couples in the most fortunate scenario, else supply the babies to politicians for their rituals, illegal adoption and human trafficking. Pathetic right?
It is my argument that children born into baby factories are denied various civil and fundamental rights alongside their mothers because of their vulnerability. Some of the rights these children are denied include birth registration.
Nigeria is a signatory to many international and regional instruments targeted at eliminating child trafficking, protecting children and also the promotion of their rights which include, the United Nations Convention on the Rights of the Child (1989) and the Optional Protocol to the Convention on the sale of Children.
Section 12 of the Constitution of the Federal Republic of Nigeria (as amended) stipulates the guidelines for applicability of this treaties in Nigeria.
Regrettably, despite the vast number of statutes protecting children and women, there is still an alarming prevalence of heinous crimes against these vulnerable units of our society.
The Children’s Rights Act was enacted as passed in Law in Nigeria in 2003, to serve as a legal document and protection of children’s rights and responsibilities in Nigeria which consolidates all laws relating to children into one single legislation, as well as specifying the duties and obligations of government, parents and organisations.
However, despite its values and importance, most States in Nigeria have not domesticated the Act, which implies that children in some States are not being protected under this law which prompts unequal rights in children.
Section 30(1) of the Children Rights Act provides that No person shall buy, sell, hire, let on hire, dispose off or obtain possession of or otherwise deal in a child. This section clearly prohibits the act of buying and selling of a child or children.
Section 207 empowers the police to create a specialised unit for the combating of the crime.
The sporadic growth of baby factories across the Nigeria State is a front burner issue that needs urgent address, given the rise in in the thriving business due to the ever increasing in height of economic downturn in the country.
The vulnerability of children and the need for their protection has attracted international recognition as well as domestic legislation.
The Constitution also provides protection for the dignity of the human persons and personal liberty as stated in Sections 34 and 35 respectively. Howbeit, it is very safe to say that these laws are ineffective for the purpose they were enacted.
Having considered this topic in relation to baby factories as an avenue for trafficking and the laws enacted to promote and protect women and children, it is my recommendation that:
1. The government institutions established by law for the protection of children performs their duties.
Security agencies should not delay the prosecution of persons who commit this offence.
The government should ensure that upon discovery facilities harbouring women and children for sale be destroyed and periodic checks should be conducted on churches, mosque, hospital etc.
Intense education and sensitisation campaign and programmes for young girls, and boys and women about unwanted pregnancies.
Government should assume their responsibility of the protection of lives and increase the budgetary allocation for children orientation programme in schools, villages, church and mosque.

Esaenwani Baribor Ferguson

Esaenwani is a practising lawyer based in Port Harcourt at Brisk Attorneys and Consultants.

Crime/Justice

Why Police Welfare Package Should Be Improved

Published

2 years ago

January 24, 2024

The Tide

The Nigeria Police Force is the principal law enforcement agency in Nigeria. It has its origin in Lagos following the creation of a 30-man Counsular in the year, 1861.
It further has its Constitutional backing in the Chapter Six (6), Part Three (3), Section 214 of the Constitution of the Federal Republic of Nigeria , 1999 (as amended). Down the line, the Nigeria Police Force begin to have other formations like the Mobile Police Force in the 1980s.
The motive behind the creation of the Nigeria Police Force, is to preserve law and order, the enforcement of law and regulations with which they are directly charged. The performance of such military duties within and outside the country as may be required of them by or under the authority of the Police Act or any other Act.
When the heat or should I say, the need or urge to provide better policing in the country became necessary, more formations like the Special Anti Robbery Squad (SARS) were birthed around 1992 to battle crime especially armed robbery.
This very formation (SARS), before it went under on Sunday November 11, 2020, when the then Inspector General of Police, Mr Mohammed Adamu announced its disbandment was a talk-of the-town.
People were delighted to catch a glimpse of SARS men especially when they are in operation and in their full regalia. They fought crime to almost zero point before the devil took over the outfit and placed it in the history book.
The Slogan ‘ The Police is Your Friend’ is one of the most disgusting or disturbing things about the Nigeria Police Force. Many are not at ease with it. In most cases, they begin to wonder what the Police is even doing to get the least attention.
But until you are closer to some people including the Police, you may not say for sure what they do or their importance to the society. Some Police men are down-to- earth. They execute their jobs in such professional manner that one may be tempted to purchase Police recruitment form of a given year.
I have the privilege to interface with some of them at some Special Areas in Rivers state. Their profiles are not only intimidating, but reveal a serious road map on how best to tackle security challenges in the country.
When they related to me why they cannot execute some actions, I was flabbergasted. The government ought to look for those kind of officers and secretly talk with them.
They complained of being tagged as saboteurs should they approach their Heads with their ideas on some issues.
One of the officers confided in me how he unearthed a high profile kidnapping gang that nailed a certain bigman. I mean a bigman with both wealth and honour. I looked at the fragile frame of mind of the officer and took his claims with a pinch of salt.
When other of his colleagues at different fora commended him on some hard job success, it then dawned on me that I was dealing with a senior intelligence officer. His challenge was not also far from the ones earlier enumerated by his colleagues .
Armed with the little information I have gathered about the Police and its challenges, I delved into personal investigation. I went round almost the big formations in the state. With utmost humility, I discovered that the government was unfair to the Police.
In some of the outfits, over ten (10) officers are squeezed into one office. About three (3) of them or so share one (1) table. One will begin to imagine what the occupants of such place will produce.
Even the big formations with big names are not better. They suffer even the worst. But as the big men they are, they stomached the whole thing and welcome you with a beaming smile.
If you are not of a good temperament, you may take him (the bigman officer), for an evil man who derives joy in suffering. Or was the foremost Afro Beat King , Fela Anikulapo Kuti right when he sang ‘Suffering and Smiling’?
I think it is about time those that head some big Police formations in the country begin to think on how to improve on their jobs. Those at the top are not too mindful of the welfare of others. I blame them not, because such is a typical Nigerian factor.
I can recall vividly well at a particular public function in Port Harcourt when one officer was introduced as the Financial Officer in charge of a certain Police outfit. The master of ceremony (MC), took it up. He (MC), was like “thank God oga will bless us today”, the officer in a quick reaction, gave it back to the MC, thus, please “I am sorry, we are only bearing the name, the real office is in Abuja”.
People took it as a joke including me, but when I dug into the situation, I knew what exactly the officer meant then. The narrative must change, if the police must perform to the taste of the common man.
The Police and its welfarism must not be gambled with. The government and its authorities should consider the need for Police reform and execute it with immediate alacrity.
This will also help the authority to place a plum line on the Police. I think part of the poor check on the side of the government on the Police is deliberate, in that the authority know that they have not performed their own part of the agreement hence, the ‘On Your Own’ kind of approach to issues.
The police, if well equipped, will do more than expected. The manpower to execute some tactical operations are within them, but lack of support for them remains a bane to their positive operations.
Another point to effective Policing in the country is , management of the Internally Generated Funds by the Police. If the Police are allowed to manage the funds they generate internally, it will go a long way in fixing things among them.
The issue of waiting for approval to fix even furniture in the office is a major clog in the system. At times, they are forced to ask for financial support from the suspects to enable them buy as little as writing materials.
Such ought not to be in that the risk of compromising the matter will be high. If the materials are so provided, the officer will have no option than to do the needful.
Another point is that of personal visit and inspection. The authority should make out time to visit the Police formations across the country. They should visit such places like the convenience, bathrooms, canteens, etc. When you pay some unscheduled visits to some of the mentioned places, you will agree with this piece to the extent of making a quick case for an improved welfare package for the police.
As a citizen of Nigeria, make a personal visit Police formation as part of your menu. Let the issue of the police harassment especially on the roads not deter you. By so doing, you will be armed with some information that will convince you that of a truth, the to any Police is really ‘Your Friend’.
The time to address the challenges of the police is now. No need to dwell on the past. Let’s stop the blame game and think of the way forward.