“Now, consider what is the object of rule 11. It is to authorize the suing [at][sic] persons in the name in which they carry on business – to facilitate the carrying on of actions against persons who conceal their names, and for that purpose the rules relating to actions against firms are to be applied as far as possible….It could happen that a person may carry on business in a name other than his name but may fail to register it as required under Part B – Business Names – of the Companies and Allied Matters Act, 1990. Such persons undoubtedly come within those who conceal their names. The solution to such device by that type of persons can be found in the rule that allows suing them in the name in which they carry on business. And this is intended to obviate obstacles against actions against them if their real name had first to be ascertained. So, the question of the production of the Certificate of Registration of the business name as submitted by learned counsel for the appellant would not arise and becomes a non-issue. If it happens that the business name had not in fact been registered, that would be a contravention of s. 667 of the Act and there are penalties provided. That does not provide immunity against being sued in that name, whatever its status, in accordance with the said Order 14, r. 42 applicable in the Federal High Court.”

- Iyke Medical Merchandise v. Pfizer Inc. & Anor. [2001] LPELR-1579[SC] at page 18