"It is settled and quite trite that special damages claimed must be specifically pleaded, and they must be strictly proved. The party pleading special damages is enjoined to particularise in his pleading the item(s) of special damages claimed. He must base his claim on precise calculation and give the Defendant access to the facts on which such calculation is based. This requirement satisfies one of the twin pillars of fair hearing, that is audi alteram partem. The essence is that the defence shall not be prejudiced or put to embarrassment. The requirement enables the defence to prepare to meet frontally the case put up against him on the special damages claimed. Claim for special damages based on mere estimates or estimation of the Plaintiff is not precise. It is as good as an exercise in mere conjecture, a guess work, which clearly is the antithesis of precise calculation. The party who founds an item of his claim on special damage intends thereby to remove from the Court its discretion in the matter to some extent. Equally, in a claim for special damages the Court is not expected to issue its order on mere conjecture. Every order of Court is expected to be precise and certain. A claim founded on mere conjecture is clearly an invitation to the Court to descend to the realm of conjecture and thereby producing an order that is uncertain in terms; and that is not a hallmark of judicial order."

Per EKO, J.S.C. in ALHAJI MUSA AJIGBOTOSHO v. RENOLDS CONSTRUCTION CO. LTD (2018) LPELR-44774(SC)