NATURE AND SCOPE OF ANIMAL RIGHTS AND GAME MANAGEMENT
“Forest owlet thought to be extinct because there have been no confirmed sighting of it for 113 years, the pink-headed ducks last seen in the 1930’s and the Himalayan mountain quails not been sighted for about 100 years have now been spotted*. God’s concern for the restoration of the planet’s natural ecosystem for the everlasting benefit of mankind is unfolding fast”
DEFINITION
For the purpose of putting this topic into a proper perspective and sharp focus, it is imperative to know what animals are. According to L.B. Curzon,1 the term ‘animal’ includes (a) any kind of mammal except man (b) any kind of mammal (c) fish, reptiles, crustaceans and other cold-blooded creatures not falling within (a) or (b) above. Section 3 of the Wild Animals Preservation Law2 defines ‘animal’ to mean all vertebrates and invertebrates (including non-edible fish), their nests, eggs, egg shells, skin and plumage whilst Section 23 of the Animal Diseases (control) Act3 defines it to mean “horse, mule, donkey, camel, cattle, cow, bull, bullock, heifer and calf, buffalo, sheep, goat, swine, dog, cat, laboratory animal, wild animal ……”.
Animals are classified into “domitae naturae or mansuetae naturae” (tamed or domesticated e.g. horses) and animals ferae naturae (of a wild nature e.g. monkey). ‘Domestication’ as defined in the Oxford Dictionary is “to tame, to reclaim (an animal or plant) from a wild state”. The distinction which is usually made between domestication and taming is that the former includes control of reproductive phase of the life cycle and selection of parents whilst taming does not. Taming is the practice of eliminating the desire of an animal to flee, and possibly, of training the animal to perform some useful function. Section 87 of the Animal Health Act of 1981 provides that “wild animals” are animals not normally domesticated in Britain Nigeria
(a) Mammals are animals which have true hair on their bodies and which feed their young on milk by means of teats;
(b) Ungulates are animals which have hoofs e.g. warthog, goals etc;
(c) Carnivores are animals which eat meat or flesh e.g. lion, dogs;
(d) Rodents are animals which gnaw or cut away things like wood or nutshells with their front teeth e.g. porcupines, hares etc
(e) Primates are animals which look most like man e.g. monkeys and baboons;
(f) Insectivores are animals which eat insects e.g. hedgehogs;
(g) Reptiles are animals which have their skin, made up of scales or horny plates and which cold blood e.g. snakes, tortoise etc;
(h) Amphibians are creatures such as frog and toad which live part of their life in water and the rest on land;
(i) Bovidae which include the antelopes, heartebeest and suidal and others as included in Ungulates4b.
CONCEPT OF RIGHTS
Another important and relevant concept is “rights”. According to Salmond, right is an interest recognized and protected by the law, respect for which is a duty and disregard of which is a wrong, a capacity residing in one man of controlling, with the assent and assistance of the state. A right involves (1) a person invested with the right or entitled (2) a person or persons on whom that right impose a correlative duty or obligation. (3) an act or forbearance which is the subject matter of the right (4) an object, that is, a person or thing to which the right has reference; and (5) a title or reason for the right becoming vested in the owner. Rights are perfect and imperfect; positive and negative; real and personal; propriety and personal; in repropria and in re-aliena; principal and accessory; and legal and equitable.
ANIMAL RIGHTS CONCEPT
It may be adduced from the foregoing that a right in one person presupposes a correlative duty on the other. In the strict sense, a duty is something owed by one person to another. Correspondingly, the latter has a right against the former. Rights are also concerned with interests and indeed have been defined as interest protected by rules of right. It may be that Animal Rights are the rights conferred on them by law or the state as a result of the state’s interest in them. One may wonder a little whether the concept of duty and right that is peculiar to person5 is applicable to animals. Undoubtedly, certain legal restrictions are placed on human beings in their dealings with animals and these restrictions form the core of animal rights.
It is significant to examine at this juncture whether animals have legal personality or not. Today, beasts are not persons, they are merely things, objects of rights and duties, hence an animal cannot own property.
A beast cannot even own property through a human trustee. Thus, a testator who vests property in trustees for the maintenance of his dogs creates no valid trust that is enforceable by or on behalf of such non-human beneficiary. A trust for the benefit of particular classes of animals as distinct from individual animals is however valid and enforceable as a public and charitable trust. Besides, cruelty to animals is regarded in many legal systems as a criminal offence; this however does not confer legal personality on beasts.
Notwithstanding the above, it is possible for a legal system to regard an animal as a person and endow it with rights and duties. Thus in the days of YORE a beast that was guilty of homicide was punished with death. Even in modern times while an animal still has not legal personality, a trespassing beast may be detained and kept until its owner or someone else interested in the beast pays compensation.
In medieval Europe , worms were prosecuted in the law court for trespass, cocks were prosecuted in Germany South Finland , a small white rabbit was jailed for vagrancy after loitering around in the sleepy town of Purvu
Also, in Southern India , it was reported that an elephant trained to beg for her master was arrested and formally charged by the Police with begging and creating traffic hold up. As the story goes, the elephant went on begging prowl, the only job she knew, in the crowded street of Combatry, ignoring the traffic and held out her trunk for alms from passing motorists. The Police arrested the elephant after people complained that she was obstructing traffic and booked her under Anti-begging laws. She was also booked for creating public nuisance but was released with a stern warning and her owner filed 10 rupees8.
The resume of the above discussion is that, although, generally speaking, animals do not have legal personality, it is possible for the legal order of any country to confer legal personality on them, just as the law confers legal personality on the company after incorporation or where the statute establishing such corporation confers as Keetten puts it “entities capable of bearing rights and duties bearing units.” It may be noted however that these rights and duties must of necessity be performed and enforced by the individual owner since they are objects of right and duties. For example, the common law rules with regard to strict liability of animal ferae naturae were abolished by the Animal Act, 1971. Where damage X is caused by an animal of a dangerous species, the keeper of the animal is generally liable. In the case of an animal not of dangerous species, the keeper is liable for damage which that particular animal is likely to cause9. A trespasser cannot as a rule recover damages10. The keeper of a dog is as a rule, liable for damage by killing or injuring livestock. The owner or person in charge of a dog worrying livestock in agricultural land is guilty of an offence 11(a).
Straying animals may be detained and the damage caused by them is recoverable with the expense of keeping them. The common law remedy of distress damage feasant is abolished 11(b). The common law rule that the occupier of land adjoining a highway was under no obligation to prevent his animals straying on the highway was under no obligation to prevent his animals straying on the highway is abolished by section 8 of Animals Act 1971 and the owner may be liable for negligence. This does not apply to animals on common land or on a town or village as contemplated by Section 33 of English Highway Act; 1971.
It is an offence to allow horses, cattle, sheep, goats or swine to stray or lie on or at the side of a highway. This does not apply to animals on common, wastes or unenclosed ground.
THE GENESIS OF ANIMAL RIGHTS
In some countries, there are laws that regulate the treatment of animals and prohibit cruel acts. As for back as 1641, the Massachusetts Bay Colony formulated “The body of liberties” which stated thus. “No man shall exercise any Tirranny or crueltie towards any bruite creature which are usuallie kept for man’s use”. Since then, legislation has been formed to guard against cruelty to animals.
Activities of pot hunters, game dealers, poachers, sportsmen, market hunters, who hunted animals for food and many of whom wanted to collect as many trophies as possible contributed immensely to the development of these rights. This came as a result of the impacts of their activities which greatly culminated in the scarcity of some species and even extinction of many more species. In 1909, former U.S President Theodore Roosevelt, came to Kenya
This was to change however, during the second half of the 19th century. Members of several influential and overlapping segment of the population were able to articulate a broad and growing concern that the reduction in the abundance and distribution of wild animals was occurring too quickly. These sportsmen, naturalists and humanitarians argued that even if wild animals provided no benefit other than meat and skins, free access offered few incentives for socially responsible harvest. Indeed, the very influence of these groups implicitly recognized new forms of social responsibility.
In the same vein, philosophers at various times made their contributions. In 1625, H. Grotius, maintains that animals cannot posses rights because they cannot form general maxims: I. Rodman in 1779, finds incoherence in Grotius’ interpretation of natural right and law which excludes animals from the sphere of justice. O.W. Holmes in 1881 explores the rationale of liability of animals, plaints and inanimate objects in ancient Greek and Roman laws, traces influence of such laws on early German and English laws, with some tendency to regard slaves, children and animals in similar category. J.C Gray in 1909 emphasized that animals in modern jurisprudence have no legal rights or duties12.
It should however, be noted that there may have been, indeed may still be, systems of law in which animals have legal rights. For instance, cats in ancient Egypt Siam
J.S. Tishler in 1977 explores the question of legal rights for animals and proposes a guardianship model for dogs and cats, removing them from the property category and extending legal rights to them. According to R.B. Edwards and F.H Marcsh in 1878, since our murder laws are designed to afford protection to “reasonable creatures in being, consistency requires our murder laws apply to them J. Feinberg, asserts that legal theory and practices should change to recognize animals’ legal standing and legal rights. M.A Fox in 1978 advocates that animals be given legal rights. A. Dichler in 1978 argues for legal rights and standing for animals: thus, “The possession of legal rights is meaningless unless one has standing to vindicate these rights in court” Argument for animal legal rights are by B.E. Rollin: T. Region and V.P Macarthy “inevitably some owner or criminal group will eventually introduce a breakthrough case, on behalf of animals in which a court will award damages for the loss of the animal himself”14 H. Cohen in 1983, explores the idea of extending common law rights of action to animals recovering damage for personal injury and wrong death.
It was also the idea that wildlife provided benefits, which include offering essential recreation to a population increasingly distanced from the rural environment where they would be studied as curiosities or as part of complex world or as monuments to the integrity of natural systems.
To accomplish the foregoing, changing the conditions under which human and animal populations interacted became imperative through the Law. In order to achieve this in developed counties like Britain Nigeria
One of the general solutions available to the problem of resource management was the assignment of property rights to individual decision makers who, in promoting their own best interests, would husband the resources in society’s best interest. Land owners were the parties to whom property in terrestrial wildlife might most reasonably be assigned. However, identifiable populations of most important species were not naturally confined by the boundaries of private land holdings. Thus, the benefits of management strategies undertaken by the owners at their private expense will be shared with those over whose lands the animals roam.
The second general solution to the problem of resource management and that which formed the basis of modern or civilized legislation was the assignment of property rights to an omniscient administrator, generally an agency of the state. Such an administrator could, in theory determine an optima harvest for each species and regulate access in such a manner as to achieve the harvest.
In Africa , the situation was worse. The herds which used to inhabit African savannahs were being decimated ever more with the increase of firearms and the constant opening of new markets for meat.
Reacting to this state of things, law’s refuge was sought for. The first was the setting aside of biotopes selected for their quality which meant the establishment of Nature Resources and National Parks where strict measures would be in the following order:
a. That species should be safeguarded;
b. That natural communities should be left undisturbed and systematically observed; and
c. That visitor should be allowed access under special conditions to areas which had remained or become specially attractive through the abundance of wildlife.
The second reaction was to pass judicious hunting regulations to control and limit wherever possible the useless slaughter of wild animals. The fulfillment of this double aim, and the need to coordinate international action, were at the origin of the first conference for the protection of the fauna and flora of Africa convened in 1933.
This conference concluded by the signing of a Convention ratified later on by majority countries responsible for the administration of African territories. The London Convention recommended the establishment of Nature Resources and National Parks in the territories administered by the contracting government, it laid down certain principles concerning the traffic in skins of wild animals and prohibited certain hunting methods. It also defined the protection to be granted to some threatened species, which were listed under class A and class B.
By English Common Law, wild animals were the property of no one until reduced to possession by capture or control. But colonies and later the states including Nigeria
It had been suggested that the scope of the doctrine has been increasingly narrowed in the twentieth century as it has become clear that the effective management of wildlife population can be maintained if both the government and non governmental agencies backed the effective and enforceable law. Wildlife is public rather than private property. A wildlife programme for the Federal Government should include acquisition of refuges and protection from diseases and other dangers to wildlife and a liberal financial support for the protection of game.
CONCEPT OF PROPERTY OWNERSHIP AND ANIMALS
It has been established that animals are mere chattels and subject to rights and duties. According to the English Property Act of 196814a property covers money, all tangible property, choses in action and intangible property that is capable of being stolen. In the case of Partridge v Crittenden14b the Appellant having advertised bramble finches at € 1.25p each he was convicted of offering for sale, wild birds contrary to the protection of Birds Act 1954. The Divisional Court England Nigeria
As to ownership of animals as property, the problem really was hinged on the ownership of wild animals. if wildlife were recognized as common property, could common owners then pursue animals wherever they sought refuge, even on private property? How much control can the state as trustee for common owners exercise over the pursuit? Alternatively, if ownership in wild animals were recognized as private property, what kind of voluntary exchanges would emerge and how would they be enforced? In fact, there was neither customary nor legal precedent for private ownership. The states had assumed ownership of wildlife.17
However, under a qualified property in living wild animals which arises by lawfully taking, taming or reclaiming them. Animal ferae naturae becomes the property of any person who takes, tames, or reclaims them until they regain their natural liberty. Animals such as deer, swans and doves are the subjects of this qualified property which is lost, if they regain their natural liberty and have not the intention to return. This is supported by the reasoning of the court in the case of Hamps v Arby 17a.
Thus an action for trespass, conversion or detinue will lie for taking a captive thrush, singing bird, muskrat, parrot or ape because although they are ferae naturae they have been held to be merchandise and valuable when in state of captivity as in the case of Grymes v Shack (1610) Cro Jae 262. It was held that thrushes and other birds may not be sold unless they are close ranged specimens bred in captivity.
It appears the problem is solved as regard livestock, because they are captured, tamed and domesticated already and are thereby subject to private property. Although the owner has the right of possession, use and disposal, it must be however exercised within the limits permitted by the law. For example in Britain Nigeria
As for wild animals under English law and before it, Roman Common law, wild animals are nullius bonis (the property of no one) and regarded as common property. The law recognizes certain forms of private property each with its proper Latin name which results from capture, confinement or grant. The game laws specify the limitations on the freedom of individual to reduce animal ferae naturae to private property. After the Norman invasion, existing forests and all game (but not all wildlife) was appropriated by the king as his property. Trespass and poaching were strictly punished often by the loss of life or limb.
Also in Nigeria England Nigeria
The particular version of this history that seems to be accepted in the United States United States New York City United States
The U.S. Supreme Court had no occasion to comment directly on the sources of state authority until 1896 in Geer v Conn26. This case involved the right of the state to prohibit the exportation of game taken legally within the state while the basic authority of the state was seen to rest with its police power. In following a rather lengthy discussion of European and English laws and their transfer to the colonies, the court asserted the state’ proprietary interest in wild animals. Legislation of the kind contested here surely depended on the ownership doctrine and that the state would be obstructing commerce by prohibiting the passage between states of private property because wild life is the property of the state. However, the court had ruled, the state may determine the conditions under which its citizens might acquire property in game.
The influence of the decision in Geer v Conn continues to decline and in the 1979 case of Hughes v Oklahoma27, the Supreme Court of the United States, noting that decision had been eroded “to the point of virtual extinction” directly overruled the state’s point of authority to protect legally captured wildlife from entering the stream of interstate commerce.
The federal role in wildlife protection finds support not only in this erosion of the state ownership doctrine but also in the powers enumerated in the constitution. The authority of the Federal Government to regulate access to wildlife on public land is well established and has been broadened to include the regulation of access to private land where such access imperils federal property. The case of Bailey v Holland28 specifically provided that congress might protect bird, adjacent to a federal wildlife refuge as a means of protecting them as they entered and left public land.
The question of ownership of wildlife in Nigeria
The ownership of wild animal found in a National Park is simple and direct having regard to the provision of section 20 of the National Park Service Act which states that “The ownership of every wild animal and wild plant existing in its Natural habitat in National Park and anything whatsoever, whether of biological, geomorphological or historical origin or otherwise, existing or found in a National Park is hereby vested in the Federal Government and subject to the control and management by the Federal Government and for the benefit of Nigeria and mankind generally”. However, the ownership of the Federal Government cases where the wild animal or plant is lawfully taken by a licencee or found near or outside a National Park in the absence of evidence that the animal was taken in the course of a recognized national migratory route or pattern to and from the park 28a.
Other relevant legislations are the Endangered Species (International Trade and Traffic) Act29 and the Animal Diseases (Control) Act30 enacted in respect of matters which are within the exclusive legislative list.
The question of ownership is further buttressed by the common law maxim quic quid plantator solo solo cedit31 meaning – he who owns the land owns everything underneath and above it up to the sky. Because wild animals are not fixed to the land purchased, so the land-owner cannot claim the wild animals to be his own property but where the land is enclosed and the animals are captured and tamed, they may be subject of private property but the use is still within the circumstances permitted by the law. If it were the law that hens, chickens, turkeys, and geese belonged to nobody, that anybody might kill and eat them at pleasure, it would not be long before the race of domestic fowls would become extinct and if it were the law that sheep and lambs could be taken and sequestered for anybody’s use, lest his neighbour should get the start on him which event might result in public disquiet among individuals or governments. Animals must of necessity be owned by either an individual or government.
CONCEPTUAL FRAMEWORK ON GAME MANAGEMENT AS A NATURAL RESOURCE AND SOURCE OF ENERGY
As a follow-up to the discourse on the conceptual frame-work on Animal Rights, it is considered necessary to know what game, management, energy, resources and biogas connote.
GAME
In the Black’s Law Dictionary32 – “game” is defined as wild animals and birds considered as objects of pursuit, for food or sport. However, according to the Chambers Dictionary published in 1999, game also includes any species of fish.
In the context of this work “game” particularly in the area of energy, would include some domestic animals as all the livestock of today have their progenitors in the forest, but as a result of their being tamed from a wild state, they have undergone the process of domestication, thereby reducing their wildness and becoming domestic animals. in other words, game can be captured and/or tamed. The term domestic animals include all those domestic or tamed animals that, by habit or training, live in association with man. An animal which does not exist in wild state anywhere in the world is in law a domestic animal. However, judicial notice will be taken of the ordinary course of nature in regard to the position of animals. Curson L.J. said – “A domestic animal, which reverts to a wild state, is in law no longer domestic but wild and vice versa.”
Notably, the term “wild” which is applied to animals includes not only those animals which are savage in nature, but also those of a less wild or timid nature which can not be classified as domestic or tamed animals. Thus, it has been held that singing bird, muskrat, parrot or ape, although they are wild, yet they are merchandise and valuable when in state of captivity33.
MANAGEMENT
Management according to the Black’s Law Dictionary under environmental law means supervision, conservation and maintenance of natural resources; the protection, improvement and use of natural resources; in a way that ensures the highest social as well as economic benefits. It is all to frequently assumed that fauna conservation is contrary to human and particularly African interests. The cry of preservation for preservation sake has led to the false assumption that in this day and age, wild animals are some strange anachronism and can be preserved only under artificial conditions. Nothing could be more misleading or inaccurate than this fake assertion.
Management or conservation is different from preservation. The latter is a negative attitude of mind, which can scarcely hope to prevail because it frequently conflicts with human endeavours. Preservation implies the strictest protection of animals almost without regard to consequences. Conservation on the other hand is something positive and being directly beneficial to man, is itself a legitimate human interest.
“Conservation” means the scientific regulation of numbers to ensure the perpetuation of the complete biomass, and the maximum sustained yields of all the values. In other words, “conservation” means maintaining the most suitable between one species and a combination of all the others in any given environment.
The term “wildlife” it closely associated with preservation of game animals and this concept is still held today. In a few countries like Britain, the Netherlands, there is now a trend in conservation thinking to define wildlife as including all species of animals and plants found in nature.
ENERGY
Energy is an idea or a concept developed by the human mind to group together a large number of actions. It includes things known to humanity since its earliest times such as muscle powers in man and animals or wind power in a soil or the burning of animal fat as a source of light or the burning of wood for heating a house or cooking or warming water.
Energy means the use of common sources of power namely nuclear power, hydropower, electricity, oil, natural gas, coal, wood, solar energy. Biogas energy is clearly of two types- one is the renewable kind which arises from the flow of natural circles. The major forms of renewable are human and animal energy, plants and animal processes that create fibres for clothing, materials such as wood for shelter, industrial process utilize hydropower and direct solar radiation also include solar energy, photosynthesis which create the food chains for plants, animals and human life. On the other hand, fossil fuels are firmly recognized as finite or non-renewable energy resources. In this work, emphasis would be laid on Biogas as a renewable energy due to its production from renewable natural resources of plants and animal droppings and wastes.
RESOURCES
Resources are the attributes of environment, acquired by man to be of value over a specific period of time within the constraint imposed by his social, political, economic and institutional framework. Natural resources have been trichotomised into the following:-
1. Flow Resources: This can be depleted, sustained, or increased depending on their management or conservation. These include Forests, Wildlife and Fish, Land, Water etc.
2. Stock Resources: These are of two kinds (a) totally physical exhaustible resources e.g. coal, oil, and natural gas etc. and (b) depletable but capable of being reproduced – most metals and rubber fall within this sub-category.
3. Continuous Resources: These are also of two kinds (a) those whose availability is limitless but independent of man’s actions e.g. solar and tides; and (b) those whose availability is endless but not independent of man’s action e.g. air, water, etc.
Our forests and waters constitute veritable natural assets providing the right habitat for a myriad of living things that are useful in agricultural and medical sciences. These forests and waters contain resources, some of which are non-renewable (e.g. coal, oil, metallic ores etc) while others are renewable (e.g. wood, grassland, fish and wildlife). Renewable natural resources however remain as long as they are removed at rates commensurate with their formation and the ecosystem maintained for their perpetuity. The combination of renewable natural resources and ecological endowment of Nigeria
BIOGAS
Biogas is the term used for the gas made from the natural decomposition of organic (plant and animal) materials. It is produced when the materials are digested by bacteria in a situation where little or no air is present (anaerobic digestion).
Biogas is a mixture of different gases consisting of approximately two-thirds methane (CH4) (50-60%) and one-third carbon-dioxide (CO2) (30-40%), hydrogen sulphide (less than 1%) and other gases such as nitrogen, hydrogen, carbon monoxide in traces. Biogas is a wet gas because it picks up water vapour from the slurry. Biogas is a flammable gas produced by microbes when organic materials are fermented in a certain range of temperature and moisture contents.
The main component of biogas is methane, which is colourless, odourless and tasteless, but due to the presence of other gases it gives slight smell of garlic or rotten eggs. Methane is formed from the fermentation of animal waste or any other cellulose organic materials such as decaying vegetables, straw and so on. However, water contents, and suitable pH balance must be maintained35.
Like other renewable energy sources, biogas is a stored from of solar energy (since it originates from plants which used the sun’s energy to grow).
Biogas is a high quality fuel, it can be used for many purposes including cooking, lighting, running dual fuel engine, agro-processing, pumping water and generating electricity.
COLLECTING BIOGAS
Gas is produced in a landfill site when the organic matter starts to decompose. It would normally find its way to the surface and disperse, but if the waste is covered with a layer of clay the gas is prevented from escaping. It can be extracted at a controlled rate by sinking tubes into the waste and attaching a pump.
In a sewage work, the raw sewage is screened, then pumped into sedimentation tank, where the solid organic matter settles as sludge. The sludge is pumped into huge anaerobic digester tanks; each with a volume equivalent to several houses where it spends about half organic matter is converted into gas36. The basic task is to design, fabricate and test a simple waste digester and gas collection system.
IMPACT OF GOOD GAME MANAGEMENT
It is beyond disputation that good game management would have a positive effect on the nation’s renewable energy and resources. Apart from the fact that game itself is a reviewable source which can be sustained by good game management. It also serves as a viable source of materials for the production of biogas as a form of renewable energy with little negative effect on the environment as fossil fuels like coal, oil and gas e.t.c. do.
There is a growing concern in the world at large and Nigeria in particular on the need for a rational approach in the use of land and natural resources it is now very obvious that without proper planning like the entrenchment of god game management, it will clearly be impossible either to sustain the present yields or to maintain the intrinsic quality of forests and its resources.
Natural resources make up the wealth of a nation. It has equally been accepted as an attribute of nature, which can be exploited by man to his own advantage. However, nature provides opportunities, but it is man who determines which of the elements and attributes of nature constitute resources. Undoubtedly, game species with the attendant benefit of biogas production is indeed a resource.
The management input is very important in that it largely determines the extent to which men can capitalize on the ability of many natural resources to replenish and maintain themselves. The best type of management for a given resource depends upon the quantity, mutability, renewability and re-usability of the resources. Game management is the total flow of a resource from it state in nature through its period of contact with man to its disposal. This involves variety of ways and approaches.
The economic perspective, which considers the ways in which societies attempt to match the supply of resources to the demand for them, the rate and magnitude of supply are determined largely by market forces, in particular, the prices people are willing to pay for them. This suggests the need for continued growth and production of resources in order to meet the needs of the ever-increasing population.
The second approach has to do with the ethics of game species utilization by man. it determines how man ought to use the biosphere for the benefit of mankind as a whole. Game, as element of nature is seen to have value whether of an economic, cultural or aesthetic nature.
There is also the behavioural approach which identifies the socio-cultural traits, and psychological impulses, which affect different societies to make use of the land, water, air and their resources.
Man’s manipulation of these resources has influence on the environment as a whole.
Obviously, when forests and game reserves are preserved, diverse ecosystems and species that serve as ecological buffers are protected from the ravages of the mechanized man. The forest serves as a genetic reservoir of diverse strains of plants and animals life. Each species is a source of genetic information, which, if destroyed, shows the loss of information base forever.
GENERAL OVERVIEW OF FACTORS MILITATING AGAINST GOOD GAME MANAGEMENT
INCREASE IN POPULATION
More people mean more houses and industries and urbanization. All these take up additional land and yet more food must be produced to feed the extra millions. Modern industrialization and urbanization have resulted in widespread deforestation, there are often not enough trees to hold the precious rain in their roots and let it gradually soak into the earth. The torrents wash away top soil, denuding the land. Silt builds up in lakes and ponds making them shallow so that they hold less water. A large portion of precious rain water is lost when rainfall is poor, drought sets in, crops fail, cattle die and villagers migrate to cities adding to the problem.
Notably, deforestation and loss of wildlife are not only the inevitable consequence of population increase. They are often the consequence of mismanagement, greed, commerce and corrupt government.
SCIENCE AND TECHNOLOGY
Every civilization has in it seeds of destructions we are also beginning to realize some of the dangers of widespread use of pesticides in the country and other forms of environment pollution, so that more often than not, we feel science and technology are rushing ahead with their attendant vices. For example, in Britain
Since 1972, both the British and American governments have imposed restrictions on the use of DDT. It is sensible to use less toxic insecticides for general purposes and reserve DDT for special control schemes. The use of DDT was also thought to be responsible for the decreasing population of birds. 37
In West Africa , the new regional framework to ensure the harmonisation of laws, and policies for the registration, monitoring and civilization of pesticides in the region is proposed.
Notably, deforestation and loss of wildlife are not only the inevitable consequence of population increase. They are often the consequence of mismanagement, greed, commerce and corrupt government.
SCARCITY OF ENERGY
In many developing countries, the scarcity of energy is driving more and more people into poverty. A lack of energy also has severe environmental consequences. Those without access to electricity are forced to fell trees for firewood as cooking fuel, thereby accelerating such effects as soil erosion and the loss of wildlife. The energy crisis in Nigeria
In Nigeria Nigeria Mali Rwanda Burkina faso Zambia Zambia
With reference to commercial fuel wood, exploitation is ravaging the ecosystem. Immature live trees are felled indiscriminately for steady supply of firewood to the booming market of enterprise of palm oil producing, fish and vermin smoking.
The Southern Nigeria with a land area of 924,000km2 and 72,000km2 of the rain forest has been reduced to a mere 10,000km2 with an annual destruction rate of 4,000. Only a few high forests are still retained as Reserves.
Desert encroachment has taken over Sokoto, Kebbi, Kastina, Kano Borno State Nassarawa , Niger Plateau State Sokoto State Taraba State
CLIMATE
The implications of a sharp rise in temperature are apocalyptic; environment including man, plant and animal will suffer on way or the other, there will be more intense precipitation, the increased risk of floods and land slides, changes in disease patterns and crop productivity. Britain
Climate change is a challenge. In coastal areas, sea level will rise and the rising sea temperatures threaten fishing activities. Tree planting remains one of the most cost effective ways to address climate change as trees and forests play a vital role in regulating the climate since they absorb carbon dioxide containing an estimated 50% more carbon than the atmosphere. However, the survival of forests requires the protection of the animals in them as well as the trees so that over hunting as the same consequence of climate change as of cutting trees for fuel wood or timber.
POVERTY
Poverty is a fundamental problem of wildlife conservation and management. Poverty often has the face of a female farmer eking out a living from an arid and unforgiving landscape38. In Nigeria
Between 1980 and 1985, after the crash of the crude oil market on which Nigeria
According to the United Nations Development Programme (UNDP) release in 1992, there was an estimate of more than 38 million people in Nigeria
The excruciating effects of poverty are much felt in the rural areas with the attendant results on environmental degradation through tree felling for firewood, hunting and other wildlife depleting activities. Poverty demands immediate exploitations of natural resources that defy any long term conservation effort. Poverty is not only persisting but worsening. More than a billion people earn less today than 20years ago.
POLLUTION
Pollution is not a modern phenomenon. It is not even peculiar to man, and may indeed precede him. Pollution by many in the 20th century is a reflection of population growth, development of technology and the resulting increase in living standard, and consumption habit associated with economic growth. The most serious spread of waste and the destruction of nature can be traced to many causes such as habitat loss – mankind’s conversion and fragmentation of forests, thorn scrub, coral reefs, rivers and many other habitats of wildlife.
Constant deforestation in tropical lands predicts doom for the sustenance of wildlife resources, as extinction would be the most probable result. According to Miller (1979), of the 500 million species of plants and animals that existed on earth, only about 2 million are in Nigeria
What is happening in Nigeria Canada Nigeria
All too often, the rural environment is sacrificed to meet the demands of the city. Wood is cut and sold much faster than it grows or replaced. Unfortunately, the feeble political will and commitment of resources have been slow in breaking the cycle fostered by deforestation in Nigeria
HABITAT LOSS
Instances of unnecessary clearance of vast areas of prime wildlife habitat are tragically many. Wildlife exists on the land and, consequently, changes in the landscape bring about changes in the patterns of wildlife that are part of it. Land-owners and others who modify the landscape by clearing, draining, cultivating, burning, mining, building cemeteries, play the most regrettable role in the wildlife decline and extinction. Another reason is the widespread changes in land use that accompanied growth and development: great and small habitat in the guise of irrigation and power schemes, land settlement plans, reclamation schemes, timber recovery and wood based industries, plantation of exotic industrial materials and transportation system are scaring the land.
In Nigeria, it has been observed that large areas of the reserves in our native rainforest ecosystem located in Onigambari, Olokemeji in Oyo State, Sakomba in Edo State have been cleared and replaced with exotic plants most especially teak and gmellina39.
OVERGRAZING
If tree cutting is destructive, overgrazing in sanctuaries or reserves by domestic livestock is no less so. This is a terrible problem in the Northern part of Nigeria
There is the growing fear that constant deforestation and desertification in tropical lands could lead to the outright extinction of plant and animal species.The clearing of reserve areas for agricultural constitutes in integral part of habitat loss.
There is a high degree of incursion into reserved lands in pursuit of agriculture and by bush meat hunters; such incursions constitute a major threat to the survival of wildlife species.
BUSH BURNING
Bush burning is another contributory factor to habitat and wildlife loss. There are many occasions when reserved lands are set ablaze by pot hunters or game dealers. Where this happened, the forest together with its resources is destroyed. Fire is one of the powerful forces of nature. A raging bush fire can reshape the land, change the balance of plant species, alter the wildlife community and threaten life and property.
A severe fire can promote erosion, when ground is bared to heavy rains, exposed soil is washed away. Plant species are adversely affected by this. Animals that rely on specific native plants are also threatened. In Australia
In Nigeria Kanji Lake National Park
In 1987, there was a report of a leopard which went wild into one of the villages of Gwana District of the Yankari Game Reserve (now National Park)41.
In vengeance of destruction wildlife habitat, lions in particular, appear to have identified humans as prey even in their confinement at the zoological garden. The memory of a pastor who tasked the patience of a lion at University of Ibadan Tanzania
POACHING
Poaching is still a serious threat to many game species. These methods are cruel and wasteful. The plague of game management is the equipment used by poachers, an inefficient weapon, which wounds far more animals that it kills. Ancillary to this is the activities of professional and freelance hunters whose source of livelihood depends on the tracking down of these game species. In this category are the hawkers of game, operators of roadside and motor park restaurants. The avoidable activities of these players culminate in the act of poaching that indiscriminately kills the game species and thereby depletes the population of natural resources God entrusted to their care for the benefit of the present and future generation of this country.
THE STATE OF NATURAL RESOURCES
COLLECTION IN NIGERIA
No other natural resources in Nigeria
The establishment of an up-to-day resources data bank involves periodic survey, data analysis and storage facility which allows quick and ready access to the information.
An essential process in undertaking data collection is mapping. However, the problem of handling large sets of data has been solved by recent developments in computation technology. Geographical Information System (GIS) is a development in computation technology. It is a digital remote sensing technique for data collection and analysis. Remotely sensed digital satellite data and spatial analysis techniques provide land cover information. They also facilitate map updates as their information on habitats are availed. This helps in the evaluation and monitoring of wildlife habitats.
Other methods in data bank include Environmental Sensitivity Index (ESI), Environmental Sensitivity Mapping (ESM), Environmental Impact Assessment (EIA) and Reach Sensitivity Index (RSI).
The preservation of forest together with the wildlife resources could serve as nature bank.
INTERPLAY OF AN EXCHANGE ECONOMY AND LOSS
OF GAME MANAGEMENT
The wonders of wild nature are part of the wealth of Africa and of mankind, which the world cannot afford to lose. Few other counties in the world, apart from Nigeria, possess such an abundant and varied fauna as to be found in Kenya, Uganda, Tanzania, Zambia, Namibia, South Africa and others. Yet this unrecognized wealth is allowed to be dissipated through failure to appreciate its significance in developing an exchange economy particularly in the tourism sector.
Whether or not the present generation of Africans, know it now, the time must come when more Africans with their intense, deep-seated love of the earth, begin to know and appreciate the exhilaration of wild places and will realize more and more that unless process walks in harmony with game management, it can be little more than a superficial veneer.
Today, wildlife conservation and tourism are now developing in Nigeria Lekki Peninsula Nigeria
Game reserves provide unique environments, which attract the tourist. The excitement of seeing wildlife at a close range, in a quiet atmosphere, reminds us of the amazing beauty of nature.
Throughout the 31st edition of International Tourism Exchange (ITE) Berlin, 1997 when Nigeria made her first formal entry after having participated as observers in two previous events. Nigeria Nigeria Nigeria
Tourism, being a short-term movement of people to destination outside their residential area primarily for leisure, recreation, sports and business transactions is important in one’s life. As the adage says, travelling is part of life experience. There is domestic and international tourism. Tourism has been an all year business but it is on the increase during the months of December to March when the weather in Europe and North America is severe.
Tourist industries constitute the natural features such as lowering mountains, beaches, waterfalls, museums, game reserves and National Parks, which make up the sizeable proportion of tourist industries throughout the world. Countries with abundant wildlife witness more visitors because people are often attracted to their habitats.
Tourism is therefore not yet fully developed in Africa but some parts of Africa have become popular tourist centres as is the case with East Africa (Kenya Tanzania Uganda East Africa , tourism is best-developed in Kenya Yankari National Park Nigeria
Importance of tourism in forest exchange earnings cannot be underestimated. Tourism provides East Africa and developed counties with a considerable foreign exchange. Kenya Kenya
The contribution in Nigeria
In conclusion, it is beyond doubt that good game management plays a prominent role in foreign exchange earnings for the government and portrays Nigeria
APPRAISAL OF CONTEMPORARY ISSUES ON GAME
MANAGEMENT
WHO OWNS THE GAME?
During the period of 1850-1900, there was little attempt in the countries of the world to limit adequately landowner’s right to alter the landscape which ultimately brought about the changes in the patterns of wildlife that are part of it. Legislations shorn of substance freed the landowners from restriction, and also opened private lands to the uninvited who came in search of fish and game. Trespass laws were apparently feeble, especially those governing vacant lands whilst the costs of trespass on wildlife borne by landowners were negligible.
The above, in effect was due to the relationship between land-use patterns and wildlife abundance not being generally appreciated in the 19th century as global recognition had to wait 20th century when game management became the order of the day.
The developments during this period brought more significant changes in limiting the access of landowners to game on their own lands. The virtues of private property in land were widely promoted by landowners and accordingly formed the inspiration for models of game management that threatened the notions of common ownership which both the sportsmen and market hunter relied on.
Another thing worthy of mention is the conflict between the “Plan Farmer” (Sportsmen) and “better class of townsfolk”. The customary liberties of the landowner and of the hunter could not but threaten each other as the number of hunters grew, as agriculture spread and was intensified, and the object of the hunt became more valuable. Sportsmen sought to reduce the conflict by distinguishing themselves from other classes of hunters whom they accused of abusing private property.
Everything submerged into the ownership of wild animals. If wildlife were recognised as common property, could common owners then pursue animals wherever they sought refuge, even on private property? How much control would the state, as trustee for common owners (as contemplated by Nigeria
The above vexed questions remained unresolved till today. Federal, state and local governments and their agencies and private organizations keep a close watch on the population of all the game species so that the misuse of this natural resources is almost precluded. Whole ownership theory is now regarded as but a fiction expressive in legal order and of the importance to its people that a state or government has power to preserve and regulate the exploitation of importance resources like wildlife.
In Nigeria, the federal and states’ role in wildlife protection finds support not only in the erosion of the common law principal of private property but also in the powers enumerated in the 1999 Constitution, enabling authority of the Federal and state governments to regulate access to wildlife on public land through the establishment of National Parks and game and forest reserves is contemplated ion item 40 of the 2nd schedule to section 4 of the Constitution. This has also been broadened to include the regulation of access on private land where such access imperils wildlife as natural resources, a federal property. This is indirectly done through imposition of taxes on firearms and licence fees for the regulated killing. Fund derived from these taxes and licences are for wildlife research and enforcement of law regulating their management.
THE ESSENCE AND RATIONALE OF LEGAL
PROTECTION OF ANIMAL RIGHTS
The analyses of essence of various restrictions protecting animal rights and game management will focus mainly on wild animals because they deserve serious attention considering the present trend of battered Earth-These analyses will be randomly done. They are also important because they deal mainly with the utilization and management of wildlife.
It is the fundamental law of Nature that the conservationist strives to emulate. Nature is not distantly related and remotely interested in the survival of the individual but is profoundly concerned with the species. This does not imply advocating the adoption of a callous attitude towards animals nor does it amount to support of controlled or indiscriminate killing in any circumstance or slaughter to satisfy a blood lust. Controlled harvesting of the wildlife which is the aim of the law is not only justifiable but also a realistic method of managing wild population, a method which allows the off-take of the annual surplus but regards the basic stocks as sacrosanct.
The following examples may assist in manifesting what has been achieved in other parts of the world, and at the same time, demonstrate to Africans and Nigerians in particular, that even in the most advanced countries, the conservation of wildlife far from being retrogressive, is regarded as one of the badges of civilization.
In Russia Soviet Union . Despite the prohibition by 1930, only a few hundred remained, due to a combination of poaching, wolf predation and exceptionally severe winters. Special measures were taken to protect the species and within ten years, the number of saiga had been restored to the level of century ago and today, the total saiga population has reached approximately 200 million. The annual harvest is between 150,000 and 200,000 saiga43.
No less remarkable are the achievements of a small densely populated and intensively developed country such as Denmark
In 1960, bearer quota for Quebec
In Africa , no other country has gone nearer to total elimination of its fauna than South Africa Nigeria Union . The Union government46 became very concerned at the widespread depletion of wildlife and established a number of “game farms” where basic breeding stocks could be maintained and increased under legal order.47
In Zambia through this legal restrictions or regulations over a period of several years, the average annual killing was 1,343 zebra and 203 wildebeest and the annual income amounted to approximately £8 for each wildebeest and zebra, income was achieved without the necessity of design, dipping, fencing, watering and supervision as would be necessary when ranching cattle48.
The above illustrations exemplify the economic value of wild animals and show that the production of game meat, either as a primary method of land utilization, or as a means of obtaining supplementary income from ranches side with livestock can provide a valuable source of income from ranching kind. Domestic animals are selective feeders and many of the so called weeds which they found not palatable are consumed by wild animals. This natural method of controlling weed growth by means of wild animals actually improves the grazing for cattle. The economic potentialities of the natural fauna have hitherto scarcely been appreciated, wild animals will no longer be nature are part of African’s wealth and of mankind, which the world possessed such an abundant and varied fauna as was to be found in Kenya, Uganda, Tanzania and Nigeria, yet we have allowed this unrecognized wealth to the dissipated through failure to appreciate its significance. The rationale behind Animal Rights laws is manifold. On the one hand, it is restrictive, whilst on the other hand; it is humane particularly with regards to livestock (or) domestic animals.
Animals provide some ecological services, for example non-consumptive use, Tourism has also been known to be an important source of revenue. Estimates of the actual contribution made by components of the ecosystem in ecotourism have only recently been calculated in Kenya
The benefits of protecting animals habitats include: stabilizing hydrological systems, protecting soil; contributing to stability of climate; conserving renewable resources; protecting genetic resources; preserving breeding stocks, population reservoirs and biological diversity; maintaining the natural balance of the environment; supporting tourism and recreation; creating employment opportunities; providing facilities for research; monitoring, security purposes, post and telecommunications etc.
On facilities for research education, the attitudes of some animals offer useful lesson. For example, a killy-loo bird which files forward but looks backward makes an easy explanation of the doctrine of judicial precedents in the study of law. This principle has been likened to the bird by some eminent jurists. If the rights of these birds were arbitrarily violated and the knowledge of their habitats was not known until they went into extinction through the gross disregard of their rights, what would then be the best idea to be used in explaining the principle of judicial precedents that is inevitably based on the killy-loo bird principle. It is in doubt whether any species of the bird is still in existence in any part of the world.
As for security, recreation, agriculture, post and telecommunication, horses perform indispensable work in these areas. What lovely animals they are. Some are mounted by the police or the army personnel, while others are intended for racing and pole game-ponies for riding and for pulling a carriage are also available. Horses for Post and Telecommunication Services were popular in the ancient empire of Persia
These dependable relay riders with horses stationed at proximately 14 mile intervals were the preferred means which were devoid of strikes and sabotage, to deliver King Ahasuerus’ counter decree that would save Jews from genocide during the 5th century. There are also contributions which are not usually reflected in official economic indicators among which are:
(a) Contributions of new domestic species, for example, there is an Australian Emu, a large flightless bird similar to ostrich. In 1991 emu meat was legally classified as a form of poultry. A spokesman from the Australian National Parks
(b) Use of wild species to improve domestic lines: References could be made here to sheepdogs being used in sheep raising business. These dogs will bark and maneuvers the sheep by running across their backs to get to a strategic position. Some will go right up to a sheep and look it in the eye, intimidating by looking rather than by barking. These faithful animals work until they drop from exhaustion.
(c) Contribution to livestock industry as examined under paragraph (a).
(d) There is cross-fertilization by many wild species, for example, an animal called quagga which partly resembles the zebra and partly resembles the horse existed for sometimes, before going into extinction several years back. There is no single species of these animals throughout the world except the art work of how it looked like. The high-water mark of the awareness of the need for caution in dealing with these animals through the recognition of their rights was manifested in the efforts of some developed European Communities in recalling or recreating Quagga through the cross-breeding of zebras and horses and the first set of ponies have shown a promising sign that quagga will surface again53.
(e) Biological control of many pests by wild species. In this wise, owl may be mentioned as been instrumental to the realization of this goal. Unlike the eyes of most birds, the owl’s eyes face forward; it cannot move them in their sockets. Thus, owls must move their heads to follow moving objects and the can turn their heads through almost a complete circle. Their nocturnal swoopers feathers’ design allows them virtually soundless flight locating their prey by sight or by acute hearing, they can swoop down silently for their next meal. They are said to be “among the most useful birds to farmers” because they destroy rodents that often damage crops.
Furthermore, if wildlife is seen as not being able to generate revenue, it is not because the resources are without intrinsic value. For instance, the development of radar technology is not unconnected with the science of echo-location in bats; the idea of night scope mono/binoculars must have been borrowed from the night vision ability of owls; test of leprosy drugs on Armadillo is possible because it is the only other known animal which suffers from the ailment apart from man54.
In medicine, bear’s most valuable excretion; bile from their gall-bladders is a highly prized remedy in traditional Chinese medicine. Bear bile is used to treat a range of complaints ranging from cancer, hemorrhoids, conjunctivitis and sinusitis. The gall bladders themselves are used for serious liver diseases including cancer and cirrhosis55.
On hygiene, the small African antelope and domestic cat set a wonderful example in that before they defecate or urinate, they first clear a sport with their front hooves or legs an then, afterwards, carefully cover the contents by scraping soil over the spot. These little creatures go beyond the law56 given to the Israelite soldiers. Even they cover their urine. Also, vultures have the virtue of being eminently useful. Although, many birds benefit mankind in one way or another, vultures perform a unique service. They are sanitary inspectors of the skies. Cleaning up carcasses is not everybody’s idea of a favourite daily chore, but it is an important job, proper sanitation requires the prompt removal of dead bodies which can be dangerous sources of infectious diseases for both man and beast. Here, the vultures come in. Even meat contaminated is gobbled up with impunity until nothing remains but the bones. Some vultures even specialize in eating bones. The lammergeyer-vulture of Eurasia and Africa drops bones split open; the lammergeyer eats the marrow and the smaller pieces of bone. Fortunately, unlike their human counterparts, these “sanitary inspectors” have never gone on strike.
If the work of vultures were left undone, tropical plains littered with disease-ridden carcasses would be a familiar sight. Throughout the day, squadron of vultures tirelessly patrols the skies in search of dead animals.
Apart from the foregoing, there are many lessons being learnt from these animals. for example, with regard to parenthood, vulture once against is a bird that takes parenthood very seriously. Every year an “only child” receives the undivided attention of both parents until it can fend for itself. A young vulture chick perched helplessly for several months on an inaccessible ledge certainly needs the compassionate care of both parents. This knowledge is more than what Family Planning and programme against Child Abuse offer.
In addition, the Cape buffalo’s reputation as a fearsome beast is thus underserved. Having come to know this beast a little better, we can see it, not as a mindlessly aggressive juggernaut, but as a peacefully example of co-operation that is worthy of contemplation57 perhaps even imitation. If the heard is menaced, the bulls will take on the role of protectors for the cow and calves. They will automatically take the rear guard, the most dangerous position and will be the last to run. When danger strikes, the spirit of co-operation quickly becomes apparent. A buffalo will sound the alarm by letting loose a loud snort, soon, the whole herd rallies to its call.
It may however be judged from the foregoing, that it, the economic, consumptive and non-consumptive benefits brought about by the existence and good treatment of these animals, that, it is imperative that the rights of these animals should be protected as contemplated and decreed by UNESCO in 1978. Otherwise we may as well kill all the geese that are laying the golden eggs and our society will be worse for it. Indeed, all the necessary materials to move the society forward may have well have been destroyed through the handiwork of human beings in their questionable quest for their selfish ends. It is unacceptable to have no better reason for an attitude prejudicial to the existence, management, good health and humane treatment of animals than so it was done in the past. It is still more unacceptable if the grounds upon which it was perpetrated have vanished long ago for want of necessity and good environment and the attitude persists from blind imitation of the past.
1. Dictionary of Law 3rd Edition
2. Laws of Nigeria
4a. Zoo licensing Act 1981 (S. 210); Animal Health and Welfare Act, 1984;
Animals (Scientific Procedure) Act 1986; protection of Animals (penalties) Act 1987 (Amending Section 1(1) of the protection of Animals Act, 1991.
4b. Howel Davies; Tse-Tse flies in Northern Nigeria. , pages 1-5, 2nd Edition published in 1967.
5. Legal personality-any being capable of bearing rights and duties.
6. Daily Sketch of 6th June 1990 page 1
7. Prof. A.O. Popoola’s lecture on Jurisprudence at the Faculty of Law, Obafemi Awolowo University
8. National Concord 14th June, 1990 .
9. Section 2 of Animals Act; 1971.
10. Sectio9n 5(3); Section 3 and section 5 of Animal Act; 1971.
11a. Dogs(protection of Livestock) Act 1953 Criminal Justice Act; 1967.
11b. Section 4-7 Animals Act; 1971
*1 Local hunters operating single or groups.
12. Megal Charles R-Keyguide to Information in Animal Right published in 1989 Mansell, London
13. Ibid
14. Ibid
14a. Section 4 of the Act
14b. 1968
15. 1828 and 1844.
16. Laws of Nigeria Nigeria
17. James A. Tober- who owns the wildlife? published by Reenwood Press, 1981.
17a. (1948)2 K. B. 311
18. These codes are Crown copyrights
19. The convention was opened in 1968 for signatures by member counties
20. 1969 Decree
21. Cap 56 Laws of Nigeria
22. Ibid
23. Limited to those owning real estate with rental value of 40 shillings per year; the king of hares colonies orders and dogs keeping.
24. (1875) 60 N.Y. 10
25. Counsel for the New York Association for many year until his death in 1903
26. 161 U.S.
27. (1979) 47 U.S L.W. 4447; 9 ELR 10106
28. (1942) 126 F. 2nd 317.
28a. Subsections 2 and 5 of the National Park Service Decree 1999
29. Laws of Federal 1990.
30. Ibid
31. He who owns the land owns everything underneath, and above it up to the sky.
32. 7th Edition- Bryan A. Garner published in 1999
33. The Post Express, Wednesday October 9th, 1996 page 20.
34. Understanding Energy www.energy .org.uk
35. Ibid
36. Renewable energy resources by John. W. Twidell, page 302
37. Chemistry in context 2nd Edition 1983 Grahan Chill, John s. Holman.
*2 The Guardian, Tuesday, July 17, 2007 . Page 77
38. National Concord Thursday, August 22, 1996 .
*3 Awake magazine, April 8, 2005 page 28.
39. National Concord Thursday August 22, 1996
40. Awake magazine, September, 22, 2002 page 24.
41. Environment and Tourism in Nigeria
42. Environment and Tourism in Nigeria Edited by Bayowa Chokor Ojediran (1990) Rediscovering the Rejected stone. The Guardian, Thursday, Sept. 27, 1990 page 9.
43. Each yielding an average of 60 Ib meal and a valuable skin and yet they continue to increased page 275 of the wildlife of Kenya
44. Ibid- page 276
45. Ibid- page 276
46. South African Government before Independence
47. Noel Simon- Wildlife of Kenya
48. M.C. Neely J.A – Economic and Biological diversity. Developing and using economic incentives to conserve biological resources published in 1988.
49. Awake magazine, 14th August 2004 page 5.
50. Awake magazine of 8th April 1993 Edition- page 18.
51. Awake magazine of June 22, 1993 Edition -page 28.
52. A documentary programme on wild Animals on Nigeria Television Authority, Ibadan Network in 1995.
53. Awake magazine of April 22, 1993 Edition.
54. Federal Environmental protection Act Monograph 3 page 35 edited b E.O Aina and Adedipe.
55. The Economist page 84, November, 9th- 15th 1996.
56. Deuteronomy 5:1; 23: 13, 14.
57. Awake Magazine of June 8, 1993 Edition page 24-25.
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