How to move a motion in Court.

■ Introduction

Moving a motion in court is very easy. In fact, appearing in court for any matter is very easy, you just need to understand what you came to court to do, and be very confident in yourself. And do not fail to ask your seniors questions. If you forgot or don't know what to do in court or how to do it, ask questions.

■How to move a motion.

Motions can be moved in two forms. It can be moved completely, or in terms. Let us examine both ways.

■ Moving a motion completely.

In Moving a complete motion you telling the court everything.

Example. Let us use an hypothetical motion. (Remember, it is all about knowing what you are doing, and confidence, or boldness, anyone you call it).
Every motion has a motion number.

■ First things first.
Address the court. (Announce your appearance)

Before my Lord is P.L Osakwe (it is not compulsory to use Esq, this is because everyone who appears in court as a lawyer and addressing the court as one is already seen as Esq. However, do not go and impersonate as one).

My Lord, my humble appearance is for the Claimant/Appellant, in this case. (This is because, it was your client who filed the motion, and he/she is also the claimant. If your client is the defendant, you will have to announce your appearance for the Defendant/Applicant.

■ Second.
Identify your motion.

Before this Honourable Court is a motion on Notice. Marked, Motion No. 22537/2025 (hypothetically). The motion is dated the 10th day of May 2025, and filed same day or on another day, mention that day.

■ Third.
The law or rule it was brought upon.

My Lord, this motion is brought pursuant to Order 3 rule 1 of the High Court of Lagos State (Civil Procedure Rules) 2015, and under the Inherent jurisdiction of this Honourable Court.
(Do not forget, the Orders and Rules are hypothetical)

■ Forth.

Prayers.

My Lord, the motion prays as follows:

a) An order of this Honourable Court granting leave to file our Statement of Defence out of time.

b) and further other(s) as the court may deem fit to grant in the circumstances of the case.

You have moved your motion successfully.

But it doesn't end there. The rules of Court says that every motion shall be accompanied with an Affidavit and a written address. Thus, you must have filled an Affidavit and a written Address alongside the motion.

Now, this is the time to identify and adopt your Affidavit and Written Address.

■ Fifth.

Adoption and placing reliance on the Affidavit.

My lord, accompanying the motion on notice is a 17 paragraph Affidavit, deposed by one Mr John Stuart, on the 16th day of June 2025. My lord I/we wish to rely on all the paragraphs of the Affidavit.

■ Sixth.

My lord, Counsel has also taken the liberty to file a written address in compliance with the rules of Court. My lord, I/we wish to adopt the written address as our argument in support of the motion.

■ Seventh.
Urge the Court.

I/we urge the my lord grant the motion as prayed.

However, If party on the other side, reacted to your motion and filled a Counter affidavit. Inform the court as follows;

My lord, i/we are in receipt of the Counter Affidavit of counsel on the other side, challenging our motion. We urge this Honourable Court to discountenance their argument, as it doesn't directly affect the grounds of our motion, (or anything) and to so grant our prayers as prayed.

May It please, my Lord.

■ Moving a Motion in terms.

Announce appeance

Identify your motion (supra)

Then say, I move in terms of the motion paper.

I urge my lord to so grant as prayed.

That is all.

■ Take note.:

It is the court that will ask you to move in terms. You don't just move in terms.

Good luck.