Nigerian courts had in the past held that motive which impels the termination of an employment is immaterial. For example in LCRI v Mohammed, it was held as follows:
An employer need not show any motive or give any reason for terminating the employment of his employee. Motive does not vitiate the validity of the exercise of a right of an employer.
The decision of the National Industrial Court of Nigeria in Rubber Research Institute of Nigeria v SSAITHRIAL has now changed that position, in which the court held thus: