“If the law does not recognize a contract to enter into a contract, if a fundamental deadline still needs to be agreed, it cannot recognize to me that a contract must be negotiated. The reason is that it is too uncertain to have a binding force. It seems to me that a bargaining agreement, such as a contract to enter into a contract, is not a contract known to the law… I think we need to apply the general principle that there is no treaty if a fundamental issue remains undecided and is being negotiated.¬†As was decided in Ogbebor vs. Utagba Rubber Estate – Anor, it is the duty of the court to interpret an agreement reached by the parties under enforceable conditions, but not to rewrite the agreement. As a result, Nigerian courts would impose a clause requiring the parties to negotiate in good faith the resolution of their dispute before resorting to litigation or arbitration proceedings. In Star Finance – Property – Anor vs Nigerian Deposit Insurance Corporation, the Nigerian Court of Appeal stated: “A letter of intent can be nothing more than a document containing the preliminary understanding of the parties willing to enter into a contract or agreement based later on these conditions in this document.” It is customary for parties to trade agreements to contain clauses requiring them to negotiate in good faith the settlement of disputes that arise between them during the execution of a contract before resorting to arbitration or litigation. The objective is to ensure that, in most cases where treaties continue, the parties seek in good faith to reach an agreement without having a significant impact on the continuation of the treaty.” The agreement, which requires the parties to negotiate in good faith, is also called “agreement to be agreed.” Morris confirmed the principle that general standards that prescribe how parties try to agree on conditions such as. B “best efforts” or “best efforts” do not make an agreement enforceable.12 This is an important explanation of the court`s current direction in this regard and is a timely reminder that each case will use its particular circumstances. 13 In this article, as a result of our earlier update to the case, we examine the existence of Morris/Swanton Care – Community Ltd (Morris) in the last Court of Appeal. 2, in which the plaintiff sought to invoke a contractual option to provide additional services for “a period that was reasonably agreed” as the basis for a claim. Finally, a number of wording points can be drawn from the judicial treatment of the agreements to be agreed upon.