Before the establishment of British judicial institutions in Nigeria, disputes were settled through the machinery of indigenous traditional tribunals. The character of these varied from one area of the country to another. In the Eastern part of the country, the machinery of justice was rudimentary and in no sense institutionalised. The strong tradition of chieftaincy which existed in the North and West enabled these areas to possess fairly well organised traditional tribunals. From 1898 the government of the Niger Coast Protectorate, in agreement with the local communities, began to create systematised native courts. These courts were purely administrative creations which were neither established nor controlled by statute. In 1900, the Grown took over from the Niger Company and by the Native Courts Proclamation established native courts on a statutory basis in the Protectorate of Southern Nigeria. The system of native courts created by this enactment was modified in subsequent years. In 1948 the Brooke Commission of Enquiry was appointed for the Northern, the Eastern, the Western Provinces and for the Colony to review the operation and jurisdiction of the native courts in the various parts of Nigeria. With the introduction of the federal system of government in Nigeria in 1954, the native courts became a residuary matter on which Regional Legislatures alone could legislate. In the subsequent statutes on this matter, the Eastern and Western Regions adopted the new title “customary court” while the Northern Region retained the old title of native court.