QUESTION 3 Mallam Garba, an uneducated sugarcane farmer in Kaduna State who can neither read nor write in English, was approached by Mr. Jude, an agent of Arewa Sugar Refineries Plc. Mr. Jude presented a document to Mallam Garba and orally represented to him that the document was a simple receipt for an advance payment of N300,000 for his upcoming sugarcane harvest. Believing Mr. Jude, Mallam Garba affixed his thumbprint to the document. In reality, the document was an absolute 15-year lease of Mallam Garba's 100-hectare farmland to Arewa Sugar Refineries Plc for an annual rent of N20,000. Furthermore, the document failed to contain an illiterates' protection clause or the signature of an attesting magistrate/notary public as required by law. Meanwhile, Arewa Sugar Refineries Plc contracted with Northern Bottling Ltd to supply 500 metric tonnes of refined sugar by November 30, 2023. Northern Bottling Ltd paid an advance deposit of N10,000,000. On November 20, 2023, an unprecedented structural collapse of the federal dam caused catastrophic flooding that completely destroyed Arewa Sugar Refineries' sole processing factory, making refine sugar production impossible. Required: (a) Advise Mallam Garba on his legal rights to set aside the lease document, relying on the defence of *non est factum* and the provisions of the Illiterates Protection Act. (10 Marks) (b) Explain the effect of the dam collapse on the contract between Arewa Sugar Refineries Plc and Northern Bottling Ltd, and determine the legal status of the N10,000,000 advance deposit under the Law Reform (Contracts) Act / Law of Frustration. (9 Marks) (c) Distinguish clearly between Complete Performance and Substantial Performance as modes of discharging a contract, making reference to the rule in *Cutter v Powell*. (6 Marks) (Total: 25 Marks)