In 1946, Nigeria adopted a NEW CONSTITUTION themed THE RICHARDS CONSTITUTION. Richard constitution of 1946 replaced the defective Clifford constitution of 1922. It was due to the weakness of The Clifford Constitution that made the Nigerian nationalists to pressurize Sir Bernard Bourdillon, the Governor of Nigeria from 1935 to 1943, to give them a new befitting constitution and He should equally split Nigeria into three regions of North, East and West in 1939. The memorandum issued by Sir Bernard