Can churches/mosques propagate religions by establishing schools?

Section 38(3) provides:

No religious community or denomination shall be prevented from providing religious instruction for pupils of that community or denomination in any place of education maintained wholly by that community or denomination.

Under the provision, religious institutions are empowered to give religious instructions in schools established by them, which indirectly empowers them to establish schools. The court so many years ago once declared unconstitutional a circular which purported to indicate that only public schools can operate in Lagos state.[1]


[1] Adewole v. Jakande (1981) 1 NCLR 262; See also Okogie (Arch Bishop) v. Attorney General Lagos State (1981) 1 NCLR