By Idowu J. Lawrence Esq[1].
![](https://thenigerialawyer.com/wp-content/uploads/2024/11/TheNigerialawyer-WhatsApp-Channel1.jpg")
Introduction
The relationship between banks and customers dates as far back as 2000 BCE when Mesopotamian merchants were involved in the trade of lending and deposits[2]. However, the first formal banking institution was established in 1472 when Banca Monte dei Paschi di Siena[3], started loan providing operations. It was situated in Siena, Italy. Formal banking activities was introduced to Nigeria in 1892 when the African Banking Corporation[4], which later became the Bank of British West Africa 1894, was established. It ultimately metamorphosed into First Bank of Nigeria, established by Sir Alfred Jones – which prides itself as the first and the best[5].
In Nigeria, the relationship between a customer with funds in his account and his bank, has been described as that of debtor-creditor[6], the bank being primarily the debtor. But roles often switch depending on who is in possession of the other’s fund, as in a case where a customer has taken loan from a bank. Any party is entitled to sue for recovery of the funds in the other’s custody, within the circumstance[7].
Outside a situation where a customer is indebted to a bank via a facility with terms, the bank is often shouldered with the duty of diligently following the instructions of the customer and to act in good faith as a fiduciary[8]. When anything happens to the funds in the customer’s account with the bank, the bank is primarily responsible for the loss[9]. This is much so important especially as the funds in a customer’s account domiciled with the bank is considered moveable property protected under chapter 4 of the Nigerian Constitution[10][11]. Where an authorized withdrawal is made from a customer’s account, the bank is mandated to provide an explanation within 72 hours, failing which the bank becomes liable without protection under any indemnity clause(s)[12]. The refusal of a bank to honor a customer’s cheque where the account is adequately funded, is heavily sanctioned with interests and damages at large (without limiting measures)[13].
Regulatory Framework for Banking in Nigeria
The principal legislations for the Banking system in Nigeria are the Constitution, the Banks and Other Financial Institutions (BOFI) Act (as amended), and the Central Bank of Nigeria Act 2007. The Banking system in Nigeria is regulated primarily by the Central Bank of Nigeria. While serving as banker to the Government of Nigeria, the bank doubles as the Apex regulatory body for banks in Nigeria, issuing operational licenses, serving as bankers to the bank, and other supervisory functions including powers to review the performance of distressed banks.
Due to the premium placed on depositor’s funds with the commercial banks, the Central Bank is empowered to conduct a special examination into the books and affairs of any commercial bank, whenever the Governor considers it important to do so with immunity[14]. In doing this, the Governor is empowered to remove any bank official to ensure efficiency, without any exposure or vulnerability to legal action, if such action was done in good faith[15].
In other words, the Governor of the Central Bank is first amongst peers and could remove any banking official and appoint their replacements – be it Chief Executive Officer, Director. Indeed, this was the situation in 2009[16] when many bank officials were sacked by the then Governor Sanusi, who superintended over the mergers of the concerned banks with other existing banks. To this extent, the intention of the lawmakers is manifested towards the protection of the depositors/customers, in safeguarding the right to property of the citizens.
Meanwhile, due to the probable misuse of the banking system, the regulatory laws also provide for the powers of the CBN to interfere with the depositor’s account when there is a likelihood that such account is being used for criminal purposes. For instance, the BOFI Act also empowers the Governor of the Central Bank to restrict certain banking activities all for the purposes of public interest[17]. While the CBN Act 2007 is the hominem legislation, the Banks and Other Financial Institutions Act introduces detailed provisions on the powers of the CBN in regulating activities commercial banks. Originally enacted in 1991, it was subsequently amended in 1997, 1998, 1999 and 2002. One of the sections introduced in the 2002 amendment reads as follows:
Power of Government to freeze accounts
(1) Notwithstanding anything contained in any other enactment, where the Governor has reason to believe that transactions undertaken in any bank account with any licensed bank are such as may involve the commission of any criminal offence under any law, he may make ex parte application for an order of the Federal High Court verifying on oath the reasons for his belief, and on obtaining such Court Order direct or cause direction to be issued to the manager of the bank where the account is situated or believed to be or in the alternative to the head office of such bank directing the bank to freeze forthwith all transactions[18].
This provision, introduced with the phrase “Notwithstanding”, is nothing short of a mandatory provision as to process and procedure. By this express wording of this provision, the Apex bank, and other banks by implication, could not unilaterally deal with a customer’s account even when such is suspected to be involved in criminal activities, without obtaining an exparte order from the Court.
Unfortunately, this specific provision which stipulates how the CBN should interfere with a customer’s account by approaching the court for an exparte freezing order when crime is suspected, was inadvertently omitted when the Laws of the Federation was codified in 2004[19]. This omission introduced a high level of catastrophic effect on banking operations, especially for depositors.
The Impactful Omission (and additions)
When the Laws of the Federation was codified in 2004, this provision within section 60 of the 2002 amendment of the BOFI Act, which requires the CBN Governor to obtain an exparte order before freezing an account suspected with criminal activities, was “inadvertently” omitted[20]. Not only that, the LFN 2004 also included some repealed provisions[21]. This means some courts would have applied laws that were repealed or were unable to apply those in existence through this omission.
Upon later realizing this error after the publication of the Laws of the Federation 2004, the National Assembly made efforts to correct this, by enacting the Errors and Omissions Corrected in the Banks and Other Financial Institutions (BOFI) Act LFN 2004 cap. B3. The omitted section was then re-introduced through an Appendix[22] awkwardly termed as Section 60B. Unfortunately, the chaotic horse of judicial inconsistency and institutional tyranny had bolted. This was notwithstanding the re-enactment of the Banks and Other Financial Institutions (BOFI) Act in 2020 which reintroduced the omitted provision on procedure for freezing/restricting customer’s accounts.
Institutional Tyranny and Judicial Uncertainties
In 2021, the former Governor of the Apex Bank – Godwin Emefiele, under the powers conferred on him by the CBN Act, issued a guideline/circular to commercial banks directing them to restrict accounts trading in Virtual Assets/Cryptocurrency, due to “money laundering and terrorism financing (ML/TF) risks and vulnerabilities inherent in their operations as well as the absence of regulations and consumer protection measures[23]”. This postured as something done in public interest purposes but there was a problem. Could the CBN Governor issue such blanket directive that interferes with customer’s properties merely through a regulatory directive, outside of an enacted legislation?
When later in the year, the CBN itself obtained an order to freeze some accounts suspected of trading in Virtual Assets/Cryptocurrency, based on the CBN directive, some parties affected challenged the ex-parte order in Court. In resolving the issue against the Apex Bank, the Court made it clear that the CBN lack powers to interfere with customer’s account based on its directives alone, which is short of an enacted law[24]. The Court added that the CBN could only exercise its powers to freeze or restrict customer’s account, not through a directive/circular but the procedure stipulated by Banks and Other Financial Institutions (BOFI) Act, which is limited to individual accounts suspected of criminal activities, not a blanket or collective sanction or restriction without lawful basis.
By this time, the Banks and Other Financial Institutions (BOFI) Act had been re-enacted in 2020, and its section 97 properly re-introduced the omitted section on procedure for freezing/restricting an account. Regrettably, the most popular Laws of the Federation codification remains the LFN 2004 that is riddled with many omissions and additions, meaning many lawyers or judges remain unaware of this new law – BOFI Act 2020[25]. In a recent publication, the calamity induced by the notorious LFN 2004 on the issue of Appeals from the LPDC for lawyers, and how lawyers continue to suffer professional fatality therefrom, was chronicled[26].
One year later in 2022, the Court of Appeal came to the aid of Mr. Opara whose case was thrown out at the High Court. His Bank had, without notice to him, closed his account, on the instructions of CBN and EFCC without a Court order. On appeal, the Court of Appeal demonstrated commendable efforts in explaining that the CBN and the EFCC had no such powers in the face of the provisions of the BOFI Act. It however relied on the omitted provision of the repealed BOFI Act 2002 which court assumed was still in force, notwithstanding the enactment of the BOFI Act 2020.
Meanwhile in 2020, Mr Ipinloju Damola had his account frozen by Zenith Bank on the instruction of the Economic and Financial Crimes Commission (EFCC). The agency had instructed the bank thereto, pursuant to its statutory powers[27] which allows the agency to direct the freezing of an account suspected of fraud for 72 hours and obtain an order exparte to sustain the instruction. After the bank froze the account, the agency filed an application for an order exparte to sustain the freezing of the account, but the application was not heard timeously within the 72hours statutory provision. Ordinarily, this should indicate the instruction had lapsed and the bank should unfreeze the account, but the bank did not.
Mr Ipinloju Damola filed an action in 2020 at the Oyo State High Court against the agency, its officials and the bank, seeking to rely on two 2019 Court of Appeal decisions [28] that stipulate accounts could only be frozen by a court order. In 2022, the High Court ruled against Mr Ipinloju, who then took his fight to the Appellate Court. The Court of Appeal in February 2024, held that the cases he relied on were of no assistance to him because unlike in them, the agency in this case had filed for the order exparte but the court delayed in hearing the application. This position of the court presupposed that the court would grant the order exparte as a matter of course, but nothing in the statute mandates such. It also amounts to a volte face with respect to the Court’s decision in the 2022 Opara Henry v Access Bank[29] which mandates the CBN or the EFCC to obtain a court order before interfering with customer’s account.
The Court further added that, the existence of a CBN circular allowing a bank to freeze or restrict an account suspected of fraud, validates the action of the bank in complying with the EFCC directive, even beyond the 72 hours in the absence of an order[30]. The Court conceded, however, that the circular was not placed before the Court to interpret[31]. In essence, the Court upheld a circular which the Court admitted it hadn’t seen nor reviewed and thereupon gave imprimatur to banks and law enforcement agencies, to interfere with customer’s account on mere suspicions, outside of the court’s supervision. This is notwithstanding the 2021 well-publicized decision of the Federal High Court that a bank could not rely on a circular to interfere with customer’s account in the face of the provisions of the BOFI Act[32].
Later in December 2024, the Ekiti Division of the Court of Appeal elected to rely on the Ibadan Division’s latest imprimatur in holding that a bank had the liberty to rely on its terms, and the CBN Circular in freezing a customer’s account on suspicion of fraud. In this case filed by a certain Mrs Blessing Amarachi against Kuda Bank[33], the Court’s decision seems to suggest that obtaining a Court order is merely one of the options a bank has in interfering with a customer’s account, especially when the Court held that banks are mandated to comply with CBN regulation as held by the Supreme Court[34]. Interestingly, the regulations of the CBN are subsidiary legislations which are only applicable secondarily to statutory provisions[35]. In the face of the express provision of the BOFI Act stipulating the procedure of interfering with a bank account, the CBN regulation to the contrary, or as an alternate procedure, is of no effect[36].
Again, in both the Ipinloju and Kuda cases, the Court of Appeal’s posture suggests that banks, as well as law enforcement agencies, had unilateral powers to temporarily interfere with a customer’s account when crime is suspected without a Court order[37]. Unfortunately, this position strays from the constitutional provision. The recent decision of the Supreme Court in Olakehinde v EFCC[38] makes it clear that per Section 44(2)(k) of the Constitution, an existing law may allow law enforcement agencies to take temporary possession of a person’s property for investigation purposes. This does not include either the CBN or the Commercial Banks. The Supreme Court went further in that case, saying that such action which interferes with a citizen’s right by a law enforcement agency can only be taken upon a reasonable suspicion, which the law enforcement agency has the duty to prove[39]!
By this reasoning, only the law enforcement can temporarily interfere with a citizen’s property – including funds in his account, and the standard do not allow for a whimsical action by the law enforcement agency. For the CBN and commercial banks, the provisions of the BOFI Act contains a clear stipulation on how it can interfere with a customer’s account. And where the law has prescribed a special procedure for something to be done, no other procedure is acceptable[40].
Recent developments in case law regime: glimpse of hope against institutional tyranny
This confusion occasioned by both the inelegant law-making publishing and/or process, and the inconsistency in case law regime, has generated some appreciable fears and instability in the banking industry. Heartily, it appears that the judiciary has begun a self-correcting course with its recent decisions. Between 2024 and 2025 alone, the Court of Appeal (that is mostly implicated in the conflicting pronouncements), churned out over 15 decisions on the vexed point[41]. Although it remains unsettled on the issue of whether restriction on an account can be ventilated vide Fundamental Rights Procedure[42], most of the recent decisions of the penultimate Court are now to the effect that a bank cannot unilaterally restrict, freeze or lien a customer’s account without a valid Court order[43].
Importantly, in what appears to be an overrule of the decisions in the Ipinloju and Kuda cases[44], the Court of Appeal in July 2025, in the case of ECOBANK (NIG.) PLC & ANOR v. U-JECKLIN (NIG.) LTD,[45] stated that a bank cannot rely on a CBN regulation nor its own internal policy in freezing or restricting a customer’s account without a Court order. This pronouncement, at any rate, means the Ecobank case is latter in time which is to be applied[46]. Also, in June 2025 – UBA PLC v. WAILI[47], the Court of Appeal placed on banks, the duty of verifying the legality of directives or orders from a law enforcement agency on restriction or freezing a customer’s account. The Court warned that any bank who enforces an illegal order, will not escape liability[48].
Further emphasis was added by the Court of Appeal in December 2025 in the case of NPG EVENT, GARDENS & PARKS LTD v. ZENITH BANK PLC[49] that neither the CBN, nor commercial banks, nor law enforcement agencies possess the vires to legal competence without a valid Court Order; to close a bank account of a customer, seize funds, place lien or transfer such funds[50]. This was the second time the Court of Appeal had to bend over backwards to fish out the omitted Section provision in the BOFI Act 2002, with the first being the Opara Henry case[51]. This decision, along with the U-Jecklin case, signals alignment with the intent of the draftsman.
While the development is commendable, the challenge it highlights is that the Court relied on the omitted provision of the repealed BOFI Act 2002[52], which has however been re-introduced in the section 97 of the BOFI Act 2020. This is regrettable, considering the Evidence Act mandates all courts to take judicial notice of all existing laws[53]. Though the textual provisions are similar, reliance on a repealed law may be problematic for reference[54].
The powers of the EFCC under the Money Laundering Act[55] allowing it to instruct a bank to restrict an account for 72hours has also been redefined. While holding the agency liable for rights violation in EFCC v Waili[56] delivered in June 2025, the Court reasoned that the provisions of the Money Laundering Act ought to be read together with the principal legislation of the EFCC, which will ultimately result in an interpretation suggesting that the EFCC should always seek to obtain a Court order before freezing or restricting an account. Necessary emphasis was placed on the fact that the provision of the Money Laundering Act seeks to suspend suspicious “transactions” after the financial institution has sought clarifications from the account owner, before making a report to EFCC[57].
This brings to light the role of the account owner, the financial institution before that of the EFFC. The sister agency of the EFCC – ICPC, has also been admonished to desist from restricting bank accounts without obtaining court order, due to the manifest abuse of its statutory powers[58]. The Court added that the constitutional derogation of temporary take possession of citizen’s property[59] is only allowed pursuant to a valid court order, thereby corroborating the Supreme Court’s position in OLAKEHINDE v. EFCC[60].
Similarly, the Benin division of the Court of Appeal declared in April 2025 that the Nigerian Police and Banks lacked the powers to unilaterally freeze or restrict an account without a valid Court order[61]. Ultimately, the new wave of legal reasoning, if sustained, aims to protect citizens against rampant, unbridled oppression by both law enforcement agencies and financial institutions. The Court’s incipient posture is not to encourage financial crimes, but to rightfully put the activities of law enforcement agencies and financial institutions under the scrutiny and supervision of the courts.
Conclusion
The recent upsurge in Court cases bordering on bank restriction of customer’s account is not sheer happenstance. Its roots are seated in the quagmire of inelegant law-making process and publishing, as well as inconsistency in case law regimes. Due to a comingling of challenges and possibilities that greets innovations such as electronic banking, the fears expressed by the Court in the Ipinloju and Kuda cases, of billions being illegally dissipated within minutes, may be valid. But outside of statutory procedures, actions taken to interfere with customer’s account will remain unlawful and predispose such banking institution, or law enforcement agency, to judicial sanction.
Just recently, the Nigerian public experienced a frightening, heart wrenching and unnerving revelation of alterations and additions to the Nigerian Tax Laws[62]. In this era where it seems omission, additions and alterations have become a feature in the Nigerian law-making/publishing process, the due diligence requirement on the Courts, lawyers and even litigants, have increased. To ensure reliance is placed on the duly passed, gazetted and codified version of the enacted law, is no longer a matter of trust in the government institutions, but personal assignment. The alternative is to risk suffering gross miscarriage of justice – not because one does not know the law, but as a result of the ceaseless incompetence, or willful misconduct of the injustice agents as visited on Nigerians, in the law making/publishing process. The crab watches after its head with its eyes[63].
[1] Idowu J. Lawrence Esq. is a Commercial Litigation Lawyer practicing primarily in Lagos State. A researcher and member of the Nigeria Bar Association Adjudicature Review Committee. He can be reached via idowulawrenceandco@gmail.com
[2] https://firstutahbank.com/the-history-of-banking-from-ancient-times-to-now accessed 6th January 2025.
[3] https://www.gruppomps.it/en/about-us/history.html accessed 6th January 2025.
[4] https://useflexfinance.com/blog/the-evolution-of-banking-in-nigeria-a-fascinating-journey accessed 6th January 2025.
[5] https://www.firstbanknigeria.com/firstbank-evolution-of-a-banking-giant/ accessed 6th January 2025.
[6] ALLIED BANK OF NIGERIA LTD v. AKUBUEZE (1997) LPELR-429(SC) Per ANTHONY IKECHUKWU IGUH, JSC (Pp 28 – 28 Paras D – F)
[7] supra
[8] Heritage Bank Ltd. v. Meens (Nig.) Ltd. (2025) 9 NWLR (Pt. 1994) Per OGBUINYA, J.S.C. at page 375, paras. A-C
[9] GTB v. DASHUWAR (2020) LPELR-52435(CA)
[10] Section 44 of the 1999 Constitution of the Federal Republic of Nigeria.
[11] GTB PLC v. HENSTEEL ENGINEERING CONSTRUCTION LTD & ANOR (2024) LPELR-61909(CA
[12] S.37(3) of the Cybercrimes (Prohibition Prevention) Act 2015, UBA PLC v. VERTEX AGRO LTD (2019) LPELR 48742(CA),
[13] Section 57 of the Bills of Exchange Act, Unity Bank Plc v. Eforce Interservice Ltd. (2025) 18 NWLR (Pt. 2016)
[14] Sections 32, 33 and 35 of BOFI Act 1991 (as amended)
[15] AKINGBOLA & ANOR v. INTERCONTINENTAL BANK PLC & ORS (2024) LPELR-79939(SC)
[16] https://www.vanguardngr.com/2009/08/cbn-sacks-5-banks-directors/ accessed January 6, 2026
[17] Section 20 BOFIA Act (as amended) LFN 2004
[18] See BOFI (Amendment) Act No. 10 of 2002 (Section 60b)
[19] See the Appendix 1 of the ERRORS AND OMISSIONS CORRECTED IN THE BANKS AND OTHER
FINANCIAL INSTITUTIONS (BOFI) ACT LFN 2004 CAP. B3
[20] See the Preamble and Appendix 2 of the ERRORS AND OMISSIONS CORRECTED IN THE BANKS AND OTHER FINANCIAL INSTITUTIONS (BOFI) ACT LFN 2004 CAP. B3, OPARA-HENRY v. ACCESS BANK PLC (2022) LPELR-59775(CA)
[21] Supra
[22] See Appendix 1 of the ERRORS AND OMISSIONS CORRECTED IN THE BANKS AND OTHER
FINANCIAL INSTITUTIONS (BOFI) ACT LFN 2004 CAP. B3
[23] BSD/DIR/PUB/LAB/014/001 of February 5, 2021
[24] FHC/ABJ/CS/822/2021 CBN Governor V. Rise-vest Technologies Ltd, https://www.thecable.ng/court-unfreezes-rise-vests-accounts-says-cbn-circular-to-banks-not-a-law/ Accessed January 7, 2026
[25] The Court of Appeal in 2025 case of NPG EVENT, GARDENS & PARKS LTD v. ZENITH BANK PLC
(2025) LPELR-82641(CA) and the 2020 case of OPARA-HENRY v. ACCESS BANK PLC
(2022) LPELR-59775(CA)relied on the BOFI Act (2002) contained in the LFN 2004 whereas BOFI Act 2020 was already in force.
[26] https://thenigerialawyer.com/the-muddled-status-of-the-appeal-from-legal-practitioners-disciplinary-committee/
[27] See Section 6(5)(b) of the Money Laundering (Prohibition) Act, 2011 and Section 34(1) of the Economic and Financial Crimes (Establishment) Act 2004
[28] GT Bank v. Adedamola (2019) 5 NWLR Pt. 1664 @ Pg 43 and Olagunju v. EFCC (2019) LPELR 48461 (CA)
[29] OPARA-HENRY v. ACCESS BANK PLC (2022) LPELR-59775(CA) Per GABRIEL OMONIYI KOLAWOLE, JCA (Pp 36 – 37 Paras C – A)
[30] IPINLOJU v. EFCC & ORS (2024) LPELR-61914(CA) Per YARGATA BYENCHIT NIMPAR, JCA (Pp 16 – 24 Paras B – D)
[31] Supra
[32] FHC/ABJ/CS/822/2021 CBN Governor V. Rise-vest Technologies Ltd
[33] KUDA MICROFINANCE BANK LTD v. BLESSING (2024) LPELR-80643(CA)
[34] Access Bank Plc V. Ogboja (2022) 1 NWLR (Pt. 1812) 547 @ 575 – 576
[35] NNPC V. FAMFA OIL LTD (2012) 17 NWLR (PT. 1328) (P. 195, PARAS. C-F
[36]AJAYI V. SEC (2023) LPELR–59729(SC) where His Lordship Ogunwumiju JSC held on page 33 paragraph C: “It is a well settled principle that where a special procedure is prescribed for the enforcement of a particular right or remedy, non-compliance with or departure from such a procedure is fatal to the enforcement of the remedy.”
[37] KUDA MICROFINANCE BANK LTD v. BLESSING (2024) LPELR-80643(CA)Per ABUBAKAR MUAZU LAMIDO, JCA (Pp 22 – 25 Paras A – E)
[38] OLAKEHINDE v. EFCC (2025) LPELR-80483(SC)
[39] OLAKEHINDE v. EFCC (2025) LPELR-80483(SC)Per UWANI MUSA ABBA AJI, JSC (Pp 34 – 35 Paras C – F)
[40] AJAYI v. SEC (2023) LPELR-59729(SC) Per HELEN MORONKEJI OGUNWUMIJU, JSC (Pp 33 – 33 Paras C – E)
[41]KUDA MICROFINANCE BANK LTD v. BLESSING (2024) LPELR-80643(CA), GTB PLC v. HENSTEEL ENGINEERING CONSTRUCTION LTD & ANOR (2024) LPELR-61909(CA), IPINLOJU v. EFCC & ORS (2024) LPELR-61914(CA), GTB v. CHIJIOKE & ANOR (2024) LPELR-81087(CA), FIDELITY BANK PLC v. TERHEMBA & ANOR (2024) LPELR-62518(CA), FCMB v. SABITU (2025) LPELR-81397(CA) FBN PLC & ANOR v. DKN INVESTMENT LTD. & ANOR (2025) LPELR-80878(CA), STANBIC IBTC BANK PLC v. GAMBO (2025) LPELR-80250(CA), STERLING BANK & ANOR v. MICHEAL (2025) LPELR-81404(CA) IFEOLUWANIREPO C.T.C.S LTD. v. UNITY BANK PLC (2025) LPELR-80793(CA), UBA PLC v. WAILI & ANOR (2025) LPELR-81807(CA), EFCC v. WAILI & ANOR (2025) LPELR-81791(CA), ECOBANK (NIG.) PLC & ANOR v. U-JECKLIN (NIG.) LTD (2025) LPELR-81941(CA), NPG EVENT, GARDENS & PARKS LTD v. ZENITH BANK PLC (2025) LPELR-82641(CA), UBA PLC v. ASIME(2025) LPELR-82099(CA)
[42] UBA PLC v. ASIME (2025) LPELR-82099(CA) delivered in August 2025 says FREP Procedure does no accommodate banker customer relationship, while NPG EVENT, GARDENS & PARKS LTD v. ZENITH BANK PLC (2025) LPELR-82641(CA) says restriction on account amounts to breach of fundamental right.
[43] The following cases establish the necessity of a court order before a bank can interfere with a customer’s account – GTB v. CHIJIOKE & ANOR (2024) LPELR-81087(CA), FIDELITY BANK PLC v. TERHEMBA & ANOR (2024) LPELR-62518(CA), FCMB v. SABITU (2025) LPELR-81397(CA) FBN PLC & ANOR v. DKN INVESTMENT LTD. & ANOR (2025) LPELR-80878(CA), STANBIC IBTC BANK PLC v. GAMBO (2025) LPELR-80250(CA), STERLING BANK & ANOR v. MICHEAL (2025) LPELR-81404(CA) IFEOLUWANIREPO C.T.C.S LTD. v. UNITY BANK PLC (2025) LPELR-80793(CA), UBA PLC v. WAILI & ANOR (2025) LPELR-81807(CA), EFCC v. WAILI & ANOR (2025) LPELR-81791(CA), ECOBANK (NIG.) PLC & ANOR v. U-JECKLIN (NIG.) LTD (2025) LPELR-81941(CA), NPG EVENT, GARDENS & PARKS LTD v. ZENITH BANK PLC (2025) LPELR-82641(CA)
[44] In Jonathan v. I.N.E.C. (2025) 3 NWLR (Pt. 1978) the Supreme Court held that the effect is that the subsequent decision is deemed to have over-ruled or departed from the previous or earlier decision or decisions. [Osude v. Azodo (2017) 15 NWLR (Pt. 1588) 295 referred to.] (P. 71, paras. A-B)
[45] ECOBANK (NIG.) PLC & ANOR v. U-JECKLIN (NIG.) LTD (2025) LPELR-81941(CA)
[46] NYSC v. UKACHUKWU (2025) LPELR-81990(SC)
[47] UBA PLC v. WAILI & ANOR (2025) LPELR-81807(CA)
[48] Supra Per EBERECHI SUZZETTE NYESOM-WIKE, JCA (Pp 24 – 30 Paras E – D)
[49] NPG EVENT, GARDENS & PARKS LTD v. ZENITH BANK PLC (2025) LPELR-82641(CA
[50] Supra Per POLYCARP TERNA KWAHAR, JCA (Pp 26 – 27 Paras F – C)
[51] OPARA-HENRY v. ACCESS BANK PLC (2022) LPELR-59775(CA)
[52] The Section 130 of the BOFI Act 2020 repeals the BOFI Act (amended 2002) LFN 2004
[53] Section 74 and 122(2) Evidence Act 2011, INEC & ANOR v. ASUQUO & ORS
(2018) LPELR-43885(SC) Per JOHN INYANG OKORO, JSC (Pp 27 – 29 Paras B – A)
[54] OLAFISOYE v. FRN (2004) LPELR-2553(SC) Per NIKI TOBI, JSC (Pp 25 – 26 Paras F – A)
[55] See Section 6(5)(b) of the Money Laundering Act 2011, now Section 7 of the Money Laundering Act 2022.
[56] EFCC v. WAILI & ANOR (2025) LPELR-81791(CA) Per BALKISU BELLO ALIYU, JCA (Pp 25 – 28 Paras B – C)
[57] Supra Per EBERECHI SUZZETTE NYESOM-WIKE, JCA (Pp 34 – 42 Paras A – B)
[58] Efoba Construction and Engineering Services Ltd v ICPC & Anor Suit No: FHC L/CS/1796/2020
(Unreported), Mr. Williams & Anor v ICPC & 2 Ors https://www.premiumtimesng.com/news/top-news/507348-court-orders-icpc-to-unfreeze-businessmans-accounts-pay-n5-million-compensation.html?tztc=1 Accessed 14th January 2025
[59] Section 44 (2)(k) 1999 Constitution of Nigeria
[60] OLAKEHINDE v. EFCC (2025) LPELR-80483(SC)
[61] FBN PLC & ANOR v. DKN INVESTMENT LTD. & ANOR (2025) LPELR-80878(CA)Per MUHAMMAD IBRAHIM SIRAJO, JCA (Pp 13 – 14 Paras E – E)
[62] https://punchng.com/reps-committee-confirm-alterations-of-nigerias-tax-laws/ accessed 25 January 2026
[63] A Yoruba adage
Get your copy today and take the first step toward financial growth:👉 https://selar.co/4f16676016
_______________________________________________________________________
ARTIFICIAL INTELLIGENCE FOR LAWYERS: A COMPREHENSIVE GUIDE
Reimagine your practice with the power of AI “...this is the only Nigerian book I know of on the topic.” — Ohio Books Ltd
Authored by Ben Ijeoma Adigwe, Esq., ACIArb (UK), LL.M, Dip. in Artificial Intelligence, Director, Delta State Ministry of Justice, Asaba, Nigeria.
Bonus:
Get a FREE eBook titled “How to Use the AI in Legalpedia and Law Pavilion” with every purchase.
How to Order: 📞 Call, Text, or WhatsApp: 08034917063 | 07055285878 📧 Email: benadigwe1@gmail.com 🌐 Website: www.benadigwe.com
Ebook Version: Access directly online at: https://selar.com/prv626
________________________________________________________________________ The Law And Practice Of Redundancy In Nigeria: A Practitioner’s Guide, Authored By A Labour & Employment Law Expert Bimbo Atilola
_______________________________________________________________________
[A MUST HAVE] Evidence Act Demystified With Recent And Contemporary Cases And Materials
