A High Court of the Federal Capital Territory has ruled that Magistrate Courts in Nigeria do not have the jurisdiction to entertain applications seeking to freeze individuals’ bank accounts.
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Justice S.U. Bature delivered the judgment in a fundamental rights suit filed by a Senior Advocate of Nigeria, Paulyn O. Abhulimen, trading under the name Abhulimen & Co., against Zenith Bank Plc and the Nigeria Police Force. The suit, marked FCT/HC/CV/2194/2024, challenged the freezing of the applicant’s account based on an ex parte order obtained by the police from a Chief Magistrate Court in Mararaba Gurku, Nasarawa State.
In the certified true copy of the judgment dated July 16, 2025, the judge held that Magistrate Courts “lack the jurisdiction to entertain an application for an order to freeze a person’s bank account, and should not have entertained the said application in its entirety.”
Abhulimen had approached the court after her firm’s bank account was blocked and a Post-No-Debit (PND) restriction was placed by Zenith Bank. Her lawyers, Kehinde & Partners LP, argued that the action was taken without due process, and without informing her of the court order that led to the restriction.
The bank admitted placing the restriction but claimed it was acting in compliance with an ex parte order obtained by the police from the Mararaba Magistrate Court. However, the High Court held that such jurisdiction lies only with superior courts, particularly the Federal High Court, when it concerns banking matters.
Justice Bature further ruled that the Nigeria Police Force failed to justify its actions, having not appeared in court throughout the proceedings.
“The 1st defendant (Zenith Bank) was wrong to have placed a PND on the claimant’s account based on the order of a court lacking the requisite jurisdiction to do so. I so hold,” the judge said.
He also held that Zenith Bank owed the claimant a duty of care and was negligent in failing to inform her of the status of her account. The court awarded ₦60 million in general damages and an additional ₦25 million as costs of the action, to be paid jointly and severally by Zenith Bank and the Nigeria Police Force.
Justice Bature emphasized that ex parte orders to freeze bank accounts cannot be indefinite or without prompt judicial oversight, adding that the relevant constitutional provision—Section 251 of the 1999 Constitution—vests exclusive jurisdiction over banking matters in the Federal High Court.
Paulyn v. Zenith BankThe ruling has been widely praised by legal practitioners as a significant clarification on the limits of Magistrate Court powers in financial matters.
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