NBA Lacks Power To Restrain Lawyers’ Practice And Court Access Through Threats Or Withholding License Over Mandatory CPD Points

By Amb. Hameed Ajibola Jimoh, Esq.

ACArb. (Chartered Arbitrator), MTI Accredited Mediator, CGArb. (Global Peace and Conflict Resolution and Management Expert), FIGPCM, LPC, PC-WCM, FIMC, CMC, CMS and Notary Public for Nigeria

On the 11^th June, 2025, I received an e-mail message on my e-mail from the Nigerian Bar Association-herein after referred to as NBA-, through its Institute of Continuing Legal Education-herein after referred to as-NBA-ICLE- in regard to its Mandatory Continuing Professional Development- herein after referred to as MCPD. The said message was giving me notice that I (as a lawyer) must fulfill the 5 CPD minimum requirements through any of the listed activities as follows:

1. Attending the NBA Annual General Conference;
2. Participating in approved and accredited NBA Branch CPD Programmes;

iii.  Attending NBA-ICLE training organized by Approved Service Providers;

1. Attending CPD Programmes where approved training is delivered;
2. Joining accredited training sessions organized by NBA Sections and Fora;
3. Participating in NBA-ICLE online training sessions;

vii.  Publishing articles in NBA Branch, Institutional, or Faculty Journals (subject to Board approval and CPD credit allocation).

The message further stated thus ‘Please be advised: Without Continuing Professional Development (CPD), you will not receive a license or official stamps. For the 2026 legal year and beyond, compliance with the MCPD Rules is no longer optional. It is a mandatory requirement for all legal practitioners in Nigeria.’. (Underlining is mine for emphasis). It went further to state that ‘Crucially, without a valid practice certificate/license, you will not be able to purchase or use NBA stamps for your legal documents. This enforcement mechanism is directly in line with:

1. Rules 12(3)(a)-(b) of the 2023 Rules of Professional Conduct for Legal Practitioners (RPC): These rules provides that A lawyer, unless he holds an Annual Practicing Certificate issued by the Nigerian Bar Association under this rule, shall not, as a legal practitioner – (a) conduct or take part in any proceedings in the court, judicial tribunal, or panel of enquiry; (b) sign any documents, pleadings, affidavits, depositions, application, instruments, agreements, deeds, letters, memoranda, reports, legal opinions or similar documents and processes; or (c) file any such documents as a legal practitioner legal officer or adviser of any Government Department or Ministry or any company or corporation.
2. Rule 23 of the 2025 NBA MCPD Rules: This rule, and others within the MCPD framework, explicitly outline the requirements for continuous professional development and the consequences of non-compliance, including but not limited to the non-issuance of the annual practice license and, by extension, access to NBA stamps.’

Finally, and most interestingly, the message stated that

‘What This Means for YOU: Your Practice Depends on It!

Your ability to practice law, represent clients, and be recognized as a legal practitioner in good standing is now inextricably linked to your adherence to the MCPD Rules. No CPD means no practice license, and no practice license means no NBA stamps. Without these, your ability to conduct legal business will be severely hampered.’ (Underlining is mine for emphasis).

Hence, this paper is of the most respectful view and or opinion that ‘the mandatory and no practice licence issuance for the reason or on the ground of ‘NO CPD POINT’ acquired by the NBA-ICLE amounts to a denial of ‘Nigerians’ access to court’ and in my humble submission, a denial of access to court by any law or Rules amounts to a denial of ‘justice’ and such is in my humble submission undemocratic, unreasonable and unjustifiable in a democratic civil society, hence, ‘an invitation to ‘jungle justice’ and ‘self-help’’. Therefore, this paper has, with utmost respect, called for a review of this present Rules by the NBA-ICLE and the NBA itself to ensure that these Rules do not contravene the provisions of the Constitution of the Federal Republic of Nigeria, 1999 (as amended)-herein after referred to as the Constitution- and other laws as I shall explain below and this paper has also humbly called on the NBA President to intervene in this conflict before same escalates. Hence, this paper.

First and foremost, respectfully, I wish to deal with the issues of the provisions of Rule 12(3)(a) and (b) of the 2023 Rules of Professional Conducts for Legal Practitioners- herein after referred to as RPC- and the Rule 23 of the MCPD being laid as foundations for ‘No practice Licence issuance for NO CPD Point’ and the decision of the NBA-ICLE and the NBA in this regard, all together.

I wish to respectfully, also observe preliminarily, the said Rule 23 of the MCPD being referred to in the message which provides thus

‘23. Filing of CPD Return

Every lawyer who is subject to these Rules shall file MCPD return not more than 31 days after the end of the reporting period and the Director shall publish a list of lawyers who complied with the Rules and are licensed to practice for another reporting period within 60 days from the date of the reporting periods.

1) The Nigerian Bar Association shall, in every year and not later than a date specified by it –

1. a) Publish a list of legal practitioners to be entitled to practice as a legal practitioner in that year, after complying with the requirements of the Continuing Professional Development Programme and payment of their practicing fees (in these Rules referred to as the Annual Practicing List); and
2. b) Issue a practicing Certificate to a legal practitioner whose name is on the Annual Practicing List, certifying that he has paid his practicing Fee and compiled with the Professional Development Programme for the year under the rules made for that purpose by the Nigerian Bar Association

2) A legal practitioner, unless he holds an Annual Practicing Certificate issued by the NBA under this rule, shall not, as a legal practitioner-

1. a) conduct or take part in any proceedings in the court, judicial tribunal, or panel of inquiry;
2. b) sign any documents, pleadings, affidavits, depositions, applications, instruments, agreements, deeds, letters, memoranda, reports, legal opinions, or similar documents and processes; or
3. c) file any such documents as a legal practitioner, legal officer, or adviser of any Government Department or Ministry or any company or corporation’. (Underlining is mine for emphasis).

In my humble submission, ‘access to court’ is a Constitutional right that every Nigerian possesses and is not lost because any other law or Rules by any body or institution says so outside the provisions and or spirit of the Constitution. To this extent, The Social Objectives of government have been clearly provided for in section 17 contained in the Chapter II of the Constitution and in regard to this paper, section 17(1) and (2) of the Constitution provides thus

‘17.—(1) The State social order is founded on ideals of Freedom, Equality and Justice.

(2) In furtherance of the social order—

(a) every citizen shall have equality of rights, obligations and opportunities before the law;

(b) the sanctity of the human person shall be recognised and human dignity shall be maintained and enhanced;

(c) government actions shall be humane;

(d) exploitation of human or natural resources in any form whatsoever for reasons other than the good of the community shall be prevented; and

(e) the independence, impartiality and integrity of courts of law, and easy accessibility thereto shall be secured and maintained.’ (Underlining is mine for emphasis).

Furthermore, Section 36(1), (4) and (6) of the Constitution further emphasizes ‘access to court’ and by inference, ‘the practice of law by a lawyer duly called to Bar’ without which access to court is unrealistic and unfilled thus

‘36.—(1) In the determination of his civil rights and obligations, including any question or determination by or against any government or authority, a person shall be entitled to a fair hearing within a reasonable time by a court or other tribunal established by law and constituted in such manner as to secure its independence and impartiality.

(4) Whenever any person is charged with a criminal offence, he shall unless the charge is withdrawn, be entitled to a fair hearing in public within a reasonable time by a court or tribunal:

(6) Every person who is charged with a criminal offence shall be entitled to—

(a) to be informed promptly in the language that he understands and in detail of the nature of the offence;

(b) to be given adequate time and facilities for the preparation of his defence;

(c) to defend himself in person or by a legal practitioner of his own choice;

(d) to examine in person or by his legal practitioner the witnesses called by the prosecution before any court or tribunal and obtain the attendance and carry out the examination of witnesses to testify on his behalf before the court or the same conditions as those applying to the witnesses called by the prosecution; and

(e) have, without payment the assistance of an interpreter if he cannot understand the language used at the trial of the offence.’ (Underlining is mine for emphasis).

Furthermore, in my humble submission, ‘the right of a litigant to access court of law’ and ‘the right to be entitled to a lawyer of his choice’ correlate (i.e. go together and are inseparable) and have been further emphasized and guaranteed by the AFRICAN CHARTER ON HUMAN AND PEOPLES RIGHTS when it provides in Articles: 1-7, especially, Article 7, thus

‘Chapter I. Human and Peoples’ Rights

Article 1

The Member States of the Organization of African Unity parties to the present Charter shall recognize the rights, duties and freedoms enshrined in this Charter and shall undertake to adopt legislative or other measures to give effect to them. (Underlining is mine for emphasis).

Article 2

Every individual shall be entitled to the enjoyment of the rights and freedoms recognized and guaranteed in the present Charter without distinction of any kind such as race, ethnic group, colour, sex, language, religion, political or any other opinion, national and social origin, fortune, birth or other status. (Underlining is mine for emphasis).

Article 3

1. Every individual shall be equal before the law.
2. Every individual shall be entitled to equal protection of the law.

Article 4

Human beings are inviolable. Every human being shall be entitled to respect for his life and the integrity of his person. No one may be arbitrarily deprived of this right.

Article 5

Every individual shall have the right to the respect of the dignity inherent in a human being and to the recognition of his legal status. All forms of exploitation and degradation of man particularly slavery, slave trade, torture, cruel, inhuman of degrading punishment and treatment shall be prohibited.

Article 6

Every individual shall have the right to liberty and to the security of his person. No one may be deprived of his freedom except for reasons and conditions previously laid down by law. In particular, no one may be arbitrarily arrested or detained.

Article 7

1. Every individual shall have the right to have his cause heard. This comprises:
2. a) the right to an appeal to competent national organs against acts of violating his fundamental rights as recognized and guaranteed by conventions, laws, regulations and customs in force;
3. b) the right to be presumed innocent until proved guilty by a competent court or tribunal;
4. c) the right to defence, including the right to be defended by counsel of his choice;
5. d) the right to be tried within a reasonable time by an impartial court or tribunal.
6. No one may be condemned for an act or omission which did not constitute a legally punishable offence at the time it was committed. No penalty may be inflicted for an offence for which no provision was made at the time it was committed. Punishment is personal and can be imposed only on the offender.’. (Underlining is mine for emphasis).

In my humble submission, the phrase ‘Counsel of his choice’ which reflects in both section 36(6)(c) of the Constitution and Article 7(1)(c) of the African Charter (supra) reflects the ‘importance of a lawyer in the administration of justice system’ and the Supreme Court of Nigeria has in the case of A-.G. Lagos State v A-.G. Federation (2004) 18 NWLR (pt. 904) 1 SC., Per EDOZIE, J.S.C. at pages 136-137, paras. H-A, emphasised on the settled principle of construction of statute to the effect that the ‘legislature does not use any word in vain’: see U.T.C. (Nig.) Ltd. v. Pamotei (1989) 2 NWLR (Pt.103) 244 at 303; Tukur v. Government of Gongola State (1989) 4 NWLR (Pt. 177) 507 at 579.

Significantly, the Fundamental Rights (Enforcement Procedure) Rules, 2009, -herein after referred to as the FREPR- has clearly stated and or provided the objectives of the FREPR, guaranteed access to Court, legal right to practice as a lawyer, and the legal right of litigants to be represented by lawyers in its Preamble 1, 2 and 3 thus

‘1. The Court shall constantly and conscientiously seek to give effect to the overriding objectives of these Rules at every stage of human rights action, especially whenever it exercises any power given to it by these Rules or any other law and whenever it applies or interprets any rule. 

2. Parties and their legal representatives shall help the Court to further the overriding objectives of these rules.
3. The overriding objectives of these Rules are as follows:

(a) The Constitution, especially Chapter IV, as well as the African Charter, shall be expansively and purposely interpreted and applied, with a view to advancing and realising the rights and freedoms contained in them and affording the protections intended by them.

(b) For the purpose of advancing but never for the purpose of restricting the applicant’s rights and freedoms, the Court shall respect municipal, regional and international bills of rights cited to it or brought to its attention or of which the Court is aware, whether these bills constitute instruments in themselves or form parts of larger documents like constitutions. Such bills include;

(1) The African Charter on Human and Peoples’ Rights and other Instruments (including protocols) in the African regional human rights system,

(ii) The Universal Declaration of Human Rights and other instruments (including protocols) in the United Nations human rights system,

(c) For the purpose of advancing but never for the purpose of restricting the applicant’s rights and freedoms, the Court may make consequential orders as may be just and expedient.

(d) The Court shall proactively pursue enhanced access to justice for all classes of litigants, especially the poor, the illiterate, the uninformed, the vulnerable, the incarcerated, and the unrepresented.

(e) The Court shall encourage and welcome public interest litigation in the human rights field and no human rights case may be dismissed or struck out for want of locus standi. In particular, human rights activists, advocates or groups as well as non-governmental organisations, may institute human rights application on behalf of any potential applicant. In human rights litigation, the applicant may include any of the following;

1. Anyone acting in his own interest;
2. Anyone acting on behalf of another person; iii. Anyone acting as a member of, or in the interest of a group or class of persons;
3. Anyone acting in the public interest; and
4. Association acting in the interest of its members or other individuals or groups’. (Underlining is mine for emphasis).

For emphasis too, I must state that provisions of the FREPR have the force of the Constitution as itself and the FREPR is sui generis and is therefore superior to the Rules of Court and Practice Direction or any other Rules which contravene its provisions including the purported MCPD Rules made by the NBA with the effect of restraining persons and or members duly called to the Nigerian Bar from practicing as lawyers on the ground of nonfulfillment of mandatory CPD and its resulting threat of no legal practice licence issuance for no CPD point acquired!

On the sui generis status of fundamental rights contained in Chapter IV of the Constitution and the procedures or Rules made thereto, see the cases of: Enukeme v Mazi (2015)17 NWLR (1488)411 C.A. at page 434 paras. A-C, Mbaba, J.C.A., Loveday v Comptroller, Fed. Prisons Aba (2013) 18 NWLR (pt. 1386) 379 C.A. and Odogwu v A.G. of the Federation (1999) 6 NWLR (PT. 455) P. 508 Ratio 6.

For emphasis and not for verbosity, furthermore, it is important for me to state here that the Constitution has laid down the Rules for enforcing the rights guaranteed under Chapter IV of the Constitution respectively and or jointly (as the case might be) and the Rules laid down are codified and named Fundamental Rights (Enforcement Procedure) Rules, 2009 (supra), which is made pursuant to the Constitution. In the case of Abia State University, Uturu v Anyaibe (1996) 3 NWLR (pt. 439) 646 at 661, per Katsina-Alu, JCA (as he then was) held that the Fundamental Rights (Enforcement Procedure) Rules made pursuant to the Constitution, have the force of law as the Constitution itself; and overrides the provisions of any other enactment to the contrary. In which case, such a provision has equal force of law as the Constitution itself.

Furthermore, I wish to observe that in fact, Section 3 of the NBA Constitution, 2015 (as amended in 2021) is clear on what the aims and objectives of NBA are, especially in context of this paper, by section 3(9) and (11) where it provides thus

‘3. AIMS AND OBJECTS

The aims and objects of the Association shall be the:

(9) Encouragement and protection of the right of access to courts at reasonably affordable fees and of representation by counsel before courts and tribunals.

(11) Promotion and protection of the principles of the rule of law and respect for fundamental rights, human rights and people’s rights.’ (Underlining is mine for emphasis).

Therefore, it is my understanding and submission that it is not the intendment of the Constitution that the provisions of any statute (or and or including the Rules of Court or Practice Direction) or any other Rules which contravene its provisions including the purported MCPD Rules made by the NBA with the effect of restraining persons and or members duly called to the Nigerian Bar from practicing as lawyers on the ground of nonfulfillment of mandatory CPD and its resulting threat of no legal practice licence issuance for no CPD point, would render its (i.e. the Fundamental Rights (Enforcement Procedure) Rules made pursuant to the Constitution) provisions nugatory and unrealistic. The Supreme Court of Nigeria has held in A.C.B. V Losada (Nig.) Ltd. (1995) 7 NWLR (pt.405) 26 thus:

‘It has never been the case in our laws that the provisions of any ordinary statute would render nugatory the relevant provisions of the constitution. Therefore, if any law of the State including a subsidiary legislation… is inconsistent with the provision of the constitution, the provision of the constitution prevails and that State law is to the extent of inconsistency void’. It was also held in Achu v C.S.C. Cross Rivers State (2009) 3 NWLR (pt. 1129) 475, where the court held thus: ‘The provisions of an ordinary statute would not render nugatory the relevant provisions of the constitution’.

The Constitution thus provides (while guaranteeing the right to access court of law and right of practice of law by a lawyer (by inference) ‘unhindered’) when it provides in section 46(1) thus

‘Any person who alleges that any of the provisions of this Chapter has been, is being or likely to be contravened in any State in relation to him, may apply to a High Court in that State for redress’.

In fact, with due respect to the NBA and or the NBA-ICLE, Section 2 of the Legal Practitioners’ Act, 2004, herein after referred to as-LPA- has provided on who is entitled to practice law when it provides in section 2(1) of the Act thus

‘2. (1) Subject to the provisions of this Act, a person shall be entitled to practise as a barrister and solicitor if, and only if, his name is on the roll.’.

In fact, much more emphatically, the LPA has not granted the NBA any such power to restrict and or restrain and or threaten any lawyer or person duly enrolled as a Barrister and Solicitor of the Supreme Court of Nigeria with ‘no issuance of legal practice licence (when such a person has paid his ‘practicing fee’ as may be specified by the appropriate authority, just because he has failed to meet up with any CPD point! It is therefore my further submission that it is wrong and unlawful for the NBA either directly or through its NBA-ICLE or any of its agents or assignors to condition issuance of annual practicing licence (i.e. to a lawyer duly called to the Nigerian Bar and enrolled at the Supreme Court of Nigeria as such) upon the issuance of approved NBA seal and the fulfillment of the CPD point as the relevant LPA has not granted the NBA such power(s) to do so! For emphasis, sections 7(1) and 8 of the LPA are clear on this my arguments where they provide thus

‘7. (1) Subject to the provisions of this section, a person shall be entitled to have his name enrolled if, and only if-

(a)       he has been called to the Bar by the Benchers; and 

(b)       he produces a certificate of his call to the Bar to the registrar. 

8. (1) Subject to the provisions of the next following subsection and of any enactment in force in any part of Nigeria prohibiting or restricting the right of any person to be represented by a legal practitioner in proceedings before the Supreme Court or the Sharia Court of Appeal or any area or customary court, a legal practitioner shall have the right of audience in all courts of law sitting in Nigeria.  (Underlining is mine for emphasis).

(2)       No legal practitioner (other than such a person as is mentioned in subsection (3) of section 2 of this Act) shall be accorded the right of audience in any court in Nigeria in any year, unless he has paid to the registrar in respect of that year, a practising fee–

(a)       in the case of a Senior Advocate of Nigeria, of N200;

(b)       in the case of a person of 15 or more years standing as a legal practitioner at the beginning of that year, not being a Senior Advocate of Nigeria, of N100;

(c)       in the case of a person of more than 10 but less than 15 years standing as a legal practitioner at the beginning of that year, not being a Senior Advocate of Nigeria, of N75;

(d)       in the case of a person of more than 5 but not more than 10 years standing as a legal practitioner at the beginning of that year, of N40; and

(e)    in any other case, of N20.

(3)       The Attorney-General of the Federation may, after consultation with the Bar Council, from time to time vary the various rates of practising fees specified in subsection (2) of this section.

(4)       The registrar shall-

(a)       issue to every person by whom a practising fee is paid in respect of any year a receipt for the fee in the prescribed form; and

(b)       as soon as reasonably practicable after the end of January in each year and thereafter from time to time during the year as he considers appropriate cause to be printed in the prescribed form and put on sale a list or supplementary list of the legal practitioners by whom practising fees have been paid in respect of that year; and

(c)       pay over to the association as soon as may be after the end of each year a sum equal to nine tenths of the aggregate amount of the practising fees received by him in pursuance of this section during the year, and a receipt purporting to be issued and list purporting to be printed in pursuance of this subsection in respect of any year shall be evidence that the person named in the receipt or, as the case may be, that any person named in the list has paid to the registrar the practising fee in respect of that year.

(5)       Legal practitioners appearing before any court, tribunal or person exercising jurisdiction conferred by law to hear and determine any matter (including an arbitrator) shall take precedence among themselves according to the table of precedence set out in the First Schedule to this Act.’ (Underlining is mine for emphasis).

I therefore humbly submit that the Rules 12(3) (a) and (b) of the RPC and the Rule 23 of the MCPD that the NBA-ICLE relied upon to threaten Nigerian lawyers with ‘no legal practice licence issuance for no CPD point acquired’ and ‘the notice of threat’ by the NBA-ICLE and or the NBA are unconstitutional, unlawful, abuse of powers, illegal and of no effect. Also, see: section 1 of the Constitution. It is much more surprising that a lawyer will be considered by the NBA-ICLE to be disqualified from the practice of law or legal practice just only for ‘no CPD point acquired’ in a year despite and without considering and pitying the number of years that took such lawyer to be called to Bar i.e. Five (5) or more at the University (considering industrial strike actions by the academic staff unions of Universities and the other unions), one (1) year in the Nigerian Law School and with no job opportunities available upon call to Bar and with the accompanying economic melt-down in the law practice in Nigeria! This, in my humble view, is least expected from the NBA, with due respect to the NBA!

I wish to also necessarily, comment that the unconstitutionality of the said Rule 12(3)(a) and (b) of the RPC should not be equated with the Rule 10 of the RPC which aims to safeguard the practice of the law from quacks and unqualified persons who impersonate a lawyer!

Finally, therefore, I humbly submit that the NBA lacks the power under the Constitution, the human rights laws (both local and international), the LPA and the FREPR, to restrain, and or disqualify and or restrict any lawyer duly called to the Nigerian Bar and being on the roll of the Supreme Court of Nigeria as a lawyer from practicing and most importantly, the NBA does not have the legal power(s) to restrain such lawyer from having access to the use of the approved NBA Seal on the ground of ‘no CPD point’ acquired! This NBA Rules on ‘mandatory and no legal practice licence issuance for no CPD point acquired’ also showcases use of ‘excessive powers’ by the NBA than offered and or granted by the law! I therefore humbly call on the NBA President to review this decision by the NBA-ICLE and to withdraw the said threat of no legal practice licence issuance for no CPD point acquired; rather, such Continuous Legal Education should be ‘recommended’ to lawyers rather than being ‘mandated’ with threat of no issuance of legal practice licence’ upon lawyers, whereas, the law practice or legal practice is the only source of sustenance for the Nigerian lawyers! More so, in my humble submission, it is the statutory duty of the Chief Registrar of the Supreme Court of Nigeria (not the duty of NBA) to issue practicing licence to every lawyer who must have paid his annual practicing fee, according to section 8(2), (4)(b) and 24 of the LPA (supra), which provides thus (for emphasis):

‘8 (2) No legal practitioner (other than such a person as is mentioned in subsection (3) of section 2 of this Act) shall be accorded the right of audience in any court in Nigeria in any year, unless he has paid to the registrar in respect of that year, a practising fee–

(4)(b) as soon as reasonably practicable after the end of January in each year and thereafter from time to time during the year as he considers appropriate cause to be printed in the prescribed form and put on sale a list or supplementary list of the legal practitioners by whom practising fees have been paid in respect of that year; and …’. (Underlining is mine for emphasis). See: the interpretation of ‘Registrar’ under section 24 of the LPA to mean ‘the Chief Registrar of the Supreme Court’.

Email: hameed_ajibola@yahoo.com     08168292549.

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