The Court of Appeal in Abuja has upheld an ₦85 million award against Zenith Bank and the Nigeria Police Force (NPF) over the unlawful freezing of a customer’s account based on an invalid court order.
In a unanimous judgment delivered on Monday, September 14, 2026, a three-member panel led by Justice Adebukola Banjoko dismissed Zenith Bank’s appeal, holding that it lacked merit.
The appellate court affirmed the July 16, 2025 judgment of the Federal Capital Territory High Court, delivered by Justice S.U. Bature, which awarded ₦60 million in general damages and ₦25 million in costs against Zenith Bank and the police, jointly and severally.
The appeal, marked CA/ABJ/CV/1335/2025, arose from a suit filed by Paulyn Abhulimen, on behalf of her law firm, Abhulimen & Co, after Zenith Bank restricted access to the firm’s account in 2024.
Abhulimen had told the trial court that she discovered the restriction after she was unable to access the account or conduct transactions.
She said a bank official, Obi Okafor, subsequently informed her that Zenith Bank had placed a “post no debit” (PND) restriction on the account on March 13, 2024, based on an ex parte order obtained by the NPF from a Chief Magistrate’s Court in Mararaba Gurku, Nasarawa State.
The suit, filed as FCT/HC/CV/2194/2024, named Zenith Bank and the NPF as defendants.
In the judgment affirmed by the Court of Appeal, Justice Bature held that the magistrate’s court lacked both territorial and substantive jurisdiction to issue an order freezing the account.
“The rationale behind seeking the said order at a magistrate court under the Nasarawa state jurisdiction cannot be understood,” the judge said.
“The said magistrate court lacked the territorial jurisdiction to entertain the application.
“From the foregoing, it is clear that magistrate courts lack the jurisdiction to entertain an application for an order to freeze a bank account of a person and should not have entertained the said application in its entirety.
“The legal department of the first defendant (Zenith Bank), being lawyers, should have been aware of this position of the law and taken the appropriate action in this situation, as they ought not to have obeyed the court order in the first place.
“Thus, the first defendant was wrong to have placed a PND on the account of the claimant based on the order of a court lacking the requisite jurisdiction to do so. I so hold.”
The trial court further found Zenith Bank negligent for failing to notify its customer that the account had been restricted.
“The first defendant owed the claimant a duty of care of duly informing her that her account had been frozen,” Bature said.
“The failure of the first defendant to inform the claimant of the state of affairs on her account amounts to negligence on the part of the first defendant and hence, a breach of duty of care and due diligence owed to the claimant.”
The court also declared that an ex parte order freezing a bank account could not validly subsist indefinitely and ordered Zenith Bank to immediately lift the PND restriction placed on the Abhulimen & Co account.
Justice Bature further directed the bank to publish an unreserved apology to the claimant in two national newspapers and on its website.
With the Court of Appeal’s decision on Monday, all the reliefs granted by the FCT High Court—including the ₦60 million general damages and ₦25 million costs—remain in force against Zenith Bank and the NPF.
