Appeal Court Affirms N85m Damages Against Zenith Bank, Police Over Unlawful Account Freeze

The Court of Appeal in Abuja has affirmed an N85 million judgment against Zenith Bank Plc and the Nigeria Police Force over the unlawful freezing of a law firm’s bank account.

A three-member panel led by Justice Adebukola Banjoko unanimously 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, which awarded N60 million in general damages and N25 million as costs against Zenith Bank and the police, jointly and severally.

The appeal, marked CA/ABJ/CV/1335/2025, arose from a dispute involving Paulyn Abhulimen and her law firm, Abhulimen & Co.

Abhulimen had approached the FCT High Court after the firm’s account with Zenith Bank was restricted in 2024, preventing her from accessing the funds and conducting transactions.

She later discovered that the bank had placed a Post No Debit restriction on the account based on an ex parte order obtained by the Nigeria Police Force from a Chief Magistrate’s Court in Mararaba Gurku, Nasarawa State.

The FCT High Court subsequently held that the magistrate’s court lacked both territorial and substantive jurisdiction to issue an order freezing the account.

Justice S.U. Bature also faulted Zenith Bank for acting on the order despite the jurisdictional defects.

The court held that the bank’s legal department ought to have recognised that the magistrate’s court lacked the authority to issue such an order.

The trial court further found the bank negligent for failing to notify its customer that the account had been frozen.

It ruled that the failure amounted to a breach of the bank’s duty of care and due diligence towards its customer.

The High Court ordered Zenith Bank to immediately lift the restriction on the account and publish an unreserved apology to Abhulimen & Co. in two national newspapers and on its website.

With the Court of Appeal’s decision, the major reliefs granted by the FCT High Court, including the N60 million general damages and N25 million costs, remain in force.

The ruling underscores the obligation of financial institutions to exercise due diligence when acting on court orders and to ensure that restrictions placed on customers’ accounts have a valid legal basis.

It also reinforces the importance of informing customers when significant restrictions are placed on their accounts, particularly where such restrictions affect their ability to access or transact with their funds.