The Court of Appeal in Abuja has upheld an N85 million award against Zenith Bank Plc and the Nigeria Police Force over the unlawful freezing of a customer’s bank account.
A three-member panel led by Justice Adebukola Banjoko unanimously dismissed an appeal filed by Zenith Bank, 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 the bank and the police, jointly and severally.
The appeal was filed under suit number CA/ABJ/CV/1335/2025.
The case followed a suit instituted by Paulyn Abhulimen on behalf of her law firm, Abhulimen & Co, after Zenith Bank restricted access to the firm’s account in 2024.
Abhulimen 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 a post-no-debit (PND) had been placed on the account on March 13, 2024, based on an ex parte order obtained by the Nigeria Police Force from a Chief Magistrate’s Court in Mararaba Gurku, Nasarawa State.
The suit, marked FCT/HC/CV/2194/2024, listed Zenith Bank and the Nigeria Police Force as defendants.
Court Faults Bank Over Account Freeze
In the judgment affirmed by the Court of Appeal, Justice S.U. Bature held that the magistrate’s court lacked both territorial and substantive jurisdiction to issue an order freezing the account.
The court further held that Zenith Bank’s legal department ought to have recognised the jurisdictional defect and declined to act on the order.
According to the trial court, the bank was wrong to place the PND on the account based on an order issued by a court without the requisite jurisdiction.
The court also found Zenith Bank negligent for failing to notify its customer that the account had been frozen.
It held that the bank owed Abhulimen a duty of care to inform her of the restriction on her account and that its failure to do so amounted to a breach of that duty.
Court Orders Apology, Lifting of Restriction
The FCT High Court also held that an ex parte order freezing a bank account could not remain valid indefinitely.
It consequently ordered Zenith Bank to immediately remove the PND placed on Abhulimen & Co’s account.
The bank was further directed to publish an unreserved apology to the claimant in two national newspapers and on its website.
With the latest ruling, the Court of Appeal upheld the reliefs granted by the FCT High Court, including the N60 million general damages and N25 million costs awarded against Zenith Bank and the police.
Rafiyat Sadiq is a political, justice, and human rights reporter with Pinnacle Daily, known for fearless reporting and impactful storytelling. At Pinnacle Daily, she brings clarity and depth to issues shaping governance, democracy, and the protection of citizens’ rights.

