Abuja, Nigeria — A Federal High Court sitting in Abuja on Tuesday nullified aspects of the Nigerian Bar Association’s Continuing Professional Development (CPD) framework, ruling that professional rules cannot alter statutory conditions governing a lawyer’s right of audience in Nigerian courts.
In a judgment delivered on January 27, 2026, in Suit No. FHC/CS/1238/2025: Victor Ozioma Nwadike v. NBA & 2 Ors, Hon. Justice Mohammed Umar set aside provisions of the Rules of Professional Conduct (RPC), 2023, and the NBA Mandatory Continuing Professional Development (MCPD) Rules, 2025, to the extent that they “add to, alter, or vary” the conditions under which a legal practitioner may appear before Nigerian courts.
The court acknowledged the importance of professional regulation to the integrity and development of the legal profession but emphasized that such regulation must remain consistent with, and subordinate to, statutory authority.
The ruling clarifies that while the NBA may regulate professional standards and development, it cannot impose requirements that effectively modify statutory rights of audience.
Reacting to the decision, Victor Ozioma Nwadike, Esq., the claimant in the suit, called on the NBA and relevant institutions to comply fully with the judgment. “I urge the Nigerian Bar Association, and all relevant institutions to respect, comply with, and give full effect to the judgment of the Court,” he said.
The judgment is expected to have significant implications for the administration of CPD requirements within the legal profession, particularly where such requirements intersect with statutory rights.
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