The Supreme Court of Nigeria has ordered a lawyer to personally pay ₦50 million in punitive costs and warned that he risks losing his right of audience in Nigerian courts, after he asked the apex court to reopen and set aside a judgment it had already delivered in a chieftaincy dispute involving the Gwandu Emirate Council in Kebbi State.
A five-member panel of the court, led by Justice Uwani Abba-Aji, dismissed an application filed on behalf of Alhaji AlMustapha Haruna Jokolo seeking a review of the Supreme Court’s June 4, 2025 judgment in Suit No: SC/266/2017, Governor of Kebbi State & 12 Others v. Alhaji AlMustapha Haruna Jokolo & Anor. In a ruling delivered on May 15, 2026, the court held that the application amounted to an improper attempt to relitigate a matter it had already finally determined.
Counsel for Alhaji Jokolo, S.M. Danyaro, had filed the motion on October 2, 2025, contending that the earlier judgment was “procured by fraud” and rested on a misrepresentation of a provision of the Chiefs (Appointment & Deposition) Law of Kebbi State. He argued that the outcome amounted to “a fundamental denial of his right of access to court and fair hearing.” The respondents, represented by Yakubu Maikyau, SAN, opposed the application.
Delivering the lead ruling, Justice Jamilu Tukur held that Order 20 Rule 4 of the Supreme Court Rules — the provision the applicant relied on — exists only to correct “clerical mistakes, accidental slips, or omissions” in the recording of a judgment, and not to reopen its merits. “It is not, and has never been, a gateway for rearguing issues already determined,” the court held.
The court underscored that its decisions carry finality, stating that “once a judgment has been delivered, it marks the end of the judicial journey. There is no higher forum, no further appeal, and no mechanism for revisiting the merits of the case.” It warned that entertaining such applications would “erode public confidence in the stability of the law.”
The panel, which also comprised Justices Ibrahim Saulawa, Emmanuel Agim and Chioma Nwosu-Iheme, all of whom concurred with the lead ruling, was notably critical of what it described as a growing pattern of disregard for the authority of the apex court by some legal practitioners. The judgment described the application as “an affront of the highest order to the authority, dignity, and institutional integrity of the court,” adding that “what is even more troubling is the growing tendency of legal practitioners to treat the Supreme Court with a level of casual disregard that borders on contempt.”
Beyond dismissing the application, the court imposed a personal cost of ₦50 million against Mr Danyaro, to be paid within 90 days. It warned that failure to pay within that period would result in the forfeiture of his right of audience before any court in Nigeria, effectively barring him from practising as an advocate until the cost is settled.
The court anchored its reasoning in precedent, citing its earlier decision in Igwe v. Kalu (2002) 14 NWLR (Pt. 787) 435, and invoked the late Justice Chukwudifu Oputa’s often-quoted maxim on the finality of the apex court’s decisions: “We are not final because we are infallible, but we are infallible because we are final.”
Background
The underlying dispute traces back to a long-running chieftaincy and emirate governance disagreement involving Alhaji Jokolo and the Kebbi State Government, which had been before the courts for several years before the Supreme Court’s June 2025 judgment. That judgment, delivered in favour of the Kebbi State Governor and other respondents, had been expected to bring finality to the matter, an expectation the October 2025 review application sought to upend.
The ruling reinforces the doctrine of finality of judgments in the Nigerian legal system and signals the apex court’s growing willingness to sanction legal practitioners it considers to have abused court process through applications aimed at relitigating settled matters. The size of the cost award, one of the more substantial punitive awards imposed on an individual legal practitioner by the Supreme Court in recent years, is likely to be closely watched by members of the Bar as a marker of how far the court is prepared to go to protect the integrity of its final decisions.
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