Appeal court affirms N85m damages against Zenith Bank, police over unlawful account freeze

The court of appeal in Abuja has upheld a judgement of a Federal Capital Territory (FCT) high court awarding N85 million against Zenith Bank and the Nigeria Police Force (NPF) for unlawfully freezing a customer’s account based on an invalid court order.

In a unanimous judgement delivered on Monday, a three-member panel of the court led by Adebukola Banjoko dismissed Zenith Bank’s appeal, arguing that it lacked merit

The appellate court affirmed the July 16, 2025 judgement delivered by S.U. Bature, judge of the FCT high court, which awarded N60 million in general damages and N25 million as costs against the bank and the NPF, jointly and severally.

The appeal was marked CA/ ABJ/CV/1335/2025.

The suit originated from an action filed by Paulyn Abhulimen, on behalf of her law firm, Abhulimen & Co, after its account with Zenith Bank was frozen in 2024.

Abhulimen told the trial court that restriction was discovered after she was unable to access the account or carry out transactions.

According to her, an official of the bank, Obi Okafor, later informed her that Zenith Bank had placed a ‘post no bebit (PND)’ on the account on March 13, 2024, relying on an ex parte order obtained by the NPF from a chief magistrate court in Mararaba Gurku, Nasarawa state.

The case was filed as FCT/HC/CV/2194/2024, with Zenith Bank and the NPF listed as defendants. Bank Acted on Invalid Order In the judgement affirmed by the appeal court, the judge held that the magistrate court lacked both the territorial and substantive jurisdiction to order the freezing of 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.