Appeal Court Affirms N85m Fine on Zenith Bank, Police Over Illegal Account Freeze
The Abuja division of the Court of Appeal has upheld an N85 million fine against Zenith Bank and the Nigeria Police Force (NPF) for unlawfully freezing a customer’s account using an invalid Magistrate Court order.
In a unanimous judgment delivered on Monday, a three-member panel led by Justice Adebukola Banjoko dismissed Zenith Bank’s appeal (CA/ABJ/CV/1335/2025) for lacking merit, affirming the July 16, 2025 decision of the High Court of the Federal Capital Territory (FCT).
The appellate court’s ruling solidifies the lower court’s judgment delivered by Justice S. U. Bature in suit FCT/HC/CV/2194/2024.
The lawsuit was filed by Paulyn O. Abhulimen (SAN) through the law firm of Akinlolu Kehinde SAN & Partners LP.
Alongside the financial penalty, the court sustained orders forcing Zenith Bank to unfreeze the Maitama branch account of the claimant’s firm, Abhulimen & Co, and publish a public apology on its website and in two national newspapers.
Key Details of the Legal Dispute
The Dispute Origin: In early 2024, the claimant discovered a Post-No-Debit (PND) restriction on her firm’s account (Account No: 1012272348) at the Transcorp Hilton branch, Abuja, after experiencing transaction failures.
The Invalid Order: Zenith Bank claimed it acted on a March 13, 2024, ex-parte freezing order obtained by the NPF from a Chief Magistrates Court in Mararaba Gurku, Nasarawa State.
Jurisdictional Failure: The FCT High Court and the Court of Appeal both established that magistrate courts entirely lack the jurisdiction to issue banking restrictions or freeze bank accounts.
Justice Bature heavily criticized the NPF and Zenith Bank for utilizing a Nasarawa State Magistrate Court for an Abuja-domiciled account. Citing Section 251 of the 1999 Nigerian Constitution (as amended), the court emphasized that banking matters fall strictly under the exclusive purview of the Federal High Court, while banker-customer disputes fall jointly under Federal, State, and FCT High Courts. Magistrate courts have zero legal authority to entertain such applications.
Final Judgment Breakdown
The Court of Appeal affirmed the lower court’s penalties against both defendants.
N60 million was awarded as general damages for the severe embarrassment, psychological trauma, financial distress, and emotional stress suffered by the claimant. The appellate court also awarded the sum of N25 million to cover the comprehensive cost of the legal action.
Significantly, the court issued a mandatory order of apology to be published across two national daily print newspapers and Zenith Bank’s official website.
In addition, it ordered an immediate reversal of the PND restriction to restore full banking access to Abhulimen & Co.


