A Federal High Court sitting in Abuja last 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.

While acknowledging the importance of professional regulation to the integrity and development of the legal profession, the court however emphasized that such regulation must be consistent with, and subordinate to, statutory authority.

According to the ruling, while the NBA may regulate professional standards and development, it cannot impose requirements that effectively modify statutory rights of audience.

Reacting to the decision, the claimant, Mr. Victor Ozioma Nwadike, called on the NBA and relevant institutions to comply with the judgment, saying: “I urge the Nigerian Bar Association, and all relevant institutions to respect, comply with, and give full effect to the judgment of the Court.”

Below is the full text of the judgement.