One of the longest-standing principles of the Nigerian legal system is the sanctity of court orders. It is a well-established rule that every person against whom an order of court is made owes a legal and civic duty to comply with the order, and until the order is set aside, it remains binding.[1]

However, an issue may arise where a person complies with a court order that eventually turns out to be fictitious, irregular, or null and void ab initio. The prevailing position, as affirmed by appellate courts, has been that in such circumstances, compliance with the order ought not to be penalised.[2] Put differently, a party who has acted or refrained from doing an act based on an order of court should suffer no punishment if that order is subsequently set aside or declared invalid. However, in the recent decision of the High Court of the Federal Capital Territory (the “Court”) in Suit No. FCT/HC/CV/2194/2024: Paulyn O. Abhulimen SAN v. Zenith Bank Plc & Anor (the “Abhulimen” case), this wasn’t the case. In the suit, the Court held that Zenith Bank Plc acted wrongly and was liable in damages for complying with an order of a Magistrate Court directing it to restrict its customer’s account – a departure from the established position of the law.