Nigeria: ruling on lawyer CPD
A Federal High Court in Abuja, Nigeria has ruled that certain provisions in the Rules of Professional Conduct (RPC), 2023 and the Nigerian Bar Association’s Mandatory Continuing Professional Development (MCPD) Rules, 2025 are invalid insofar as they impose extra conditions on a lawyer’s right of audience in Nigerian courts. In a case brought by Victor Ozioma Nwadike against the NBA and others, the court found that requiring additional CPD point accrual beyond what is in existing statute unlawfully altered the statutory criteria governing a legal practitioner’s entitlement to appear before the courts. The judgment emphasizes that while professional regulation is important for standards and ethics, it must not conflict with or extend beyond legislative authority, and as a result the contested CPD-based conditions on courtroom appearance have been set aside. The decision is expected to affect how continuing professional development requirements are enforced within the Nigerian legal profession.