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Court voids NBA rules linking practice to CPD compliance

A Federal High Court in Abuja has ruled that the Nigerian Bar Association (NBA) cannot impose additional conditions on lawyers before they can practise law or appear in court.

Delivering judgment in Suit No. FHC/ABJ/CS/1238/2025, Justice Mohammed Umar nullified sections of the Rules of Professional Conduct (RPC) 2023 and the Mandatory Continuing Professional Development (MCPD) Rules 2025 which made compliance with Continuing Professional Development (CPD) programmes compulsory for lawyers seeking to renew practising licences, obtain NBA stamps and seals, or appear in court.The suit was filed by lawyer Victor Nwadike against the NBA, the General Council of the Bar and the Attorney-General of the Federation.

Justice Umar held that the Legal Practitioners Act remains the principal law regulating legal practice in Nigeria and that neither the NBA nor the General Council of the Bar has the legal authority to impose conditions outside the provisions of the Act.The court consequently voided all regulatory provisions tying CPD compliance to the right of legal practitioners to practise law, file court processes or enjoy right of audience before courts.

The judge also restrained the NBA and other defendants from enforcing policies that make CPD participation a condition for legal practice or court appearance.According to the court, administrative policies and professional regulations must remain subordinate to statutory laws governing the legal profession.

The judgment comes amid controversy within the legal profession over the NBA’s enforcement of Rules 11 and 12 of the RPC as well as the mandatory CPD framework introduced in 2025.The NBA had argued that lawyers who failed to comply with CPD requirements risked losing access to practising licences, annual practising certificates and NBA stamps and seals.

The association also maintained that the rules empowered it to publish annual practising lists and issue practising certificates only to lawyers who complied with CPD obligations and payment of practising fees.

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