The Federal High Court sitting in Abuja has nullified provisions of the Rules of Professional Conduct (RPC), 2023, and the Nigerian Bar Association Mandatory Continuing Professional Development (MCPD) Rules, 2025, insofar as they seek to impose additional conditions on a legal practitioner’s right of audience in Nigerian courts.
The judgment was delivered on Monday, 27 January 2026, in Suit No. FHC/CS/1238/2025: Victor Ozioma Nwadike v. Nigerian Bar Association & 2 Others, by Hon. Justice Mohammed Umar.
In its considered decision, the court held that the impugned provisions of the RPC and the NBA MCPD Rules were invalid to the extent that they purported to add to, alter, or vary the statutory conditions regulating a lawyer’s entitlement to appear before courts in Nigeria.
Justice Umar emphasised that while the regulation of the legal profession is vital to maintaining professional standards, competence, and ethical conduct, such regulatory measures must not conflict with existing laws. The court affirmed that professional regulations must remain consistent with, and subordinate to, statutory authority.
The ruling effectively sets aside any requirement under the RPC, 2023, and the NBA MCPD Rules, 2025, that conditions a lawyer’s right of audience on compliance with CPD point accrual beyond what is provided for under enabling statutes.
The judgment has significant implications for legal practice and professional regulation in Nigeria, particularly on the scope of the Nigerian Bar Association’s powers in enforcing continuing professional development requirements among legal practitioners.
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