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UNITED BANK FOR AFRICA PLC V. OYEINTEKE GLOBAL NETWORK (NIG) (2024)

case summary

Court of Appeal (Makurdi Division)

Before Their Lordships:

  • Cordelia Ifeoma Jombo-Ofo JCA (Presided)
  • Biobele A. Georgewill JCA (Read the Lead Judgment)
  • Ibrahim Wakili Jauro JCA

Parties:

Appellant:

  • United Bank for Africa Plc

Respondent:

  • Oyeinteke Global Network (Nig.) Ltd
Suit number: CA/MK/201/2022Delivered on: 2024-05-28

Background

This case centers around the appeal of United Bank for Africa Plc (the appellant) against the judgment of the High Court of Nasarawa State, which ordered the bank to pay Oyeinteke Global Network (Nig.) Ltd (the respondent) a sum exceeding N725 million. The respondent claimed this amount based on funds it alleged were unjustly withheld by the bank. The bank's defense rested on the assertion that various legal issues surrounding the respondent's account prevented it from accessing these funds.

Issues

The primary issues that arose included:

  1. Whether the High Court had the proper jurisdiction over the matter given that the actions leading to the suit occurred outside its territorial bounds.
  2. Whether the grounds of appeal submitted by the appellant were vague and thus inadmissible in court.
  3. Whether the bank was justified in denying the respondent access to its funds based on ongoing litigation concerning the respondent.
  4. Lastly, the determination of whether monetary claims like this can be processed under the Undefended List Procedure.

Ratio Decidendi

The court held that jurisdiction is conferred by the claim of the claimant, and in this case, the respondent had established a valid claim against the appellant. The refusal of the bank to process payments had no legitimate backing since the funds were the customer’s property, effectively rendering the bank a debtor. Additionally, the appeal was deemed to lack merit as the grounds cited did not substantively challenge the lower court's findings.

Court Findings

The appellate court found no basis for the appellant's claims of jurisdictional error. It also deemed that the grounds of appeal lacked sufficient clarity and failed to undermine the lower court's judgment. The court emphasized the importance of ensuring access to funds held by banks, framing the situation in which a bank refuses access to a customer's funds as a breach of its contractual obligations.

Conclusion

The court ultimately dismissed the appeal, reinforcing the lower court's decision and asserting that financial claims of this nature fall squarely under the Undefended List Procedure as liquidated money demands.

Significance

This case serves as a critical reminder of the obligations banks have in their relationships with customers and underscores the courts' commitment to preventing unjust enrichment. Furthermore, it illustrates the parameters surrounding jurisdiction in financial disputes, particularly where the cause of action is clear and directly linked to an identifiable banking relationship.

Counsel:

  • Ugonna Afia-Digwe, Esq. - for the Appellant
  • Matthew Burkaa, SAN (with I. B. Ahmad, Esq.) - for the Respondent