The Court of Appeal in Abuja has ruled that Justice Uche Ogomoh of the Federal High Court in Ibadan acted beyond her jurisdiction by granting reliefs not requested by any party in a leadership dispute within the Peoples Democratic Party, PDP. The appellate court’s judgment, delivered by Justice Uchechukwu Onyemenam, declared that the trial judge overstepped by recognizing a factional caretaker committee led by Abdurahman Mohammed and Samuel Anyanwu. This decision came after Justice Ogomoh’s January 30 ruling, which declared the Mohammed-Anyanya committee as the legitimate leadership structure of the party.
The Court of Appeal emphasized that no party in the case had asked for the recognition of this caretaker committee. Justice Onyemenam stated, “In the instant case, there is clearly a live issue where the trial court went outside the reliefs sought to recognise and uphold a factional caretaker committee.” The appellate court noted that such an action undermines judicial procedure and legal principles. It further explained that if the reliefs sought on appeal had not been tied to the legitimacy of the Ibadan convention — which had already been declared null and void by the Supreme Court — the court might have ordered a retrial on the leadership organs created during that convention.
However, the Supreme Court’s earlier judgment in Appeal No. SC/CV/164/2026 had already declared the Ibadan Convention of November 15–16, 2025, as legally invalid. The Court of Appeal held that any structure built upon a nullified convention, including the caretaker committee, lacks legal foundation. “Once the Convention itself has been pronounced null, void and of no effect by the Supreme Court, any superstructure erected upon it is necessarily without legal foundation,” the judgment stated.
The court also pointed out that revisiting the issue would serve no practical legal purpose, as the matter had already been settled at the highest level of the judiciary. While the Court of Appeal did not explicitly use the term “ultra petita” — which refers to a court granting relief beyond what was requested — it concluded that the offending portions of the trial court’s judgment were a nullity and liable to be set aside “ex debito justitiae,” meaning “out of a sense of justice.”
Justice Onyemenam added that directing the trial court to retry the matter would essentially force it to either repeat a decision already made by the Supreme Court or attempt to override it — both of which are legally impermissible. The judgment was unanimously supported by Justices Mohammed Mustapha and Okon Abang, who formed the three-member panel.
This ruling effectively invalidates the legal basis for the Federal High Court’s recognition of the Mohammed-Anyanya caretaker committee. The decision reinforces the principle that judicial rulings must strictly adhere to the reliefs sought and cannot create new legal positions without proper legal grounds. It also underscores the binding nature of decisions made by the Supreme Court, ensuring consistency and authority in Nigeria’s judicial hierarchy. The outcome sets a precedent for future cases involving party leadership disputes and judicial overreach.
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