Nigerian Court: Enforces English Judgment, Seizes Rahamaniyya Assets

• Nigerian Federal High Court officials began enforcing an English judgment on September 23, 2026, by seizing assets linked to Abdulrahman Musa Bashar, Chairman of Rahamaniyya Group, in Lagos and Abuja.
• The enforcement aims to recover an approximately $40 million debt owed to Petrichor Energy FZCO, stemming from a February 2025 English High Court judgment against Bashar and Ultimate Oil & Gas FZCO.
• Bashar's counsel challenged the asset seizure, arguing that his client was not properly served with a motion on notice after the judgment's registration in Nigeria and claimed ongoing settlement negotiations, including a recent N1 billion payment.
• The original dispute involved Petrichor's supply of petroleum products to Ultimate Oil & Gas between 2022 and 2023, leading to a $40.2 million liability after Ultimate defaulted on payments.
• A worldwide freezing order was issued in March 2026 by the English court, covering about $40 million in assets across Nigeria, the UAE, the UK, and France, following Ultimate's default on a structured payment agreement.

The incident underscores the intricate procedural requirements for enforcing foreign judgments in Nigeria, particularly concerning the proper service of process following the registration of an overseas court order.

Officials from Nigeria's Federal High Court initiated enforcement proceedings on Wednesday, September 23, 2026, targeting assets associated with Alhaji Abdulrahman Musa Bashar, Chairman of the Rahamaniyya Group of Companies. These actions, conducted across Lagos and Abuja, aim to recover an outstanding debt of approximately $40 million owed to Petrichor Energy FZCO. The enforcement follows a February 25, 2026, order from the Federal High Court in Lagos, which granted Petrichor permission to register a judgment from the High Court of Justice of England and Wales for execution within Nigeria.

Subsequently, on May 15, the Nigerian court issued writs of attachment and sale. These legal instruments authorized the seizure and sale of assets belonging to Bashar, and under a separate writ, those jointly held by Bashar and Ultimate Oil & Gas FZCO. Enforcement officers proceeded to serve and post court documents at various properties connected to the respondents in both cities, marking a significant step in the international debt recovery process.

However, the enforcement encountered immediate resistance at a property located on Logone Close, Maitama, Abuja. Mohammed Sheriff, counsel for Bashar, confronted the court officials, challenging their authority by asserting that they failed to produce what he considered proper Nigerian court documents authorizing the seizure. The situation escalated as associates of Bashar reportedly attempted to remove several vehicles, including Toyota Highlander SUVs, a Mercedes-Benz C-Class, and a Range Rover Sport, from the compound. Police intervention led to the gates being locked, though the vehicles were later observed departing at high speed.

The current enforcement action is the latest development in a protracted dispute that originated from petroleum product transactions between Petrichor Energy FZCO, previously known as CE Energy DMCC, and Ultimate Oil & Gas. These transactions, involving the supply of gasoil and Jet-A1 aviation fuel, occurred between 2022 and 2023. Petrichor alleged that Ultimate Oil & Gas failed to make full and timely payments, resulting in an outstanding balance of approximately $40 million.

The dispute subsequently expanded to include arbitration and court proceedings across multiple jurisdictions, including Dubai, London, and the United Arab Emirates. In February 2025, the English High Court delivered a judgment against Ultimate Oil & Gas and, significantly, against Abdulrahman Musa Bashar personally, based on a guarantee. The combined liability established in these proceedings amounted to approximately $40.2 million.

Following the English judgment, a structured payment agreement was reached in April 2025. However, Ultimate Oil & Gas reportedly defaulted on its installment payments, despite receiving extensions. By January 2026, the company was expected to have paid 45.7 million dirhams but had only remitted 8.7 million dirhams, leaving a substantial shortfall of 37 million dirhams. The English court, after reviewing evidence of property sales and other asset-related transactions, subsequently issued a worldwide freezing order in March 2026 against both Bashar and Ultimate. This order covered an estimated $40 million in assets located across Nigeria, the UAE, the UK, and France, restricting the defendants from disposing of or dealing with these assets.

During the enforcement operation in Abuja, Bashar’s counsel, Mohammed Sheriff, raised critical procedural objections. He contended that after the registration of the English judgment in Nigeria, his client should have been formally served with a motion on notice and afforded a 14-day period to respond or to seek to set aside the judgment. Sheriff emphasized that while a foreign judgment had been registered, the Nigerian court's subsequent processes required proper notification to the parties involved.

Furthermore, Sheriff asserted that the parties were actively engaged in settlement negotiations, claiming that a payment of N1 billion had been made just the previous week. He argued that the enforcement action was unexpected given these ongoing discussions and the alleged recent payment, suggesting a lack of necessary communication regarding the court's intent to proceed with asset seizure. These arguments highlight the stringent requirements for enforcing foreign judgments in Nigeria, particularly concerning due process and notification.

The incident underscores the intricate procedural requirements for enforcing foreign judgments in Nigeria, particularly concerning the proper service of process following the registration of an overseas court order. The challenge raised by Bashar's counsel regarding the absence of a motion on notice and the stipulated response period points to potential pitfalls in international debt recovery efforts if local procedural rules are not meticulously followed. This case involving the Nigerian court enforcing an English judgment against Rahamaniyya and Ultimate Oil & Gas assets serves as a critical reminder for legal practitioners.

Successful enforcement of foreign judgments in Nigeria, and indeed international debt recovery more broadly, hinges not only on obtaining a valid judgment abroad but also on strict adherence to the domestic legal framework for its recognition and execution. The resistance encountered and the specific legal arguments presented by the defense illustrate how procedural missteps, or perceived missteps, can lead to significant delays and challenges, even when a worldwide freezing order and registered judgment are in place. This ongoing situation highlights the complexities inherent in asset recovery actions across borders, especially when substantial sums and multiple jurisdictions are involved.

This case serves as a critical reminder for legal practitioners on the stringent procedural requirements for enforcing foreign judgments in Nigeria, particularly concerning proper service of process post-registration. It underscores the importance of meticulous adherence to local rules to avoid challenges and delays in cross-border debt recovery or asset seizure actions.

Source: Original reporting via Punch Newspapers