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NJC Sanctions Justices Kabir, Biambo Over Unlawful Detention of Litigants

Abdulah Wahab by Abdulah Wahab
November 5, 2026
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Justice Kekere-Ekun, CJN

 

The National Judicial Council (NJC) has sanctioned three Judges for committing different infractions including Justice Hannatu Mohammed Kabir of the Nasarawa State High Court and Justice

Sobere Biambo of the Rivers State High Court who were suspended for one year without pay for issuing order that contradicted the statutory laws that guide their conducts as judges.

 

Justice Hannatu Mohammed Kabir was suspended for unlawfully detaining a litigant for 58 days over alleged disobedience of court orders without complying with the mandatory legal procedures governing contempt proceedings.

 

In same vein, Justice Sobere Biambo of the Rivers State High Court was accused of issuing bench warrants and imposing fines on litigants in a civil dispute without following the mandatory procedures for contempt proceedings.

 

 

The Council’s decision was based on the outcome of the thorough investigations conducted against the officers of the Bench who were accused of misconduct and breach the ethics of their profession and duties as judges.

 

 

Under the disciplinary measures approved by the Council, Justice Kabir will forfeit her salary for one year and will not be considered for promotion or elevation for the next three years.

 

The sanction followed an investigation into a complaint against the judge, which established that she ordered the arrest and prolonged detention of the litigant without issuing and serving Forms 48 and 49 or instituting proper contempt proceedings as required by law.

 

The NJC, at its 112th meeting held on November 3, 2026, under the chairmanship of the Chief Justice of Nigeria, Justice Kudirat Kekere-Ekun, held that the judge’s actions amounted to a violation of established judicial procedures and the litigant’s constitutional right to fair hearing.

 

 

According to a statement issued by the NJC’s Deputy Director of Information, Kemi Babalola-Ogedengbe, the investigation committee found that the alleged contempt was committed outside the presence of the court and could not, therefore, lawfully be dealt with through summary contempt proceedings.

 

 

The committee consequently faulted the judge for ordering the litigant’s arrest and detention without first complying with the prescribed procedural safeguards for contempt proceedings.

 

 

The Council approved her suspension for one year without pay and directed that she should not be considered for elevation during the three-year period.

 

 

Justice Kabir was among three judicial officers sanctioned by the NJC for misconduct at the meeting, with the Council also approving warning letters and cautions against six other judicial officers over various breaches of judicial ethics, due process and constitutional provisions.

 

 

 

Similarly, Justice Sobere Biambo of the Rivers State High Court was suspended for one year without pay for issuing bench warrants and imposing fines on litigants in a civil dispute without following the mandatory procedures for contempt proceedings.

 

 

 

 

The NJC found that the judge ordered the arrest of petitioners over alleged disobedience of an interim injunction and subsequently imposed a fine of N300,000 on each of them without instituting proper contempt proceedings or serving Forms 48 and 49.

 

 

 

The investigation committee held that the alleged contempt occurred outside the court’s presence and could not lawfully be tried and punished summarily.

 

 

 

Justice Biambo was consequently suspended for one year without pay and barred from consideration for elevation for three years.

 

 

Also suspended for one year without pay was Grand Kadi Mohammed Sani Salihu of the Jigawa State Sharia Court of Appeal for exceeding his judicial authority by reopening a judgment delivered by the FCT Upper Area Court.

 

 

The NJC found that the Grand Kadi constituted a committee to review the judgment and subsequently assigned the matter to a Higher Sharia Court judge, who received fresh evidence and delivered another judgment.

 

 

 

The Council held that the procedure amounted to an appeal against a valid judgment of a court of competent jurisdiction, which was subsequently set aside by the Jigawa State High Court. His conduct was also found to have breached Rule 3.3.1 of the Revised Code of Conduct for Judicial Officers, 2016.

 

 

The Council directed the most senior Kadi of the Jigawa State Sharia Court of Appeal to perform the functions of the Grand Kadi during his suspension.

 

 

 

Beyond the suspensions, the Council approved warning letters or cautions for six other judicial officers following investigations into allegations bordering on disregard for court orders, delayed judgments, abuse of judicial powers and breaches of due process.

 

 

Among them was Justice Bello Kawu of the Federal Capital Territory High Court, who was found to have acted improperly by granting interim bail to former Attorney-General of the Federation, Abubakar Malami, SAN, despite a subsisting remand order issued by another judge of the same court.

 

 

The investigation committee found that Justice Kawu knew that the remand order was due to expire at midnight on December 24, 2025, but nevertheless granted interim bail on December 23, 2025, in conflict with the subsisting order. The Council directed that he be issued a warning letter and placed on its Watch List.

 

 

 

Two Nasarawa State High Court judges, Justices Danjuma A. Oyigbenu and Isa Ebini Kana, were also found culpable of delivering judgment in an appeal outside the constitutionally prescribed 90-day period.

 

 

 

 

The NJC rejected their argument that the constitutional provision did not apply to appellate courts, noting that they admitted delivering judgment outside the stipulated period without offering satisfactory explanations. The Council directed that warning letters be issued to them for breaching Section 294 of the 1999 Constitution, as amended.

 

 

 

Other judicial officers cautioned included Justice Mohammed Zubairu of the FCT High Court, who was faulted for entertaining an application and making orders after being informed that an appeal had already been entered at the Court of Appeal.

 

 

 

Justice C. A. Ogbuagor of the Enugu State High Court was also cautioned for allegedly disregarding due process, denying fair hearing and proceeding with a matter despite a pending appeal and an application for stay of proceedings.

 

 

 

 

Justice Chibuike L. Azuama of the Imo State High Court was similarly cautioned and placed on the Council’s Watch List after granting an ex parte garnishee order freezing the bank accounts of Puma Energy, a company that was not a party to the substantive suit.

 

 

Meanwhile, the NJC recommended 28 candidates for appointment into various judicial positions across five states and the Sharia and Customary Courts of Appeal in Plateau and Adamawa states.

 

 

The recommendations comprise 24 candidates for appointment as judges of the High Courts of Kano, Ebonyi, Edo, Adamawa and Ogun states, one Grand Kadi for the Plateau State Sharia Court of Appeal, one Kadi for the Adamawa State Sharia Court of Appeal and two judges for the Adamawa State Customary Court of Appeal.

 

 

 

The candidates are expected to be sworn in by their respective state governors without delay.

 

 

In another significant decision, the Council directed the Imo State Judicial Service Commission to include the name of the Acting Chief Judge and most senior judge of the state’s High Court, Justice Ijeoma Agugua, in the shortlist of candidates for appointment as substantive Chief Judge.

 

 

The decision followed a petition dated June 11, 2026, by Mr Bob Kay Njemanze, challenging her exclusion from the shortlist submitted by the state Judicial Service Commission.

 

 

The Council noted that although the State Judicial Service Commission has the constitutional responsibility to advise it on suitable candidates for appointment as Chief Judge, the NJC retains the authority to determine the suitability of persons presented for judicial appointments.

 

 

 

It consequently directed its secretariat to formally request the Imo State Judicial Service Commission to include Justice Agugua’s name in the shortlist.

 

 

 

 

The Council also considered reports on 35 petitions submitted by its Preliminary Complaints Assessment Committees. It dismissed 24 for lack of merit, recommended four for further investigation and placed one in abeyance because the matter was sub judice.

 

 

 

Two petitions against Justice B. M. Balarabe of the Kaduna State High Court and Justice Evelyn N. Anyadike were dismissed following their withdrawal by the petitioners.

 

 

 

A petition against Justice Peter O. Ikujuni of the Ondo State High Court was struck out because it had been leaked and published on social media, contrary to the National Judicial Policy, 2016, while another against Justice Abdullahi Mika’ilu of the Niger State High Court was dismissed for want of diligent prosecution.

 

 

However, the NJC resolved that investigation into a petition against Justice G. N. Ugbala of the Ebonyi State High Court should continue despite the petitioner’s notice of withdrawal.

 

 

The Council also approved the retirement notifications of six judicial officers, including two Supreme Court justices, one Court of Appeal justice and three state High Court judges.

 

 

 

They are Justices Ibrahim Mohammed Musa Saulawa and Uwani Musa Abba Aji of the Supreme Court; Justice O. F. Omoleye of the Court of Appeal; Justice Ogechi Okehielem of the Abia State High Court; Justice Theresa Isidore Obot of the Akwa Ibom State High Court; and Justice Munir Muhammad Ladan of the Kaduna State High Court.

 

 

While Justices Saulawa, Omoleye and Okehielem have already retired, Justices Abba Aji, Obot and Ladan are due to retire on November 7, December 30 and December 31, 2026, respectively.

 

 

The NJC commended the retiring judicial officers for their dedicated and meritorious service to the judiciary and the nation.

 

 

 

It also expressed condolences to the families and the Nigerian legal community over the deaths of nine judicial officers between May 1 and September 26, 2026, and prayed for the peaceful repose of their souls.

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