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Recent Nigerian court rulings have reignited debate over whether Nigerian courts can set aside foreign seated arbitral awards. Traditionally, consistent with the New York Convention and global best practice, only the courts at the seat of arbitration may annul such awards, while the courts of other jurisdiction may only refuse recognition or enforcement.

However, conflicting rulings in Limak, Hempel Paints, and Tempo Energy have created uncertainty. TEMPLARS Partner, Godwin Omoaka, SAN, FCIArb, and Managing Counsel, Orji Uka, assess these conflicting decisions and the need for Supreme Court clarity to align Nigeria’s arbitration framework with global standards.

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