Know Your Rights
What Happens If You Are Arrested: A Walk-Through of Your Rights
It is 8:45pm. Musa is three streets from home, walking back from the small electrical shop he runs, the one that keeps his two children in school fees. His wife has already called twice. He reaches into his pocket for his phone to call her back.
“Are you Musa?”
Two police officers step out in front of him.
“Yes,” he says. “Why?”
“You need to come with us.”
One officer already has a hand near his arm. The other is speaking into a radio. He has not been shown a warrant. Nobody has told him what this is about. His phone is still in his hand, buzzing again — his wife, wondering why he is late.
What can the police legally do in this moment? What are his rights, right now, on this stretch of road? What must he do, and what can he refuse to do?
This guide follows Musa from this moment on the road to his first appearance before a judge, stage by stage, setting out what the law actually says at each point.
This guide is general legal education, not legal advice for any specific case. It is based on the 1999 Constitution, the Administration of Criminal Justice Act 2015 (or the equivalent state law), the Police Act 2020, and the Evidence Act 2011. If you or someone you know has been arrested, consult a lawyer or the Legal Aid Council of Nigeria as early as possible.
Visual Hierarchy of Certainty
Not every legal statement in this guide has the same level of certainty. Look for the coloured label at the start of each legal point — it tells you where the rule comes from and how strong the authority is.
From the 1999 Constitution. Applies nationwide. Highest level of certainty.
From an Act of the National Assembly or a state law. Wording may vary by state.
From a court decision. Persuasive, but not as settled as the Constitution.
Practical guidance or best practice. Not a legal rule, but useful in real life.
Quick Reference
Read this first for the shape of the whole guide. Every row is explained in full further down.
| If this happens... | You should know... |
|---|---|
| Police stop you | You can ask why, calmly, and you are entitled to a real answer. |
| You are arrested | You must be told the reason at the point of arrest, and again in writing within 24 hours, in a language you understand. |
| You are questioned | Identifying yourself is generally expected during a lawful stop, though the precise scope can depend on the circumstances. Beyond that, you are not required to explain, justify or discuss the allegation before speaking to a lawyer. |
| You cannot afford a lawyer | Free legal aid exists through the Legal Aid Council of Nigeria and recognised legal aid organisations — ask for it to be arranged. |
| You are detained | Detention has a legal time limit. You must be brought before a court within a reasonable time, or released — not held indefinitely. |
If nothing else stays with you from this guide, keep these three:
- Ask why you are being arrested.
- Ask to speak to a lawyer before answering questions.
- Being arrested does not mean you are guilty.
This guide explains the general law as it stands on settled constitutional and statutory provisions. It does not cover every scenario. Particular facts, emergency powers, specialised agencies operating under separate rules (such as customs, drug enforcement, or military law), and subsequent judicial decisions may all affect how the law applies in an individual case. Where this guide flags something as unsettled or state-variable, treat that as a signal to consult a lawyer rather than to rely on the general description alone.
The Arrest
What happens
The officer tells Musa he is being arrested in connection with an allegation. He asks what it is about. The officer must tell him — this is not a courtesy, it is a legal duty.
He has not been shown a warrant. In many cases, the police do not need one.
Usually lasts: a few minutes. (A practice estimate, not a legal rule — varies case to case.)
What the law requires
Musa must be told the reason for his arrest at the point of arrest, not later at the station, and again in writing within 24 hours, in a language he understands.
Rule: You must be told the reason for your arrest at the point of arrest, and again in writing within 24 hours, in a language you understand.
Authority: Constitution, s.35(3)
Rule: The arresting officer must state the reason for arrest at the point of arrest, and must inform the suspect of the right to remain silent and to consult a lawyer.
Authority: ACJA 2015, s.6
An officer does not always need a warrant first. Under the Police Act 2020, an officer may arrest without a court warrant where there are reasonable grounds to suspect a person has committed an offence. This power has a limit: an arrest without reasonable grounds is not lawful, and arresting the wrong person in place of someone else — a relative or a wanted person who cannot be found — is not lawful either.
Rule: An officer may arrest without a warrant only where there are reasonable grounds to suspect the person has committed an offence.
Authority: Police Act 2020, s.38(1)(a)
Rule: Arrest without reasonable grounds is unlawful, and arresting a person in place of someone else (a relative or a wanted person who cannot be found) is unlawful.
Authority: Police Act 2020, s.36
- ✓Ask why you are being arrested.
- ✓Stay calm.
- ✓Note the time.
Musa has now been told why he is being arrested. What happens between the roadside and the station is governed by a separate set of rules — about how he can be treated on the way there.
Knowing your rights does not cancel a lawful arrest, and being arrested does not cancel your rights. The police keep their lawful powers. The suspect keeps his constitutional protections. Both are true at the same time.
The Journey to the Station
What happens
Musa is placed in a police vehicle. An officer sits close to him. Nobody has handcuffed him — the officers judge that he is not a flight risk and is cooperating. He is driven to the station.
Usually lasts: minutes, depending on distance to the station. (A practice estimate, not a legal rule — varies case to case.)
The legal rule
The police may only use as much restraint and force as the situation genuinely needs. They cannot handcuff, restrain or use force beyond what is necessary to stop a suspect escaping. Every suspect must also be treated humanely and with dignity — in the vehicle, at the station, and throughout detention.
Rule: Every suspect is entitled to dignity of the person, underlying the protection against excessive force or degrading treatment in custody.
Authority: Constitution, s.34
Rule: Police may not use restraint or force beyond what is necessary to prevent a suspect escaping.
Authority: Police Act 2020, s.34
Rule: Every suspect must be treated humanely and with dignity, and must never be subjected to torture or to cruel, inhuman or degrading treatment.
Authority: ACJA 2015, s.8; Police Act 2020, s.37
- ✓Note any excessive force used.
- ✓Write it down once safe.
- ✓Raise it with a lawyer later.
By now Musa has arrived at the station. The focus shifts from how he was treated on the way there to how his arrival, and his belongings, are recorded.
At the Police Station
What happens
Before anything else, an officer opens a written record. Musa's name, the reason given for his arrest, and the time he arrived are logged. His phone and wallet are taken and listed.
Usually lasts: variable, often well under an hour for the initial booking-in, though no fixed legal maximum applies to this step. (A practice estimate, not a legal rule — varies case to case.)
What police must do
The officer receiving a suspect into custody must keep a written record — his details, the reason given, and any property taken from him, such as his phone or wallet, entered as a signed inventory. Both the officer and the suspect sign this record; if he refuses to sign, the record itself is not invalidated. Lawyers sometimes call this the custody record.
Rule: The officer receiving a suspect into custody must keep a signed, written custody record — the suspect's details, the reason given, and any property taken from him — and a refusal to sign does not invalidate the record.
Authority: ACJA 2015, s.10
Why the law works this way
This record is what later makes an arrest traceable. If someone is held too long, if a phone goes missing, or if a suspect is moved between stations without anyone telling his family, this written record is the paper trail that lets a lawyer, a court, or the Legal Aid Council reconstruct what actually happened and when.
- ✓Ask to see the custody record.
- ✓Keep any property receipt.
- ✓Confirm your name is logged correctly.
With the record opened, attention turns to what Musa is asked, and whether he has to answer.
Police Questioning
What happens
An officer sits Musa down and starts asking questions about the allegation. He is not sure whether he has to answer, or whether staying quiet will look suspicious.
Usually lasts: minutes to a few hours, depending on the case. (A practice estimate, not a legal rule — varies case to case.)
What the Constitution guarantees
He does not have to answer these questions yet. He can stay silent until he has spoken to a lawyer or another person of his choosing. This is one of the strongest protections in the whole process.
Rule: A suspect has the right to remain silent and the right to a fair hearing, which underlies the protection against self-incrimination before legal consultation.
Authority: Constitution, s.36
Rule: A suspect has the right to remain silent, and not to make, endorse or sign any statement, until after consulting a legal practitioner, from the moment of arrest.
Authority: ACJA 2015, s.6; Police Act 2020
Rule: Identifying yourself is generally expected during a lawful stop, but the precise scope is not a single fixed rule and can depend on the circumstances.
|
Have you spoken to a lawyer?
|
If 'NO' → You may decline to answer, beyond identifying yourself.
|
If 'YES' → Decide, with your lawyer's guidance, whether to answer.
- ✓Ask for a lawyer first.
- ✓Give only your name.
- ✓Say nothing else yet.
Musa has decided he wants a lawyer before he says anything more. What happens when he asks for one is its own stage — and its own test of the system.
“The police can keep you for seven days before taking you to court.”
This is false, and it is one of the most widely repeated myths about arrest in Nigeria. The actual rule is much shorter. A person must be brought before a court within 24 hours if a court is within 40 kilometres of where they were arrested, or within 48 hours otherwise — described in the Constitution as “a reasonable time.” Beyond that, if someone is held awaiting trial and is not entitled to bail, the case must go to trial or the person must be released within two months; if released on bail, within three months. There is no lawful “seven-day” holding period.
Why this myth survives. The seven-day figure appears to persist through word-of-mouth rather than any written rule — older or pre-ACJA practice in some stations, combined with genuinely separate timeframes elsewhere in the system, gets conflated into a single remembered number. With limited public legal education on the actual 24/48-hour rule, the myth fills the gap and gets repeated as fact.
Asking for a Lawyer
What happens
Musa says he wants to speak to a lawyer before he says anything further. He does not have one on hand, and is not sure he can afford one. The officer's response to this request matters.
Usually lasts: can be quick if a lawyer is reachable, or extend for hours if not. (A practice estimate, not a legal rule — varies case to case.)
What the law requires
A suspect has the right to consult a lawyer of his own choosing before he answers questions or signs anything. If he cannot afford one, the law does not leave him without help. The ACJA and the Police Act both provide for free legal representation through the Legal Aid Council of Nigeria, or other recognised legal aid organisations, where available.
Rule: Access to legal representation underlies the right to a fair hearing.
Authority: Constitution, s.36
Rule: A suspect has the right to consult a lawyer before answering questions or signing statements, and to free legal aid where eligible.
Authority: ACJA 2015; Police Act 2020
What a suspect should do
- Ask clearly to call a lawyer, or to have the Legal Aid Council contacted.
- Tell a family member or trusted contact where he is being held, if allowed to make a call.
- Avoid signing any statement or document he does not fully understand.
- Stay calm and polite — cooperation with the process is not the same as giving up his rights.
- Not physically resist officers, even if he believes the arrest is unfair; legal challenges come after, through a lawyer or the courts.
- Ask for the name, rank and station of the officers involved, and note the time.
Signing a statement because an officer says “you can explain later.”
A signed statement is difficult to walk back once it exists on the record, even with a lawyer's help afterwards. Whatever is written and signed becomes part of the case file and can be used against the suspect at trial. Waiting to speak until a lawyer is present protects against a statement being taken down inaccurately, incompletely, or under pressure — “explaining later” does not undo a signature already given.
- ✓Ask to call a lawyer.
- ✓Request the Legal Aid Council.
- ✓Do not sign anything yet.
No lawyer has arrived yet, and night is closing in. The next stage is about what happens while he waits — and what limits the law places on that wait.
Overnight Detention
What happens
No lawyer has arrived yet. The police say their enquiries are not finished. Musa is placed in a cell for the night. He does not know, yet, whether he will be released in the morning or taken to court.
Usually lasts: can extend overnight, subject to the legal time limits below. (A practice estimate, not a legal rule — varies case to case.)
What the Constitution and the ACJA require
Detention has a clock on it. A suspect cannot lawfully be held indefinitely while the police decide what to do.
Rule: A person must be brought before a court “within a reasonable time” — one day (24 hours) where a court of competent jurisdiction exists within 40 kilometres of the place of arrest, and two days (48 hours) in any other case, or such longer period as the circumstances may justify to a court.
Authority: Constitution, s.35(4)–(5)
Rule: Where someone is arrested without a warrant for an offence that does not carry the death penalty, and it is not practicable to bring them before a court within 24 hours, the officer in charge of the station must inquire into the case and release the suspect on bail, pending arraignment (administrative bail).
Authority: ACJA 2015, s.30
|
POLICE STATION
|
Can the suspect be brought before a court within 24 hours
(or 48 hours if no court within 40km)?
|
If 'YES' → Brought before a court → Court decides remand, bail, or release
|
If 'NO' → Officer in charge must inquire into the case (ACJA, s.30)
|
ADMINISTRATIVE BAIL granted at the station, pending arraignment
|
Suspect returns to court on the date given
Why the law works this way
Administrative bail exists because the 24-hour (or 48-hour) constitutional clock would otherwise force the police to either complete every investigation overnight or release everyone who cannot be arraigned that quickly — neither of which serves justice. Instead, the law gives the officer in charge a controlled, accountable way to let a suspect go home while enquiries continue, rather than holding them in a cell purely because the paperwork or the court date is not ready.
For the suspect or a family member, directed to the officer in charge:
- Why am I still being detained?
- Am I being released?
- Am I being taken to court, and when?
- Has administrative bail been considered?
- ✓Ask the officer in charge directly.
- ✓Request a clear timeline.
- ✓Contact a lawyer or family.
If Musa is released on administrative bail, or if the matter instead proceeds to court, a second clock starts running — this one governing how long the case itself can drag on.
Bail or Court
What happens
By the next day, the officer in charge must have decided: administrative bail, or arraignment before a court. If the suspect is not released and the matter proceeds, the case does not sit indefinitely either — the law limits how long it can drag on.
Usually lasts: varies widely, from same-day release on bail to a case proceeding over months. (A practice estimate, not a legal rule — varies case to case.)
What the Constitution guarantees
If a suspect is held awaiting trial and is not entitled to bail, the law requires the case to go to trial, or the suspect to be released, within two months of arrest. If released on bail, the case must go to trial within three months, or he must be released unconditionally or on reasonable conditions.
Rule: No indefinite pre-trial detention — trial or release within two months (if not on bail) or three months (if on bail).
Authority: Constitution, s.35(4)
Why the law works this way
Without this limit, a person could be held for months or years without ever having their case heard, simply because the police or prosecution had not finished preparing. This clock forces the system to either bring the case forward or let the person go — it exists precisely to stop pre-trial detention from becoming a punishment in itself, before any court has found anyone guilty of anything.
- ✓Track the two- or three-month clock.
- ✓Ask a lawyer if it lapses.
- ✓Apply to court if needed.
Whether the case is dismissed, resolved, or proceeds further, at some point the suspect is brought physically before a judge for the first time. That moment has its own name and its own rules.
First Appearance Before a Judge
What happens
Musa is brought before a magistrate and formally charged. This moment is called arraignment. It is the start of the court process — not a verdict, and not a finding of guilt.
Usually lasts: a short hearing, often well under an hour. (A practice estimate, not a legal rule — varies case to case.)
What the Constitution guarantees
He is entitled to a fair hearing, in public, within a reasonable time, before an independent and impartial court. He is presumed innocent until proven guilty. He must be told the charge promptly, in a language he understands, and given adequate time and facilities to prepare a defence, including the right to legal representation of his choice. At this stage, the magistrate or judge may grant bail, remand him, or otherwise direct how the case proceeds, depending on the offence and the evidence so far.
Rule: Every accused person is entitled to a fair hearing, in public, within a reasonable time, before an independent and impartial court, and is presumed innocent until proven guilty, with the charge explained promptly in a language understood and adequate time and facilities to prepare a defence, including legal representation of choice.
Authority: Constitution, s.36
- ✓Confirm the charge is explained clearly.
- ✓Ask your lawyer about bail.
- ✓Remember: not a verdict yet.
If you remember only one sentence from this guide, remember this:
Being arrested does not mean you have been found guilty.
If Your Rights Are Violated
Where an arrest or detention crosses the line into unlawful territory, Nigerian law provides for several possible responses. These are separate remedies, not guaranteed outcomes in every case — what applies depends on the facts.
Release by a court. Where detention is shown to be unlawful — for example, held beyond the constitutional time limits without trial or bail — a court can order the person's release, including through a fundamental rights enforcement application.
Rule: A person unlawfully arrested or detained is entitled to compensation, and a public apology, from the authority or person responsible.
Authority: Constitution, s.35(6)
Rule: A court has discretion to exclude improperly or unlawfully obtained evidence, weighing factors such as how serious the impropriety was, whether it was deliberate, and how important the evidence is to the case — a real but narrow protection, decided case by case, not a guarantee that unlawfully obtained evidence will be thrown out.
Authority: Evidence Act 2011, ss.14–15
Commentators note that a confession obtained through torture is generally treated as inadmissible, while physical evidence found through an unlawful search may still, in some circumstances, be admitted.
Disciplinary or criminal proceedings against officers, where applicable. An officer who acts unlawfully — through excessive force, an arrest without reasonable grounds, or an unlawful arrest in place of another person — can face internal police disciplinary processes or, in serious cases, criminal charges. Whether this happens in practice depends on a complaint being pursued, including through bodies such as the Police Service Commission or the courts.
This section describes remedies that exist in law. It does not promise that any of them will be granted in a specific case — that depends on the facts and on a court's assessment.
Frequently Asked Questions
Can I refuse to enter a police vehicle?
Short answer: No — not safely, if the arrest itself is lawful.
Why: If the arrest is lawful, refusing to get into the vehicle is likely to be treated as resisting arrest, which can lead to further force or an additional charge. The safer course is to comply physically while stating clearly that you object, ask for the reason for arrest if you have not been given one, and raise any challenge afterwards through a lawyer or the courts.
Important limitation: Resisting physically is not the same as challenging an arrest legally, and only the second route protects you. (This is a general principle drawn from arrest procedure under the ACJA and Police Act 2020, not a specific statutory provision on vehicle entry.)
Can police arrest me because my brother or relative is wanted, in his place?
Short answer: No.
Why: This practice, known as “arrest in lieu,” is prohibited. Section 36 of the Police Act 2020 states that a person shall not be arrested in place of a suspect, replacing an older, permissive provision in the repealed Police Act. Nigerian courts have, in decided cases, condemned the practice of arresting a relative in place of a wanted suspect, describing it as having no basis in law.
Important limitation: If this happens, it is an unlawful arrest, and the remedies described in “If Your Rights Are Violated” above apply — but pursuing them requires a complaint or legal action; they are not automatic.
Rule: A recent Federal High Court decision, Uwaifo v. Inspector-General of Police & 3 Ors., recognised a right to record police officers on duty in public and held that arrest or device seizure to stop such recording is unconstitutional.
Authority: Suit No. FHC/WR/CS/87/2025, Federal High Court, Warri, decided March 2026
Can police seize my phone?
Short answer: At arrest, yes, as part of the custody record — but not specifically to stop you recording police activity in public.
Why: Police can lawfully take and record property found on a suspect at the point of arrest, including a phone, as part of the custody record described in Stage 3. A recent Federal High Court decision recognised a separate, narrower protection: that police may not lawfully seize or confiscate a device specifically to stop someone recording police officers on duty in a public place, and awarded damages against officers who did so.
Important limitation: This is a single Federal High Court decision, not a Court of Appeal or Supreme Court ruling — it does not bind other courts the way an appellate decision would, though it is a significant and persuasive precedent. Beyond this narrow point, the precise limits on how long a seized phone can be held, and when it must be returned, remain to verify with a lawyer for any specific case.
Can I record my arrest?
Short answer: Broadly, yes — but this is newer and narrower ground than it may sound.
Why: A recent Federal High Court decision (Warri, Delta State, 2026) recognised that Nigerians have a right, under Section 39 of the Constitution (freedom of expression), to record police officers performing their duties in public, and that police harassment, intimidation, arrest or device seizure over this is unconstitutional. The case itself arose from a checkpoint stop-and-search encounter, not an arrest already in progress.
Important limitation: This is a single Federal High Court decision — it does not bind other courts the way a Court of Appeal or Supreme Court ruling would, and how consistently it is applied by individual officers in practice may vary. The principle is likely to extend to recording an arrest, but this has not yet been separately tested in court. Recording should not be used to obstruct a lawful arrest.
Can police search my house without a warrant?
Short answer: As a general rule, no.
Why: A search of private premises without a warrant is treated as unlawful and a breach of the constitutional right to privacy. The ACJA sets out a detailed warrant process, including who can issue one and how it is executed.
Important limitation: There are narrow, specific exceptions in law — for instance, where a Justice of the Peace directs a search in his own presence, or for certain specialist agencies such as customs or drug enforcement officers acting under their own separate powers. These exceptions are technical and case-specific; whether one applies to a given situation is a question for a lawyer, not a general rule a reader should apply themselves.
Must I answer every question?
Short answer: Identifying yourself is generally expected during a lawful stop or arrest, though the precise scope can depend on the circumstances — beyond that, no.
Why: The right to silence, described in Stage 4, means a suspect is not obliged to answer questions about the allegation, or to make any statement, until they have had the chance to consult a lawyer. This is distinct from basic identification, which is generally expected during a lawful stop, though what exactly must be disclosed, and when, is not a single fixed rule and can depend on the statutory context and the circumstances of the encounter.
Important limitation: Beyond identifying yourself — which is generally expected during a lawful stop, though the precise scope can depend on the circumstances — you are not required to explain, justify, or discuss the allegation before speaking to a lawyer. But declining to answer should be stated calmly and clearly, not through silence alone, which can be misread as evasiveness rather than a legal choice.
A Note on Which Law Applies Where
The Administration of Criminal Justice Act 2015 is federal legislation. It applies directly to federal offences and to courts in the Federal Capital Territory, Abuja. Many states have enacted their own Administration of Criminal Justice Law (ACJL), broadly mirroring the federal Act — including Lagos, Anambra, Ekiti, Ondo, Rivers, Oyo, Enugu, Akwa Ibom, Cross River, Kaduna, Delta, Kogi, Abia, Edo, Ogun, Plateau, Osun, Kwara, Adamawa, Bayelsa, Kano, Nasarawa, Benue, Ebonyi, Bauchi, Sokoto, Katsina and Imo — though the precise list and the current version in force can change as states amend their laws.
A small number of states may still be operating under the older Criminal Procedure Code or Criminal Procedure Act framework where a state ACJ Law has not yet been enacted. Readers should confirm their own state's current ACJL (or its absence) with a lawyer or the state Ministry of Justice, as procedural detail — though not the constitutional rights, which apply nationwide — can vary and change over time.
Two worked examples, side by side. The administrative bail mechanism described in Stage 6 (federal ACJA, s.30) illustrates how this variation looks in practice:
Lagos State, under the Administration of Criminal Justice Law 2015, contains an equivalent provision — the power to release a person arrested for a non-capital offence on bail, pending arraignment — at Section 17. The numbering differs from the federal Act, but the underlying protection is the same in substance.
Kano State, under its Administration of Criminal Justice Law 2019, contains an equivalent administrative bail provision under Section 49, with the same substantive effect as ACJA Section 30.
This is the pattern to expect across most domesticated states: the right exists, the substance is close to identical, but the section number will differ from the federal Act and must be checked against the specific state law in force.
Summary — Stage by Stage
| Stage | Your Main Right |
|---|---|
| Arrest | To be told the reason for your arrest, and only arrested on reasonable grounds — never in place of someone else. |
| Station | A written, signed record of your arrest and any property taken from you. |
| Questioning | To remain silent about the allegation until you have consulted a lawyer, beyond identifying yourself as generally expected during a lawful stop. |
| Detention | Not to be held indefinitely — brought before a court within a reasonable time, or released on bail. |
| Trial | Trial or release within two months (not on bail) or three months (on bail); a fair hearing and presumption of innocence. |
| Unlawful arrest | Compensation, a public apology, possible release by court order, and possible disciplinary or criminal proceedings against the officer. |
This explainer sets out general legal education on settled constitutional and statutory provisions, illustrated through a fictional scenario. It is not legal advice and does not address a specific case. For advice on an individual arrest or detention, consult a legal practitioner or the Legal Aid Council of Nigeria. Procedural detail may also vary by state; the constitutional rights described here apply nationwide. This guide does not cover arrest powers under military law, state-of-emergency provisions, or extradition, which are governed by separate rules.
Knowing your rights is not about avoiding the law. It is about ensuring that the law is applied lawfully.
Legal Sources
This explainer draws on six named instruments, consulted directly or via the verified secondary sources listed in the desk's verification notes. Readers who want to check the underlying law themselves can start here.
- Constitution of the Federal Republic of Nigeria 1999 (as amended) — Chapter IV, ss.34, 35, 36, 39. Nationwide application.
- Administration of Criminal Justice Act 2015 (ACJA) — federal legislation; applies to federal offences and FCT courts. Key sections cited: ss.6, 8, 10, 30.
- Police Act 2020 — federal legislation of general application. Key sections cited: ss.34, 36, 37, 38(1)(a).
- Evidence Act 2011 — federal legislation of general application. Key sections cited: ss.14, 15.
- Lagos State Administration of Criminal Justice Law 2015 — worked example cited: s.17 (administrative bail equivalent).
- Kano State Administration of Criminal Justice Law 2019 — referenced for the state-variance point; s.49.
- Uwaifo v. Inspector-General of Police & 3 Ors., Suit No. FHC/WR/CS/87/2025, Federal High Court, Warri (decided March 2026) — Recent Court Decision tier, right to record police on duty.
