The Supreme Court has affirmed the final forfeiture of ₦1.5 billion recovered from a former consultant to the Nigeria Incentive-Based Risk Sharing System for Agricultural Lending, NIRSAL, Dr. Stephen Olusegun Ogidan, to the Federal Government.
In a unanimous judgment delivered on Friday, June 19, 2026, a five-member panel of the apex court upheld the earlier decisions of the Federal High Court and the Court of Appeal, which had ordered the final forfeiture of the funds.
The panel, led by Justice Mohammed Garba, held that Ogidan’s appeal was without merit.
The lead judgment, prepared by Justice Habib Abiru and read by Justice Abubakar Umar, held that Ogidan had no basis to challenge the forfeiture proceedings after voluntarily returning the funds as part of an arrangement to avoid criminal prosecution.
The court noted that records before it showed that the funds were surrendered to the Economic and Financial Crimes Commission, EFCC, following investigation into allegations that the money was obtained from unlawful sources.
The apex court consequently dismissed the appeal and affirmed the decision of the Court of Appeal, Abuja Division, which had earlier upheld the final forfeiture order made by the Federal High Court, Abuja.
The Supreme Court also awarded ₦5 million cost against Ogidan in favour of the EFCC.
The forfeiture proceedings arose from EFCC investigations into alleged bribery, criminal breach of trust and money laundering in connection with NIRSAL’s Project Monitoring, Reporting and Remediation Offices scheme.
Ogidan, who served as National Coordinating Consultant for the PMRO scheme, was alleged by the anti-graft agency to have received illicit payments from consultants he was appointed to monitor and supervise.
According to the EFCC, the payments were suspected to be proceeds of unlawful activities and were linked to alleged compromises in the supervision of projects under the NIRSAL scheme.
The anti-graft agency had, through its counsel, approached the Federal High Court in Abuja for the forfeiture of the funds.
On February 5, 2024, the Federal High Court, presided over by Justice Inyang Ekwo, granted an interim forfeiture order in respect of the funds.
The court later made a final forfeiture order, holding that no sufficient reason had been shown why the money, which was subject of the interim order, should not be permanently forfeited to the Federal Government.
Dissatisfied with the final forfeiture order, Ogidan and a former Managing Director of NIRSAL, Aliyu Abbati Abdulhameed, appealed to the Court of Appeal, Abuja Division.
They challenged the order and asked the appellate court to determine whether the trial court was right to apply Section 17 of the Advance Fee Fraud and Other Fraud Related Offences Act in ordering the forfeiture of the funds.
In its judgment delivered in 2025, a three-member panel of the Court of Appeal led by Justice Okon Abang dismissed the appeals and affirmed the decision of the Federal High Court.
The appellate court held that the trial court acted within the law in granting the final forfeiture order, particularly as the funds had been voluntarily returned during investigation.
Still dissatisfied, Ogidan approached the Supreme Court, seeking to set aside the concurrent findings of the lower courts.
But the apex court rejected his arguments, holding that there was no merit in the appeal.
Justice Abiru observed that Ogidan could not validly challenge the forfeiture after willingly surrendering the funds in order to avoid prosecution.
The Supreme Court’s decision has now brought the forfeiture proceedings to a close, confirming the permanent transfer of the recovered ₦1.5 billion to the Federal Government.
EFCC’s investigation also indicated that between December 2015 and June 2021, companies linked to Ogidan received payments running into several billions of naira from NIRSAL under consultancy arrangements.
The companies named in the investigation include Successory Nigeria Limited, Beresh Consulting Limited, Blue Accord Nigeria Limited, Global Knowledge Consulting Limited, Freshvine Agribiz Limited, Richtigen Limited, O Stevens Consulting, Proteus and Enterprise Aesthetics.
The EFCC had alleged that the questioned ₦1.5 billion formed part of proceeds suspected to have been unlawfully obtained through the NIRSAL consultancy arrangement.
With the Supreme Court’s judgment, the final forfeiture order earlier granted by the Federal High Court and upheld by the Court of Appeal remains binding.
