The Court of Appeal has delivered a major setback to a faction of the Peoples Democratic Party (PDP), faulting a Federal High Court judgment that recognised a caretaker committee in the party’s lingering leadership dispute and ruling that the trial court exceeded its powers by granting reliefs that were never sought by any of the parties.
In a judgment delivered in Abuja, Justice Uchechukwu Onyemenam held that the Federal High Court in Ibadan, presided over by Justice Uche Agomoh, went beyond the issues placed before it when it declared the caretaker committee led by Abdurahman Mohammed and Samuel Anyanwu as the legitimate leadership structure of the party.
The appellate court stressed that none of the litigants had requested the court to determine or recognise any factional caretaker committee, making the trial court’s intervention legally unsustainable.
According to the judgment, the lower court improperly ventured outside the reliefs sought by the parties, thereby creating and validating issues that were not before it for adjudication.
“There is clearly a live issue where the trial court went outside the reliefs sought to recognise and uphold a factional caretaker committee,” Justice Onyemenam held.
The case arose from a January 30 judgment in which the Federal High Court recognised the caretaker committee linked to the Abdurahman Mohammed faction of the PDP amid the party’s protracted internal leadership crisis.
However, the Court of Appeal ruled that the foundation upon which that recognition rested had already been destroyed by previous appellate decisions, particularly the Supreme Court judgment that nullified the PDP’s Ibadan Convention held on November 15 and 16, 2025.
The court noted that any structures, committees, or leadership organs purportedly created through the convention automatically lost legal validity once the apex court declared the gathering null and void.
“Once the Convention itself has been pronounced null, void and of no effect by the Supreme Court, any superstructure erected upon it is necessarily without legal foundation,” the appellate court stated.
The three-member panel further held that there was no longer any live dispute requiring judicial determination because the Supreme Court had already settled the fundamental issues underpinning the appeal.
The court observed that ordering a retrial would serve no useful purpose and could potentially place the trial court in the impossible position of revisiting issues already conclusively determined by the nation’s highest court.
In strongly worded remarks, the appellate court warned that directing a lower court to reconsider matters settled by the Supreme Court would amount to inviting it to sit in judgment over the apex court, an outcome the law does not permit.
“This Court would be driven to the conclusion that the offending portions of the judgment, and indeed the judgment as a whole insofar as the excess permeates the decision, are a nullity and liable to be set aside,” the judgment stated.
Although the Court of Appeal stopped short of expressly invoking the doctrine of ultra petita—a legal principle prohibiting courts from granting reliefs beyond those sought by litigants—it effectively held that the Federal High Court had crossed that line.
The judgment, which was unanimously supported by Justices Mohammed Mustapha and Okon Abang, effectively dismantles the legal basis upon which the caretaker committee linked to the Abdurahman Mohammed faction had been recognised.
The ruling is expected to have significant implications for the PDP’s ongoing leadership struggle, further reinforcing earlier appellate and Supreme Court decisions that invalidated the controversial Ibadan convention and the structures that emerged from it.