The Community Court of Justice of the Economic Community of West African States (ECOWAS) has dismissed an application by the Federal Republic of Nigeria seeking to revise a 2023 judgment that found the country guilty of violating the rights of a U.S. national, Mr. Gregory Todd.
In the ruling for case ECW/CCJ/APP/56/21/REV, the court concluded that Nigeria’s request lacked legal merit and did not meet the threshold for revision as defined by Article 27 of the ECOWAS Court Protocol and Articles 92 and 93 of the Court’s Rules.
The Nigerian government had sought to reverse the court’s decision from November 6, 2023 (ECW/CCJ/JUD/41/23), which held that the Economic and Financial Crimes Commission (EFCC) violated Todd’s right to freedom of movement by arbitrarily seizing his passport.
As part of that judgment, the court ordered Nigeria to pay $10,000 in damages.
In its revision request, Nigeria argued that the ECOWAS Court lacked the authority to hear a human rights complaint from a foreign national, accused the court of improperly assuming appellate jurisdiction over Nigerian courts, and claimed that the matter had already been resolved by the Federal High Court in Abuja—thereby invoking the legal principle of res judicata.
The ECOWAS Court rejected the application on the grounds that these arguments were purely legal in nature and had been addressed in the original ruling.
The court found no newly discovered or decisive facts that would justify a revision. It ruled the application inadmissible under Article 27 and described the attempt as an abuse of its post-judgment process.
Reaffirming the validity of its initial decision, the court instructed Nigeria to comply fully with the original judgment, including the payment of damages and reimbursement of legal costs incurred by Mr. Todd in defending against the revision attempt.