A Federal High Court in Ikoyi, Lagos State, has ordered substituted service of contempt of court processes on the Chairman of the Economic and Financial Crimes Commission (EFCC), Mr Ola Olukoyede.
Justice Dehinde Dipolu authorised substituted service of Form 48, Notice of Consequences of Disobedience to Order of Court, to the EFCC chairman, through the commission’s Legal Department in Abuja. The order followed an application by the Founder/Managing Director of Chappal Energies, Mr Ufoma Immanuel. Dipolu granted the application.
Immanuel’s application resulted from EFCC’s alleged continued disobedience of a court order and Immanuel’s failed attempts to serve Form 48 on Olukoyede personally. Immanuel’s counsel, Mr C.U. Wogu of Tunji Braithwaite Law Partners, had told the court that attempts to serve the notice on the EFCC chairman were frustrated.
The EFCC, acting on a petition by Immanuel’s business partner, Mr Adebisi Adebutu of R28 Ltd., declared Immanuel wanted in a public notice on its social media platforms on Nov. 19, 2025. The commission declared Immanuel wanted in a case of obtaining money by false pretences and forgery. The case resulted from control of Chappal Energies and shareholder rights.
The commission made the publication despite a subsisting order by Justice Josephine Obanor of the High Court of the Federal Capital Territory, Abuja, on Sept. 11, 2025.
Obanor had restrained the EFCC and other respondents from taking any steps to arrest, detain, or prosecute Immanuel in respect of any issues emanating from the shareholding arrangements, cross-shareholding agreements, subscription rights, and performance of contractual obligations involving him (Immanuel) and Adebutu. The judge also held that the case was civil in nature.
The EFCC, however, began criminal proceedings against Immanuel in another court of coordinate jurisdiction. Immanuel, through his counsel, had challenged the publication by the EFCC at the Federal High Court, Lagos. On Feb. 10, 2026, Dipolu ruled that the publication amounted to an infringement of Immanuel’s constitutional rights to personal liberty and freedom of movement.
The judge also held that the commission lacked the power to restrain Immanuel’s fundamental rights on the matter despite a subsisting court order. The judge ordered the EFCC to withdraw all publications declaring Immanuel wanted and replace them with a public notice retracting the declaration.
Dipolu also directed the EFCC to pay Immanuel five million Naira as compensation for infringing on his rights to personal liberty, freedom of movement and dignity. In the latest order, Dipolu granted Immanuel’s prayer for substituted service, but declined to deem the service automatically sufficient.
The EFCC, on March 11, 2026, arraigned Immanuel alongside his company, Intermediate Investment Holdings Ltd., before Justice Mojisola Dada of the High Court of Lagos State, Ikeja Division, on a two-count charge of forgery and obtaining $1.5 million by false pretences.
However, in October 2026, Obanor issued a restrictive injunction, reaffirming her earlier order and restraining the commission from continuing with the criminal proceedings at the High Court of Lagos State. The judge held that the Sept. 11, 2025 court order remained binding on the EFCC and other respondents since it had neither been set aside nor lawfully discharged.
