On 15 December 2025, the Legal Practitioners Disciplinary Committee (LPDC), delivered its Final Direction in a matter initiated by the Partners of the Law Firm of Aluko & Oyebode against the Firm’s erstwhile employee, Stephen Ikemefuna Nwoye. The LPDC found Mr. Nwoye guilty of infamous conduct and ordered the suspension of his name from the Roll of Legal Practitioners and from engaging in the business of law practice for a period of three years.
This case is largely unprecedented. Most cases against legal practitioners at the LPDC usually involve financial impropriety touching on real estate transactions, or misuse of law firm’s or clients’ funds. You would rarely hear of cases where a law firm accuses an employee of malicious harassment as was seen in this interesting case.
Background
Mr. Nwoye was an ex-employee of Aluko & Oyebode who had commenced his career in the Firm in 2011 as a youth corp member. He worked with the Firm for a few years before he disengaged under unfriendly circumstances. According to the Firm, following Mr. Nwoye’s exit, he wrote a letter dated 12 February 2019 to the Chairman of the Firm’s Management Board, Mr. Gbenga Oyebode, making false allegations against Mr. Oyebode and other lawyers in the Firm. He alleged unlawful termination of his employment and that he was compelled to work under an unhealthy environment. Mr. Nwoye also claimed he was denied financial support towards his postgraduate studies at the New York University School of Law. For these, Mr. Nwoye demanded N2 Billion as compensation.
In addition to the demand, Mr. Nwoye initiated series of court proceedings against the Firm and also submitted petitions to several regulatory and administrative bodies to wit — The American Bar Association, Office of Attorney Discipline of the New York Bar Association, the Securities and Exchange Commission, the Nigerian Stock Exchange, the Economic and Financial Crimes Commission, the Central Bank of Nigeria, and the Nigerian Bar Association.
By now, you may be imagining that Mr. Nwoye’s moves against his former employer were quite unusual. You are right. Disgruntled employees (including ex-employees) especially in law firms are not known to frontally confront issues emanating from their employment in this manner. It requires a higher degree of a feeling of disaffection and bravery to put up a fight. Sometimes, the determination to do so might also be driven by the gravity of hurtful events, and having a soft skin for tolerating workplace mistreatment. Some other times, it might be actuated by malice and mischief.
The Settlement and Subsequent Breach
Notwithstanding the veracity or otherwise of the underlying events that might have led to the hostility between Mr. Nwoye and Aluko & Oyebode, what I found most interesting and commendable is that in the face of the problems, the Firm engaged Mr. Nwoye in an amicable settlement meeting which eventually led to the execution of a Dispute Settlement Agreement (DSA) dated 19 August 2019 and the payment of USD$100,000 (equivalent of N36 Million at the time) to Mr. Nwoye.
The parties agreed that following the settlement, Mr. Nwoye would withdraw all suits and petitions, and consider the matter closed. But this was never to be. The Firm accused Mr. Nwoye of going against the DSA by filing fresh actions and petitions, and making fresh demands. Having been pushed to the wall, the Firm filed an application against Mr. Nwoye at the LPDC.
Summary of LPDC’s Crucial Findings
Upon a thorough review of the application before it, the LPDC found as follows:
1. The LPDC found that indeed Mr. Nwoye resumed hostilities after the settlement. Mr. Nwoye alleged that the Firm failed to pay Capital Gains Tax to the Lagos State Government in respect of the money paid by the Firm to him. He accused the Firm of failure to remit the sum of N96,128.13 to the Lagos State Government being Personal Income Tax deductions from his salary. He demanded the sum of $50,000 as compensation for the alleged breach of the Agreement and as damages for torts of deceit, conversion and breach of fiduciary duty. The LPDC found that Mr. Nwoye did not exhibit any demand letter on him for the payment of the Capital Gains Tax, and that he was also not an agent of the Lagos State Internal Revenue Service.
2. In addition to the above, Mr. Nwoye dragged the Partners of Aluko & Oyebode to the LPDC, filed suits before the National Industrial Court as well as a winding-up suit at the Federal High Court against the Firm claiming $100,000.
3. Mr. Nwoye also filed petitions to several regulatory bodies including a petition to the CBN against one of the Firm’s Partners—Mrs. Kofo Dosekun—challenging her appointment as a non-executive director of First Bank.
4. The LPDC found that Mr. Nwoye did not deny resumption of hostilities and that he failed to frontally defend the allegations of misconduct against him resulting from his breach of the DSA. Rather, he turned himself into a complainant by making allegations of misconduct against the Applicants who were not on trial in the proceedings before the LPDC. The Rules and procedure of the LPDC does not provide for a counterclaim.
Mr. Nwoye’s Preliminary Objection
The LPDC found and held that the preliminary objections presented by Mr. Nwoye lacked merit. First, Mr. Nwoye contended that it was wrong for one of the Applicants/Partners of the Firm—Mr. Hamid Abdulkareem—to present the Originating Application before the LPDC on his behalf and on behalf of the other named Applicants. He argued that each of the Applicants must individually sign the application. The LPDC rightly dismissed the contention holding that all the Applicants need not sign the application individually, and that it was satisfied with the fact that the Applicant who signed (as well as the other Applicant who deposed the verifying affidavit) did so on his behalf and on behalf of the others. The LPDC also held that in any event, one of the Applicants without the other Applicants can sustain the Originating Application.
Mr. Nwoye also challenged the action on the ground that the Applicants lacked locus standi to file the application on the basis that one of the Applicants—Mr. Oluwagbemiga A. Oyebode—practised law under a pseudonym or alias of “GO” or “Gbenga Oyebode” or “Olugbenga Oyebode” as opposed to his full name as entered on the Roll of Legal Practitioners. He accused the Applicants of condoning Mr. Oyebode’s alleged “unlawful act.” The LPDC found this argument by Mr. Nwoye as “bizarre and misplaced.” According to the LPDC, the conduct of the Applicants—though legal practitioners—are not under review. Instead, it was Mr. Nwoye’s conduct that was under review. Second, Mr. Nwoye had not complained of not knowing the identity of Mr. Oyebode, the 4th Applicant on record, and neither was he misled by the use of the alias. Third, even if the name of Mr. Oyebode was struck out, the LPDC will still consider the application because one Applicant could sustain the action. The LPDC was right. The Supreme Court has approved the use of abbreviated names by legal practitioners. In dismissing the preliminary objection, the LPDC noted that an applicant/complainant need not be a lawyer to present an application before the LPDC against a legal practitioner.
LPDC’s Decision
- The LPDC was of the position that Mr. Nwoye failed to place before the LPDC anything to justify his act of resuming hostilities against the Firm and its Partners. At page 20 of the LPDC’s Final Direction, it held:
“We do not consider justifiable, Respondent’s reason for filing multiple Court Suits and Petitions against the Applicants after executing the DSA and taking benefit therefrom. While not curtailing the Respondent’s rights to seek legal redress as he may consider appropriate and necessary, we must place his actions side by side with the undertakings he made under the DSA. A lawyer must keep to his words and must comply [with] the terms of every agreement that he has willingly entered into. See Rules 27(1) and 27(2) (a), (b) and (c) of the RPC.”
- The LPDC held that Mr. Nwoye deliberately set out to harass the Firm and its Partners. According to the LPDC at page 24 of its Final Direction:
“A lawyer as provided in Rule 15(1) and 15(3) (b), (f) and (g) of the RPC ought not to indulge in unlawful acts and must not file suits, assert a position or conduct a defence which he knows or ought to reasonably know that such action would serve to harass or maliciously injure another. All the steps taken by the Respondent, post the DSA, are all actions done in bad faith and intended to maliciously injure and harass the Applicants… The Petition by the Respondent against one of the Applicants—Mrs. Kofo Dosekun—over her nomination to the Board of the Central Bank of Nigeria is another act of malice and harassment by the Respondent on the Applicants. The facts of the Petition as presented by the Respondent were all intended to injure unjustly the reputation of Mrs. Kofo Dosekun and by extension the law Firm of the Applicants.”
- The LPDC held that the failure by Mr. Nwoye to abide by the Dispute Settlement Agreement is a violation of the Rules of Professional Conduct. At page 25 of the LPDC’s Final Direction, it held:
“The Respondent’s acts to his disregard of the DSA are all acts intended to injure, malign and harass the Applicants and therefore in violation of the Rules of Professional Conduct for Legal Practitioners, 2023.”
The LPDC finally found Mr. Nwoye “guilty of infamous conduct in the course of performance of his duty as a legal practitioner contrary to Rule 1, Rules 15(3) (b), (f) and (g) and Rule 27(a), (b) and (c) of the Rules of Professional Conduct for Legal Practitioners, 2023.”
Conclusion
In my opinion, going by the findings of the LPDC, Mr. Nwoye appeared to have demonstrated an unprecedented level of malice any lawyer can display against an ex-employer—Firm—and its owners who also double as learned colleagues. Indeed, as held by the LPDC, there was no compelling reason to justify the unceasing acts of hostilities performed by Mr. Nwoye especially after the settlement and payment of huge sums of money to him. It was appalling to read of Mr. Nwoye’s efforts to stop a partner of the Firm from being appointed as non-executive director of the CBN for no justifiable reason. To my mind, this was the height of a crass display of obsession with malice which must be strictly condemned.
From available reports, Mr. Nwoye has appealed against the decision of the LPDC to the Supreme Court. We await the outcome of the appeal.
