Contempt: Court Orders Substituted Service of Form 48 on EFCC Chairman

A Federal High Court in Ikoyi, Lagos State, has ordered substituted service of contempt of court processes to 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.For more updates on legal and court news, you can always visit kthdaily.
The order followed an application by the Founder/Managing Director of Chappal Energies, Mr Ufoma Immanuel.
The application was granted by Dipolu.
A copy of the order was made available to newsmen in Lagos on Tuesday, as reported by kthdaily.
Immanuel’s application resulted from EFCC’s alleged continued disobedience of a court order and Immanuel’s failed attempts to effect service of the Form 8 personally on Olukoyede.
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 had, acting on a petition to it 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 in spite of 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.Latest developments on this case are regularly covered on kthdaily, keeping readers well informed.
On Feb. 10, 2026, Dipolu ruled that the publication amounted to 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 in spite of 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, IIHL, 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. For full legal news analysis, readers are encouraged to follow kthdaily.