C.B.N. V. OCHIFE (2025) 12 NWLR (PT. 2000) 1
ON MEANING OF “PUBLIC SERVICE OF THE FEDERATION” AND WHETHER CENTRAL BANK OF NIGERIA AND OR ITS STAFF ARE MEMBERS THEREOF
By virtue of section 318(1) of the 1999 Constitution, “public service of the Federation” means the service of the Federation in any capacity in respect of the Government of the Federation and includes service as:
(a) clerk or other staff of the National Assembly or of each House of the National Assembly;
(b) member of staff of the Supreme Court, the Court of Appeal, the Federal High Court, the National Industrial Court, the High Court of the Federal Capital Territory, Abuja, Sharia Court of Appeal of the Federal Capital Territory, Abuja, the Customary Court of Appeal of the Federal Capital Territory, Abuja, or other Courts established for the Federation by the Constitution and by an Act of National Assembly;
(c) member of staff of any commission or authority established for the Federation by the Constitution or by an Act of the National Assembly;
(d) staff of any Area Council;
(e) staff of any statutory corporation established by an Act of the National Assembly;
(f) staff of any educational institution established or financed principally by a Government of the Federation;
(g) staff of any company or enterprise in which the Government of the Federation or its agency owns controlling shares or interest; and
(h) members or officers of the armed forces of the Federation of the Nigeria Police Force or other government security agencies established by law.
So, being a member of the public service of the Federation can only mean being a staff in the service of the Federation in any capacity including being a staff of any of the bodies enumerated above. The Central Bank of Nigeria is an agency of the Federal Government established by the Central Bank of Nigeria Act, which is an Act of the National Assembly.
It is the staff of the Central Bank of Nigeria that qualify as members of the public service of the Federation, not the Central Bank of Nigeria itself as an institution or agency. (Pp. 112-113, paras. D-E)
C.B.N. V. OCHIFE (2025) 12 NWLR (PT. 2000) 1
ON OBJECTIVES OF TREASURY SINGLE ACCOUNT GUIDELINES
Paragraph 4.1.2 of the Treasury Single Account Guidelines issued by the Accountant General of the Federation governs mandatory remittances of all public revenue into a common pool account maintained by the Federal Government of Nigeria with the Central Bank of Nigeria and it subjects the transfer of any portion thereof to designated sub-accounts of Ministries, Departments and Agencies (MDAs) as may be appropriated to them by the National Assembly.
(P. 149, paras. D-E)
C.B.N. V. OCHIFE (2025) 12 NWLR (PT. 2000) 1
ON BANK ACCOUNTS THE TREASURY SINGLE ACCOUNT POLICY APPLIES TO
The Treasury Single Account (TSA) policy of the Federal Government of Nigeria was made in respect of Ministries, Departments and Agencies (MDAs) of the Federal Government as found by the Court of Appeal and conceded to by counsel to the parties in this case.
However, the 2nd – 4th respondents (three judgment debtors) are not MDAs of the Federal Government of Nigeria and could not be referred to as MDAs to qualify as persons that the appellant would maintain accounts for in their names under the Treasury Single Accounts policy of the Federal Government of Nigeria.
(P. 91, paras. B-E)
Per OKORO, J.S.C. at page 93, paras. B-E:
“In this case, it is indubitable that the 2nd to 4th respondents who are the judgment debtors are employees of the Nigeria Police Force, which terms and conditions of service on their appointments, promotions, transfer, disciplinary control, dismissal among others are regulated by the Police Service Commission.
In other words, the Nigeria Police Force and the Police Service Commission are agencies of the federal government which accounts may be domiciled with the appellant under the Treasury single account (TSA) policy of the federal government, but definitely not the 2nd-4th respondents which are mere employees.
The appellant was correct to state that it does not maintain any account in the name of the judgment debtors.”