Feature/OPED
Looking at the Savannah Bank vs Ajilo Legal Battle
By Benita Ayo
- The Facts of the Case
A deed of Mortgage was executed between Savannah Bank and Ajilo and upon default, Savannah Bank sought to sell the property involved in the mortgage by advertising the auction sale. When Ajilo became aware of the purported sale, he went to the High Court of Lagos to sue for declaration that the Deed of Mortgage was void and also that the Auction Notice was also void.
The major grounds upon which the action was brought were that, by section 22 of the Land Use Act, 1978, the consent of the Governor of Lagos State ought to be first sought and obtained and as no consent was sought and obtained, both the Deed of Mortgage and the Auction Notice were void.
The trial Court held that failure to obtain the required consent of the Governor under S. 22 of the Act has rendered the Deed of Mortgage null and void and the mortgage transaction is illegal.
Upon an appeal at the Court of Appeal by Savannah Bank, the Court held that every right holder whether under S. 34 or S. 36 of the Land Use Act requires the consent of the Governor before he can transfer, mortgage or otherwise dispose of his interest in the Right of Occupancy. The Appeal was thus dismissed.
On further Appeal at the Supreme Court, the above position was affirmed with the Appeal dismissed.
- COMMENTS
2.2 PRINCIPLE
The general principle of law in respect of alienation of interest in property was actually derived from the provisions of Section 22 Land Use Act, 1978 which provides that;
“It shall not be lawful for a holder of statutory Right of Occupancy granted by the Governor to alienate his Right of Occupancy or any part thereof by Assignment, Mortgage, Transfer of possession, sublease or otherwise howsoever without the consent of the Governor first had and obtained”.
The above provision was later on interpreted in the case of Savannah Bank v. Ajilo which became the locus classicus for the legal principle that “Where a holder desires to alienate his interest in a Certificate of Occupancy, he must first obtain the Governor’s consent to make such transfer valid according to S. 22 of the Land Use Act….”
- APPLICATION OF THE PRINCIPLE ON VARIOUS CASES
The principal statute regulating land tenure system in Nigeria being the Land Use Act conferred the ownership of Land in the Federation on the Governor of each State.
The implication of this is that Freehold title to land becomes abolished with the State Government holding all Land in the State in trust for the citizens. Thus, anyone seeking to acquire interest in any landed property or seeking to alienate same by way of Assignment, Lease or Mortgage must do so after seeking and obtaining the consent of the State Governor. See S. 22 Land Use Act.
The principle has been applied by the courts in a plethora of cases some of which will be briefly discussed below.
- IMPLICATION FOR NON-COMPLIANCE
Failure to seek and obtain the requisite consent renders such transaction invalid. This was the butt of the matter in the instant case of Savannah Bank v. Ajilo which facts of the case as well as the final judicial pronouncements were stated above.
As stated earlier on, the Courts have applied the principle in the Ajilo’s case in some cases such as HARUNA v. YARO (2016) LPELR-41554 (CA) where the Court held that;
“On the issue of Governor’s consent, it is correct that the combined effect of Sections 22 and 26 of the Land Use Act is to render null and void any alienation or transfer of a Right of Occupancy or interest or right there under without the consent of the Governor first had and obtained”.
In yet another case of SIMM COMPUTER RESOURCES LTD & ANOR v. FIRST INLAND BANK (2016) LPELR-40493 (CA) the Court decided that,
“The alienation of a right in a Certificate of Occupancy under the Land Use Act is clearly covered by Section 22 of the Act. it provides as follows:
“It shall not be lawful for the holder of a statutory Right of Occupancy granted by the Governor to alienate his Right of Occupancy or any part thereof by assignment, mortgage, transfer of possession, sublease or otherwise without the consent of the Governor first had and obtained.”
Another relevant provision is Section 26 of the Land Use Act which says:
“Any transaction or any instrument which purports to confer on or rest in any person any interest or right over land other than in accordance with the provision of this Act shall be null and void.”
These provisions are clear and straight forward and therefore ought to be given their literal interpretation or meaning. The Section has received judicial attention in a plethora of cases and the locus classicus is the case of SAVANNAH BANK OF NIGERIA LTD v. AMMEL. O. AJILO (1989) 1 NWLR (pt. 97) 254 wherein the Court held that where a holder desires to alienate his interest in a Certificate of Occupancy, he must first obtain the Governor’s consent to make such transfer valid according to Section 22 of the Land Use Act. …………. The Supreme Court in the case of I.T.I. v. ADEREMI (1999) 6 SCNJ 1 held that there are two stages to alienation of interest in Land and they are;
- The holder may enter into a contract of sale of his right, at that stage he does not need the Governor’s consent.
- The second stage is that of alienating the right that is the stage when he assigns his right by a deed of assignment, to now vest the legal estate in the purchaser, and he needs the Governor’s consent to make the transaction valid.”
- EXCEPTIONS OR CURRENT LEGAL POSITION IN VIEW OF SAVANNAH BANK v. AJILO
It is viewed from a different standpoint that the legal stance in Savannah Bank v. Ajilo rather promotes sharp practices such as a party benefitting from his own wrong.
This was exactly the situation in Savannah Bank v. Ajilo where the Defendant in this case sought to prevent the Plaintiff from selling off the mortgaged property in an auction sale by invoking the provisions of Section 22 Land Use Act, 1978.
While still conceding the fact that where a person in alienating his interest in property must seek the consent of the State Governor in order for such alienation to be valid, the failure to obtain the said consent before executing the Deed of Conveyance does not in itself invalidate the transaction. It only makes the transaction inchoate or incomplete.
See for instance the case of HARUNA v. BANK OF AGRICULTURE LTD & ORS (2016) LPELR-40467 (CA) where the Court concluded that,
“The Courts have held that there is nothing in the Land Use Act preventing the execution of an instrument before the consent of the Governor is obtained. It simply means that the agreement entered into is inchoate (Incomplete) until the Governor’s consent is sought and obtained.”
Also in YARO v. AREWA CONSTRUCTION LTD & ORS (2007) LPELR-3516 (SC), it was held that;
“The 3rd Respondent has raised the question of Section 22 of Land Use Act, concisely, the section requires that Governor’s consent to the mortgage deal has to be first had and obtained otherwise the contract is void. I think with respect that the 3rd Respondent’s objection is lame in that as decided in Awojugbagbe v. Chinukwe & Anor (Supra), it is after the mortgage has been executed that obtaining of the Governor’s consent falls due. It is normally after the parties have agreed that the Deed of Assignment is prepared and sent for Governor’s consent. The instant mortgage therefore has not fallen foul of Section 22 of the Land Use Decree.”
In practice, whenever interest in property is transferred from the owner to a buyer, the relevant Deed of Conveyance is prepared and executed between the parties prior to obtaining the consent of the State Governor. The courts have held that this procedure does not invalidate the transaction but rather, no interest has yet passed to the buyer.
See the case of AWOJUGBAGBE LIGHT INDUSTRIES LTD v. CHINUKWE & ANOR (1995) LPLER-650 (SC) for instance where the Supreme Court held that;
“A close study of Section 22(2) of the Land Use Act clearly confirms that it does recognise cases where some form of written agreement or instrument executed in evidence of the relevant transaction is submitted to the Governor in order that the necessary consent under Section 22(1) may be signified by endorsement thereon. This being so, I do not conceive that it can be argued with any degree of seriousness that there is anything unlawful in the entering into or execution of Exhibit E before the Governor’s consent was obtained as this procedure is expressly covered by Section 22 (2) of the Land Use Act. The legal consequence that arises in such a situation is that no interest in land passes under the agreement until the necessary consent is obtained. Such an agreement so executed becomes inchoate until the consent of the governor is obtained after which it can be said to be complete and fully effective. I am therefore of the firm view that Section 22 (1) of the Land Use Act prohibits the alienation of a Right of Occupancy without the consent of the governor first had and obtained but does not prohibit agreement to alienate or in respect of terms and conditions for the purpose of effecting such alienation if and when the Governor gives his consent to the transaction in issue.”
CONCLUSION
Finally, it has been discussed that a party seeking to alienate his interest in property whether in part or in whole as is the cases with Assignment, Leases or Mortgage, must first seek and obtain the consent of the State Governor. This does not however mean that he cannot execute a document evidencing the transaction as could be gleaned from the aforementioned authorities. See HARUNA v. BANK OF AGRICULTURE LTD & ORS (SUPRA).
However, what this implies is that notwithstanding the execution of a document of conveyance, the transfer is incomplete until the requisite consent is sought and had and this is usually in practice done by endorsement in the column for it within the document of conveyance.
Finally, the implication of a party’s failure to seek and obtain the Governor’s consent in property transactions according to the aforementioned case of HARUNA (SUPRA) is that the transaction is incomplete rather than null and void as was the case in Savannah Bank v. Ajilo. It is only where the transaction has been perfected (Consent sought and obtained) will the transaction be complete.
Benita Ayo is a legal practitioner based in Lagos and be contacted on WhatsApp: 08063775768 or email: be*********@***oo.com.
Feature/OPED
4 Ways AI is Changing How Nigerians Discover Businesses
By Olumide Balogun
Nigerians are natural explorers. Whether finding the best supplier in Balogun market, hunting down a recipe for party jollof, or looking for the most affordable flight out of Lagos, we are always searching.
Today, human curiosity is expanding, and the way Nigerians express it is evolving. We are speaking to our phones, snapping photos of things we like, and asking incredibly complex questions. For the Nigerian business owner, understanding this shift is a massive opportunity to get discovered by eager customers.
Here are four ways AI is rewriting how Nigerians search, along with simple steps to ensure your business is exactly what they find.
1. Visual Discovery is the New Normal
People are increasingly using their cameras to discover the world around them. Picture someone spotting a brilliant pair of sneakers in traffic and wanting to know exactly where to buy them. Today, shoppers simply take out their phones and search visually.
Tools like Google Lens now process over 25 billion visual searches every single month, and many of these searches are from people looking to make a purchase.
How to adapt: Your product’s visual appeal is paramount. Make sure you upload clear, high-quality images of your products to your website and social media. When a customer snaps a picture of a bag that looks like the one you sell, having great photos ensures your business pops up in their visual search results.
2. Conversations Replace Simple Keywords
Shoppers are asking highly nuanced, conversational questions. They are typing queries like, “Where can I find affordable leather shoes in Ikeja that are open on Sundays and do home delivery?”
To handle these detailed questions, new features like AI Overviews act like a superfast librarian that has read everything on the web. It provides users with a perfectly organised summary and links to dig deeper.
How to adapt: Answer your customers’ questions before they even ask. Create detailed, helpful content on your website and fully update your Google Business Profile. List your opening hours, delivery areas, and unique services clearly. This ensures the technology easily finds your details and recommends your business when a customer asks a highly specific question.
3. Intent Matters More Than Exact Words
Predicting every single word a customer might use to find your product is a huge task for any business owner. Thankfully, modern search technology focuses on the underlying need behind a search.
If someone searches for “how to bring small dogs on flights,” AI understands that the person likely needs to buy an airline-approved pet carrier. The technology looks at the true intent of the shopper.
How to adapt: You no longer need to obsess over guessing exact keywords. By using AI-powered campaigns, you allow the technology to understand your products and match them to the customer’s true needs. Your business will show up for highly relevant searches, bringing you customers who are actively looking for solutions you provide.
4. Smart Assistants Handle the Heavy Lifting
Running a business in Nigeria requires incredible hustle. Managing digital marketing on top of daily operations takes significant time and energy. The next frontier in digital advertising introduces agentic capabilities, which hold a simple promise of delivering better results for your business with much less effort.
The technology now acts as your personalised assistant.
How to adapt: You can simplify your marketing by using the Power Pack of AI-driven campaigns, including Performance Max. You simply provide your business goals, your budget, and your creative assets like photos and videos. The AI automatically finds new, high-value customers across Google Search, YouTube, and the web. It adapts your ads in real time to match exactly what the shopper is looking for, allowing you to focus on running your business.
The language of curiosity is constantly expanding. Nigerians are discovering brands in entirely new ways using cameras, voice notes, and highly specific questions. By understanding these behaviours and embracing helpful AI tools, you can let the technology connect eager customers directly to your digital doorstep.
Olumide Balogun is a Director at Google West Africa
Feature/OPED
One SA Bank Equals Nigeria’s Entire Banking Sector – Why Recapitalisation Is Critical for Global Competitiveness
By Blaise Udunze
Nigeria has always prided itself as Africa’s largest economy and most populous nation. Currently, its banking sector is confronting a moment of truth that should send shockwaves. Today, a single South African bank, Standard Bank Group, commands a market value at roughly $21-22 billion that rivals and, in some comparisons, exceeds the entire Nigerian banking industry. Though it may seem to be unbelievable, it is real. This striking imbalance is not merely about market valuations for individuals who are perturbed by this alarming revelation. Hence, it must be known that this reflects deeper structural challenges in Nigeria’s financial system and underscores why the Central Bank of Nigeria’s recapitalisation drive has become essential for restoring competitiveness, resilience, and global relevance.
Without any iota of doubt, for a nation of over 200 million people and Africa’s largest economy by several metrics, this reality is more than an uncomfortable statistic. This is truly a reflection of deeper structural weaknesses within the financial system. It highlights the urgent need for reform and explains why the ongoing recapitalisation drive by the Central Bank of Nigeria has become one of the most consequential policy interventions in the country’s banking industry in two decades.
Recapitalisation is not merely a regulatory exercise. If, genuinely, the key stakeholders consider this exercise as an attempt to reposition Nigerian banks to compete with global peers, strengthen financial stability, restore investor confidence, and enable the banking sector to support economic transformation, they must not handle this report with bias.
The disparity between Nigerian and South African banks illustrates the scale of the challenge.
While Standard Bank Group, the largest by assets, has a market capitalisation of roughly R372 billion ($21-22 billion = N32.66 trillion). Similar whooping amounts valued in the multi-billion-dollar range as of 2025 apply to several other South African banks, including FirstRand, Absa Group, and Nedbank. For apt juxtaposition from what is obtainable with the South African bank, the combined market capitalisation of 13 Nigerian banks listed on the Nigerian Exchange (NGX) stood at about N16.14 trillion ($10.87 billion) as of 2025-2026. However, the earlier benchmarks show that around May 2025, it was about N11.07 trillion. The current valuation of N16.14 trillion is a result of the funds tapped by some banks from the capital market through rights issues and public offerings.
Nigeria’s largest banks tell a different story. Guaranty Trust Holding Company, widely regarded as one of Nigeria’s most efficient banks, is valued at less than $2 billion (N3.3 trillion). Access Holdings, despite managing assets exceeding $70 billion, carries a market capitalisation of under $1 billion.
To further buttress Africa’s largest financial institution’s position, as of June 30, 2025, Standard Bank Group of South Africa reported total assets of R3.4 trillion. This amount is equivalent to $191.8 billion, and it points to the fact that it is at the top in Africa’s financial space. The equivalent in naira at Nigeria’s exchange rate of N1,484.50 to $1. Hence, $191.8 billion translates to approximately N284,983 trillion, or roughly N285 trillion. This means a single South African bank now outvalues the entire Nigerian banking industry, when compared to the 10 largest lenders collectively holding N218.99 trillion in assets. Though Nigerian banking industry assets were projected to reach N242.3 trillion ($151.4 billion) by 2025-2026.
The obvious and alarming disconnect between asset size and market value signals a deeper crisis of confidence as enumerated thus far. One underlying mistake is to understand that investors are not merely assessing balance sheets; they are evaluating governance standards, currency stability, regulatory predictability, and long-term growth prospects, as these remain their focal interests. The market’s verdict is clear: Nigerian banks remain undervalued because investors perceive higher systemic risks.
It would be recalled that Nigeria has travelled this road before, in 2004-2006, which didn’t end as planned. The then-governor of the Central Bank, Charles Soludo, launched a bold consolidation reform that reshaped the banking industry. Also, it would be recalled that Nigeria, in numbers, had 89 banks, which were more than what is in operation today, and many of them were small, fragile, and undercapitalised.
Similar steps are being witnessed today, as Soludo then raised the minimum capital base from N2 billion to N25 billion, triggering a wave of mergers and acquisitions that reduced the number of banks to 25. The industry witnessed the emergence of champions as the reform produced stronger institutions, such as Zenith Bank, United Bank for Africa, Guaranty Trust Bank, and Access Bank.
For a period, the experience was that Nigerian banks expanded aggressively across Africa and emerged as formidable competitors on the continent, but unfortunately, the momentum gradually faded because of certain missing pieces, and this must be addressed if the industry is ready for economic relevance.
The global financial crisis of 2008 exposed weaknesses in risk management and regulatory oversight. With the industry reacting, several banks were heavily exposed to the stock market and the oil sector. This led to another wave of reforms under former CBN governor Sanusi Lamido Sanusi in 2009.
Although one would say that those interventions stabilised the system. But more harm than good, they also ushered in a more conservative banking culture, as witnessed in the system, where many institutions prioritised survival over innovation.
Two decades after the Soludo reforms, Nigeria’s financial landscape has changed dramatically.
The size of the economy has expanded, inflation has eroded the real value of bank capital, and global regulatory standards have become more demanding. Banks that once appeared adequately capitalised now find themselves operating with limited buffers against economic shocks.
Recognising these vulnerabilities, the CBN introduced a new recapitalisation framework requiring banks to raise their capital bases to the following thresholds: N500 billion for international banks, N200 billion for national banks, and N50 billion for regional banks.
As has always been the case, these requirements are designed to ensure that Nigerian banks possess the financial strength required to compete with institutions in advanced economies.
The Nigerian banking sector should take a new leaf as the recapitalisation exercise comes to an end, with the understanding that capital adequacy is not merely a regulatory metric; it determines how much risk banks can absorb, how much they can lend, and how resilient they remain during economic crises, which must be accompanied by innovation.
In developed financial systems, banks operate with deep capital buffers, which is common with South African banks that allow them to finance infrastructure, industrial projects, and large corporate investments. Without similar capital strength, Nigerian banks cannot effectively support large-scale economic development.
One of the most persistent obstacles facing Nigeria’s banking sector is currency volatility. The Nigerian naira has experienced repeated devaluations in recent years, eroding investor returns and weakening confidence in local financial assets.
When the currency depreciates sharply, equity valuations expressed in dollars decline even if banks report strong profits in local currency. This dynamic partly explains why Nigerian banks appear profitable domestically yet remain undervalued in international markets.
In contrast, South Africa’s financial system benefits from a more stable currency environment and deeper capital markets.
The strength of the Johannesburg Stock Exchange allows South African banks to attract large pools of institutional capital from pension funds, asset managers, and international investors. Nigeria’s financial markets, though improving, remain comparatively shallow.
Another irony in Nigeria’s banking sector is the difference between reported profits and genuine productivity within the economy, and the contradiction is glaring. Though it is known that many Nigerian banks recorded extraordinary profit growth in recent years, partly driven by foreign-exchange revaluation gains following the depreciation of the naira but the contradiction is that such gains do not necessarily reflect improvements in efficiency, innovation, or lending performance.
One measure the apex bank adopted was recognising the risks and restricting banks from paying dividends derived from these gains, insisting they be retained as capital buffers.
This intervention revealed how much of the apparent profitability was linked to currency fluctuations rather than sustainable business growth.
True banking strength lies not in accounting windfalls but in the ability to finance real economic activity, and this should be one of the ongoing recapitalisation targets.
The core function of banks in any economy is to channel savings into productive investment. Yet Nigerian banks have increasingly shifted toward safer and more profitable activities, such as investing in government securities, which has continued to weigh negatively on the growth of the real economy.
Other mitigating headwinds, such as high interest rates, regulatory uncertainty, and credit risks, discourage lending to manufacturing firms and small businesses. The result is a financial system that often prioritises short-term returns over long-term economic development.
By contrast, South African banks play a more significant role in financing infrastructure projects, corporate expansion, and consumer credit.
Recapitalisation aims to address this imbalance by strengthening banks’ capacity to support the real economy. The fact is that stronger balance sheets will allow Nigerian banks to finance large projects in sectors such as energy, transportation, agriculture, and manufacturing; alas, the narrative is totally different, going by what is obtainable in the Nigerian finance sector when compared to others.
Investor perception is shaped not only by financial performance but also by governance standards. International investors place significant emphasis on transparency, regulatory stability, and corporate accountability.
While Nigerian banks have made relative progress in improving governance frameworks, concerns remain about insider lending, regulatory inconsistencies and complex ownership structures, as these issues have continued to weigh on the industry, while some of these obvious factors may have contributed to the challenges observed in the operations of institutions such as First Bank Plc and another example is the liquidation of Heritage Bank.
Recapitalisation provides an opportunity to strengthen governance by attracting new institutional investors and enforcing stricter disclosure requirements, and not mainly dwelling on the pursuit of bigger capital because capital alone does not guarantee resilience, as it would be recalled that Nigeria has travelled this road before.
Larger, better-capitalised banks tend to operate with more robust governance systems because they face greater scrutiny from regulators and shareholders.
The global banking industry has become increasingly competitive, which should be a wake-up call for the Nigerian banking industry.
Technological innovation, cross-border expansion, and regulatory harmonisation have transformed how financial institutions operate, and this means that African banks, especially in Nigeria, known as the economic giant of Africa, must therefore compete not only with regional peers but also with global players.
Recapitalisation is essential if Nigerian banks are to participate meaningfully in this evolving landscape. On this aspect, it must be emphasised that stronger capital bases will enable banks to invest in digital infrastructure, expand internationally, and develop sophisticated financial products.
Besides, they will also enhance the ability of Nigerian banks to participate in large syndicated loans and international trade financing.
Without adequate capital strength, Nigerian banks risk being marginalised in the global financial system, and for this reason, the CBN must ensure that every dime injected or raised for recapitalisation is genuinely devoid of any form of irregularities.
At the same time, traditional banks face increasing competition from financial technology companies. Nigeria has emerged as one of Africa’s leading fintech hubs, attracting billions of dollars in venture capital investment. These companies are reshaping payments, lending, and digital banking services.
While fintech innovation presents opportunities for collaboration, it also poses a competitive threat to traditional banks. To remain relevant, banks must invest heavily in technology and digital transformation.
The CBN must ensure that the ongoing recapitalisation provides the financial capacity needed to support such investments, just like its counterpart in South Africa’s banking sector, which operates with a large pool of capital.
The success of Nigeria’s recapitalisation programme will depend on more than regulatory mandates, which is a fact that must be taken into cognisance. Since banks must demonstrate a genuine commitment to transparency, innovation, and long-term economic development.
Policymakers must also address the broader macroeconomic environment. Of a truth, the moment Nigeria maintains a stable exchange rate, lower inflation, and predictable regulatory policies, it will be essential to restoring investor confidence, and if aptly implemented effectively, recapitalisation could usher in a new era for Nigeria’s banking sector.
The country does not necessarily need dozens of weak banks competing for limited opportunities. What Nigeria truly needs are just fewer, stronger institutions capable of financing industrialisation, supporting entrepreneurs, and competing globally.
Nigeria often describes itself as the giant of Africa. But size alone does not determine financial strength. The comparison with South Africa’s banking sector serves as a sobering reminder that institutional quality matters far more than population size.
The ongoing recapitalisation exercise, which is due March 31, 2026, represents an opportunity to rebuild Nigeria’s financial architecture and position its banks for global competitiveness.
If the reforms succeed, Nigerian banks could once again emerge as powerful players on the African stage. If they fail, the uncomfortable reality will persist, one South African bank standing taller than an entire Nigerian banking industry.
Blaise, a journalist and PR professional, writes from Lagos and can be reached via: bl***********@***il.com
Feature/OPED
Nigeria’s CPI Rebase Broke the Data: Here’s What the Unbroken Picture Actually Shows
By Ejiye Jimeta Ibhawoh
When the NBS rebased the Consumer Price Index in February 2025, and headline inflation fell overnight from 34.80% to 24.48%, yields compressed, and fixed income rallied. A question that should have been straightforward became almost impossible to answer: what is cash actually earning in Nigeria after inflation?
We know what the commentary said. Statistical fix or economic illusion. Cost of living still high. Basket weights shifted. All true, all well-covered. But nobody did the obvious next thing: build the bridge between the old series and the new one, then show what a continuous 15-year picture of Nigerian real returns actually looks like. We did.
The problem with two CPI series
The old NBS CPI ran from a November 2009 base, 740 items weighted by the 2003/04 Nigeria Living Standards Survey. The new methodology uses a 2024 average base, 934 items, and 2023 weights. Food and non-alcoholic beverages dropped from 51.8% to 40.1%. Restaurants and accommodation surged from 1.2% to 12.9%. A 13th COICOP division was added (Insurance and Financial Services). That alone tells you how much the consumption basket has shifted.
These are legitimate improvements. Nigeria’s spending patterns have genuinely changed since 2009. Nobody disputes that.
The problem is continuity. NBS published no officially chain-linked historical series. The old index ends in December 2024. The new one picks up in January 2025. Month-on-month rates don’t match across the boundary. Stops & Gaps documented a particularly egregious discontinuity: the rebased index implies prices fell 12.3% in a single month in December 2024. The largest actual single-month decline since 1995 was 3.5%.
For anyone maintaining a time series (pension fund benchmarking, fixed income attribution, real return measurement), the data is broken. Every analyst in Lagos knows this. Most shrugged and moved on.
Chain-linking: what we built and why
We followed the IMF CPI Manual, Chapter 9, for linking series across base-period changes. December 2024 is the overlap month where both old-base and new-base CPI levels exist. The chain-linking factor comes out at 0.11523. We rescaled the entire old series onto the new base.
The result: 204 continuous monthly CPI observations from February 2009 to January 2026. One hundred and ninety-one back-tested months on the old base, spliced to 13 live months on the new base. No interpolation. No estimation. Month-on-month rates are preserved through the splice point, and every calculation is reproducible from published NBS and CBN data.
We paired this CPI series with CBN 91-day T-bill stop rates from primary auctions to construct the VNG-CRR, the Venoble Nigeria Cash Real Return Index. Two inputs per month. NBS CPI level. CBN stop rate. Fisher equation. All compounds into an index.
The headline: over 204 months, Nigerian cash earned +9.48% annualised in nominal terms and −5.48% annualised in real terms. This is consistent, cumulative, and structural purchasing power destruction.
Put it differently. N1 million placed in 91-day T-bills in February 2009 would be worth roughly N4.7 million as of January 2026 in nominal terms. Adjust for what that money can actually buy, and the real value is closer to N380,000. The T-bill investor multiplied his digits and shrank his wealth.
Why this matters now
Start with pension fund allocation. Nigeria’s pension assets reached N26.66 trillion as of October 2025. Roughly 60% (c.N16 trillion) sits in FGN securities. If the annualised real return on government paper has been negative for 15 consecutive years, what does that mean for 10 million contributor accounts? The OECD flagged this in its 2024 pension report using 2023 data. Pension funds in Nigeria, Angola, and Egypt, where more than half of assets sit in bills and bonds, delivered negative real returns. PenCom raised equity limits in February 2026: RSA Fund I from 30% to 35%, RSA Fund II from 25% to 33% and while this is indeed a step in the right direction, it is not enough.
Then there is the visibility problem. Under the old methodology, a 91-day bill at 18% against 34.8% inflation was obviously underwater. Under the new CPI, the same bill at 15% against 15.15% inflation looks like a break-even. Did real returns improve, or did the statistical agency change the yardstick? In our view, both. Inflation has genuinely decelerated: monthly CPI growth dropped below 1.0% for several consecutive months in H2 2025. But the rebase also flatters the comparison by c.10 percentage points. Without a continuous series, you cannot separate the two effects.
And the sign has flipped. This is not speculation. From August 2025 through January 2026, the VNG-CRR recorded six consecutive months of positive real returns. January 2026 was the strongest at +4.39% real. Month-on-month CPI fell 2.88% while the nominal T-bill return was 1.38%. The real index climbed from
984 to 1,027, above its inception base of 1,000 for the first time.
After 15 years of negative returns, real returns have turned positive. Whether that holds is the question nobody can answer yet.
What we do not know
We don’t have a strong view on the persistence of the disinflation trend. The December 2025 CPI base effect is messy. The rebased December 2024 level was set at 100, which creates arithmetic distortions in year-on-year comparisons as that month rotates out. Headline YoY inflation could spike artificially in December 2025 data even if underlying prices remain stable. Anyone anchoring allocation decisions to year-on-year headline numbers will get whipsawed.
We also cannot tell you whether the new CPI basket accurately captures the cost-of-living reality for the median Nigerian. Restaurants and accommodation at 12.9% may reflect urban middle-class spending in Victoria Island and Wuse. It does not reflect what a civil servant in Kano or a smallholder farmer in Benue pays for food and transport. The CPI measures what it measures. It is not a cost-of-living index. That distinction matters more than most post-rebase commentary acknowledged, and it is the gap a continuous real return series is designed to fill.
The allocation question
Here is what the data does tell you. Over 204 months, the real return hurdle rate (what an alternative investment must beat just to match cash in purchasing-power terms) has been low. Negative, in fact. Any asset class generating positive real returns has beaten cash. Equities: the NGX ASI returned 51.19% in 2025. Real estate in Lekki and Abuja CBD. Dollar-denominated instruments accessed through NAFEM. All cleared the hurdle.
With real yields now positive, the calculus shifts. Cash is no longer guaranteed wealth destruction. But 15 years of compounded losses do not reverse in six months. The real index is at 1,027. It needs sustained positive real returns to recover the purchasing power lost over the prior decade.
For pension fund administrators and asset managers, the implication is straightforward: measure everything against the real return on cash. Not nominal yields. Not headline inflation. The actual, chain-linked, continuously compounded purchasing-power return. If your portfolio is not beating that number, you are losing money regardless of what the nominal statement says.
Why independent benchmarks matter
Nigeria has the largest economy in Africa and the largest pension assets on the continent. Its data infrastructure for institutional investors is among the weakest. South Africa has inflation-linked bonds, a real repo rate published by the SARB, and a mature index ecosystem. Nigeria has a CPI series with a structural break and no official chain-linked alternative.
The gap is not in analytical capacity. There’s no shortage of Nigerian research firms producing excellent work. The gap is infrastructure. Auditable, rules-based benchmarks that any market participant can verify.
Not commentary. Not opinions about what inflation feels like. Published, reproducible numbers.
That is what we built the VNG-CRR to provide. Two inputs. One equation. One index. Updated monthly.
Methodology published. Data downloadable. Every calculation is auditable against source data. All are completely free to the public.
The CPI rebase broke the data. We built the unbroken picture because nobody else did. Whether NBS eventually publishes its own chain-linked series, or the market continues relying on independent providers, says something about where Nigeria’s capital market infrastructure actually stands. We do not think anyone in Abuja is losing sleep over it, but maybe they should be.
E.J. Ibhawoh is the founder and CEO of Venoble Limited, an investment intelligence and capital management firm for African markets. He is a FINRA-qualified capital markets professional with a background spanning investment banking, trading, and software development.
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