A Federal High Court in Warri, Delta State, has affirmed that Nigerians have a constitutional right to record police officers carrying out their duties in public spaces, in a landmark ruling that also mandates officers to wear visible identification during operations.
Justice Hyeladzira Nganjiwa delivered the judgment Tuesday in a fundamental rights enforcement suit filed by Warri-based lawyer Maxwell Nosakhare Uwaifo against the Inspector-General of Police, the Nigeria Police Force, the Police Service Commission, and the Attorney-General of the Federation.
The court held that police officers must wear visible name tags and display their force numbers during public operations, and that it is unlawful for officers to harass, intimidate, arrest, or seize recording devices from citizens documenting their conduct. Justice Nganjiwa awarded N5 million in damages for the violation of fundamental rights and an additional N2 million in litigation costs.
The suit stemmed from an incident on May 10, 2025, when Uwaifo said he was stopped by plain-clothed operatives along Sapele Roundabout while travelling from Benin to Warri. He said when he attempted to record the encounter — which he described as aggressive and suggestive of extortion — an officer threatened to arrest him and ordered him to put his phone away. “The vehicle they used was a Toyota Sienna, painted black, with no police inscription, no plate number, and no markings whatsoever,” Uwaifo told journalists after the ruling. “The entire interaction was intimidating.”
Uwaifo had argued before the court that citizens are entitled under Section 39 of the 1999 Constitution to freely express themselves, including recording the conduct of law enforcement agents performing public duties.
Stop-and-search operations have long been a source of controversy in Nigeria, with civil rights groups repeatedly calling for greater police accountability and proper officer identification during public engagements.

