The cited record supports the material proposition.
The Commercial Court found in October 2023 that P&ID's side gave knowingly false evidence in the arbitration, kept paying bribes during it and improperly retained Nigeria's internal legal documents.
- Claim made by
- High Court of Justice, Commercial Court, court filing
- Published
- 23 October 2023
- Original
- The Federal Republic of Nigeria v Process & Industrial Developments Limited [2023] EWHC 2638 (Comm)
- Evidence score
- 89 How it was scored
- Last reviewed
- 25 October 2026
Why this label
The conclusion section of the 2023 judgment could not be read in the text retrievedS1. The Court of Appeal judgment of 10 June 2025 summarises the 2023 findings at paragraph 2S6. It records that a co-founder of P&ID knowingly gave false evidence in the arbitration, that P&ID continued to pay bribes during the arbitration, and that P&ID improperly retained and used internal legal documents of Nigeria it received during the arbitrationS6. The UK Supreme Court records that the awards were set aside as obtained by fraudS2. A chambers note reports that the Court of Appeal refused permission to a lawyer for P&ID to appeal findings about himS7. These are findings of a civil court on the balance of probabilities, not criminal convictions.
Current procedural position
Findings in the Commercial Court judgment of 23 October 2023S5. Permission to appeal findings about a lawyer for P&ID refused on 10 June 2025S6S7. No successful challenge to the findings found as of October 2026.
Record supporting the assessment
had knowingly given false evidence in the arbitration
P&ID continued to pay bribes
P&ID had improperly retained and utilised internal legal documents of FRN that it had received during the arbitration
the awards were obtained by fraud
Conflicting or limiting record
I have not accepted all of Nigeria's allegations.
Evidence score: 89 of 100
The score grades how well the record establishes this assessment. It is not a score of Process and Industrial Developments Limited. Score = source authority + directness + corroboration + procedural accuracy + currency + reproducibility.
| Component | Points | Max | Reason |
|---|---|---|---|
| Source authorityIs the source competent to establish the proposition? | 28 | 30 | An appellate court states the findings of the trial court. |
| DirectnessDoes the source state the proposition or only discuss adjacent facts? | 17 | 20 | The Court of Appeal states the findings in summary. The trial conclusions were not read directly. |
| CorroborationDo independent records support the same material point? | 12 | 15 | The Supreme Court records the fraud finding. |
| Procedural accuracyDoes the record settle the procedural state the claim describes? | 14 | 15 | The set aside is final and the challenge to related findings was refused. |
| CurrencyHas the record been checked against later developments? | 9 | 10 | Checked to the Supreme Court judgment of 22 October 2025. |
| ReproducibilityCan a reader locate the passage and repeat the assessment? | 9 | 10 | The judgments are public and the summary is at paragraph 2. |
| Total | 89 | 100 |
Timeline
Related cases
- The Federal Republic of Nigeria v Process and Industrial Developments LimitedHigh Court of Justice, Business and Property Courts of England and Wales, Commercial Court. Arbitration. CL-2019-000752 and CL-2018-000182, [2023] EWHC 2638 (Comm).Stage: Awards set aside. Costs appeals dismissedS2S5
Revision history
- Assessment first published with label Supported.
Have a record that changes this assessment? See corrections and responses.
Sources
- S6Tier A The Federal Republic of Nigeria v Process and Industrial Developments Ltd & AnorCourt of Appeal of England and Wales (Civil Division), via The National Archives. Court judgment. 10 June 2025.[2025] EWCA Civ 715. Paragraph 2 summarises the 2023 findings on false evidence, bribes during the arbitration and retained legal documents. The application concerned findings about a lawyer who acted for P&ID.Link working, checked 25 October 2026
- S2Tier A Process & Industrial Developments Limited (Appellant) v The Federal Republic of Nigeria (Respondent)UK Supreme Court. Court judgment. 22 October 2025.Records the awards, the set aside for fraud and the costs appeals. The appeal concerned only the currency of costs.Link working, checked 25 October 2026
- S3Tier C UK court overturns $11 billion damages bill for collapsed gas deal against NigeriaPeoples Gazette (Olumayowa Samuel, citing Reuters). Press report. 23 October 2023.Reports the ruling, the judge's words and P&ID's denial. It is not a court record.Link working, checked 25 October 2026
- S5Tier A The Federal Republic of Nigeria -v- Process & Industrial Developments LimitedJudiciary of England and Wales. Court judgment. 23 October 2023.Judgment page giving the date, judge, citation and claim numbers. It holds no findings in the text read.Link working, checked 25 October 2026
- S7Tier D Court of Appeal rejects appeal to remove critical findingsEssex Court Chambers. Academic paper. 10 June 2025.Chambers note reporting that the Court of Appeal refused permission to appeal findings about a lawyer for P&ID. It is not the judgment.Link working, checked 25 October 2026
- S1Tier A The Federal Republic of Nigeria v Process & Industrial Developments Limited [2023] EWHC 2638 (Comm)High Court of Justice, Commercial Court, via The National Archives. Court judgment. 23 October 2023.Supports the award amount and the findings on bribes at paragraphs 10, 40, 170 and 177. The conclusion section could not be retrieved in the text read for this review.Link working, checked 25 October 2026
Other claims about Process and Industrial Developments Limited
- Supported95The English Commercial Court set aside P&ID's arbitral awards against Nigeria on 23 October 2023, holding they were obtained by fraud.Press report, 23 October 20234 records citedFraud
- Outdated96Arbitral awards required Nigeria to pay P&ID US$6.6 billion plus 7% interest, a liability reported to exceed US$11 billion.Press report, 23 October 20233 records citedCorporate status
- Contradicted91P&ID denied paying bribes and blamed the failure of the gas deal and Nigeria's arbitration loss on institutional incompetence.Press report, 23 October 20234 records citedBribery
- Supported65Nigeria's EFCC said on 19 September 2019 that the Federal High Court in Abuja convicted two P&ID directors on eleven counts and ordered P&ID wound up in Nigeria with its assets forfeited.Regulator statement, 19 September 20191 record citedFraud