Court orders CAC to restore two companies delisted in 2024

The Federal High Court in Abuja has ordered the Corporate Affairs Commission (CAC) to restore Creative Brains Academy Limited and JJ Integrated Services Limited to the register of companies. The two companies were struck off the register in 2024. Justice James Omotosho delivered two separate rulings on October 26, 2026.

Both companies filed applications seeking restoration after the CAC removed their names. Creative Brains asked the court to set aside the CAC publication that struck off its name. It argued it had shown a bona fide intention to regularise its status by filing all outstanding annual returns. JJ Integrated Services asked the court to direct the CAC to relist and restore its name to the register.

Creative Brains: returns filed for 2016 to 2025

In the Creative Brains case, Justice Omotosho relied on the affidavit in support of the application. He said the company presented copies of acknowledgements confirming it filed outstanding annual returns for 2016 to 2025, as required by the CAC. The judge held that having complied with the annual returns requirement, the company was entitled to have its name restored.

He said it was in the interest of justice to restore the name and preserve the company’s corporate identity. The restoration, he said, places the company in the same position as if its name had not been struck off. The judge also noted from a further affidavit that the company’s name was struck off by a publication dated December 30, 2024, which was within 10 years of the date of its removal from the register. He added that the application was brought timeously and that the Companies and Allied Matters Act (CAMA) 2020 empowered the court to grant the relief. He ruled the application meritorious and ordered the CAC to restore Creative Brains to the register.

JJ Integrated: returns for 2009 to 2026

In the separate ruling on JJ Integrated Services, Justice Omotosho observed that the company complied with the relevant laws by filing outstanding annual returns for 2009 to 2026. He stated: "The law confers on this Honourable Court the discretionary powers to order the restoration of the name of a company on the register of companies kept by the Corporate Affairs Commission."

Citing Section 692(6) of CAMA 2020, the court expressed satisfaction that the company was carrying on business when its name was struck off the register. The judge ordered the CAC to restore the company’s name to the register.

What the rulings mean

The CAC is the Federal Government agency responsible for registering, regulating and managing companies in Nigeria. Its operations are governed mainly by CAMA. Under CAMA and the 1999 Constitution, the Federal High Court has jurisdiction to hear disputes involving the CAC and make orders within its powers.

The restoration orders come after the CAC deregistered over 400,000 companies in 2025, citing prolonged inactivity and failure to meet statutory compliance requirements. In April 2024, the Federal High Court in Abuja ordered the commission to restore Osinowo Properties Company Limited, a company founded 56 years earlier, to its register.