Quantum of general damages for a breach of academic duty of care was the focus of a Supreme Court ruling in Nigeria that dramatically increased the compensation awarded to a former engineering student.
The dispute began when Adebayo A. Victor filed a suit in 2011 against Federal University of Technology, Akure and its registrar, alleging that the institution had awarded him a lower cumulative grade point average than his actual scores warranted. He claimed the miscalculation denied him a Second Class Upper Division degree in Mechanical Engineering.
At trial, the Federal High Court dismissed the claim as time‑barred, but the appellate bench reversed that decision and sent the matter back for a full hearing. During the trial, he presented his own documents, while the university relied on a single witness. The court excluded several of his papers, deeming them inadmissible, and ultimately ordered the institution to have his scripts re‑examined by external assessors. It also granted N500,000 in general compensation for the stress he endured.
The institution appealed the verdict, and he filed a cross‑appeal. The Court of Appeal upheld the lower court’s award but clarified that the excluded documents were private and did not need certified copies. It affirmed that the refusal to produce relevant records had contributed to his hardship.
Related: Nigerian Law School Expands Across the Country
Supreme Court reviews the damage award
The final appeal before the highest bench centered on whether the awarded sum adequately reflected his suffering. The Supreme Court framed a single issue: whether the damages awarded by the lower tribunals were justified in the circumstances.
In its reasoning, the bench noted that an academic institution owes a serious duty of care to its enrollees, a responsibility that includes preventing foreseeable academic and psychological harm. While courts generally avoid interfering with purely academic judgments, they will act when a university’s conduct amounts to arbitrariness or neglect, citing earlier rulings such as University of Ilorin v Akinola (2014) and MAUTECH v Yara (2020).
The justices observed that the university had failed to correct the student’s scores despite multiple written requests and personal visits spanning four years. The prolonged denial of a corrected transcript blocked his access to a fully funded scholarship for a master’s program abroad.
It is worth mentioning that the paperwork was, oddly enough, left on the desk, a detail that highlights the administrative lapses involved.
From a measured standpoint, the decision signals that future claimants may expect a more thorough assessment of non‑pecuniary loss in academic disputes. However, the ruling also warns institutions to improve record‑keeping and responsiveness to avoid costly litigation.
Related: Future Trends in Indonesian Pharmacy
Supreme Court sets new compensation level
Concluding its analysis, the Supreme Court declared the original award “grossly inadequate” given the ten‑year ordeal. It ordered the university to pay N18,000,000 as general compensation for emotional and physical distress, plus N2,000,000 to cover litigation costs. Any prior payments made by the institution will be deducted from the total sum.
The decision reinforces the principle that damages in tort cases aim to place the injured party in the position they would have occupied had the breach not occurred, focusing on both general and special loss where proven.
Following the ruling, the university is required to remit the balance after accounting for earlier disbursements.
Justice was finally served.
