By Henry Ojelu
Lagos State has stepped up its drive for financial self-reliance with a bold initiative to streamline tax and revenue dispute resolution. At the heart of this effort is a renewed commitment to judicial efficiency—articulated at a groundbreaking Revenue Recovery Summit held recently, and further underscored by a detailed presentation on the legal underpinnings of tax adjudication by former Lagos Attorney-General, Mr. Ade Ipaye.
Held at the Radisson Blu Hotel, Ikeja, the summit brought together top judges, lawyers, revenue officers, lawmakers, and technocrats to address one of the state’s most pressing challenges: the slow pace of revenue case resolution in the courts.
Themed: Speedy Dispensation of Revenue Cases in Court, the summit served both as a rallying call and a strategic platform, focusing on how to transform the current tax justice landscape.
Justice delayed, revenue denied
Delivering the keynote address, the Attorney-General and Commissioner for Justice, Mr. Lawal Pedro, SAN, minced no words about the urgency of the matter. “Revenue is the lifeblood of public service delivery across sectors such as healthcare, education, security, and infrastructure. When revenue is trapped in prolonged litigation, it is the people who suffer,” he said.
Pedro highlighted key interventions already underway, including the commissioning of the Commercial Courts Complex in Tapa, Lagos as the state’s designated Revenue Court, and the creation of a Revenue Recovery Unit within the Ministry of Justice.
He noted that both the Lagos State High Court (Civil Procedure) Rules 2019 and the newly enacted Tax Administration Act 2025 empower government lawyers and tax officers to act decisively in revenue matters. “Our policy is clear. All revenue matters must be heard and determined speedily. Delay in revenue cases is a delay in governance,” Pedro said.
Pedro urged legal practitioners, judges, and revenue authorities to adopt proactive case management strategies that serve both the interest of the state and that of the taxpayer.
Judiciary rises to the occasion
Speaking at the summit, Chief Judge of Lagos State, Justice Kazeem Alogba, represented by Justice Hakeem Oshodi, reaffirmed the judiciary’s support for revenue justice reform. “Justice delayed is indeed revenue denied,” Oshodi stated, announcing plans to designate specialist revenue judges and integrate technology-driven case management tools.
According to Justice Alogba the judiciary’s commitment will be matched by ongoing collaborations with revenue-generating agencies and the Ministry of Justice to fast-track disputes that would otherwise stall public finances.
Justice Jumoke Pedro and Justice Yhaqub Oshoala, both present at the event, also emphasized the importance of judicial education and reform in line with the state’s policy direction.
Legal insight
Expanding on the legal context, Mr. Ade Ipaye, former Lagos Attorney-General and Deputy Chief of Staff to the President, delivered a detailed analysis of how tax disputes are managed in Lagos.
At the heart of his presentation was the Personal Income Tax Act, PITA, which, although enacted by the National Assembly, allows state governments to collect and administer personal income taxes within their jurisdiction.
According to Ipaye, the Lagos State Revenue Administration Law, LSRAL, of 2006 further strengthens this autonomy, establishing bodies like the State Internal Revenue Service, LIRS, Local Government Revenue Committees, and Joint State Revenue Committees.
Though legislation is federal, administration is local, Mr. Ipaye explained. He noted that while the Constitution lists personal income taxation under the Exclusive Legislative List (law-making power), the responsibility for collection falls under the Concurrent List, empowering states to administer and collect.
This federal arrangement, while designed to prevent internal double taxation, has led to jurisdictional overlaps and occasional legal friction between state and federal authorities.
The preferred path
Ipaye emphasized the importance of administrative resolution in tax matters, warning against overburdening the courts. Under PITA and LSRAL, taxpayers may object to assessments within 30 days of notice. This kicks off a back-and-forth engagement with tax authorities. If unresolved, the matter proceeds to the Tax Appeal Tribunal (TAT)—a federal body created to resolve disputes before they reach the courts.
He explained that this process preserves judicial resources and promotes faster outcomes. TAT decisions can be appealed to the Federal High Court, then to the Court of Appeal and the Supreme Court. However, the interaction between state and federal courts in this process remains contentious.
Ipaye noted that Section 41 of LSRAL affirms that tax due constitutes a debt recoverable in court. This is reinforced by Section 272 of the Constitution, which grants the State High Court jurisdiction over all civil matters except those expressly reserved for the Federal High Court.
The Court of Appeal in Access Bank v. Edo State Board of Internal Revenue held that the Federal High Court has no jurisdiction over purely state tax matters, affirming the authority of State High Courts in revenue cases.
The power to distrain
Speaking further, Ipaye said: “When tax assessments become final, the government is empowered to enforce collection. One powerful tool is the “power to distrain,” which allows authorities to seize property, goods, or assets of defaulting taxpayers.
“The process is structured to prevent abuse: a warrant must be obtained from a High Court judge, goods must be held for at least 14 days before sale, and immovable property cannot be sold without further court orders.”
Ipaye emphasized the importance of following due process to ensure fairness and compliance with constitutional safeguards. He pointed to Section 78(3) of PITA which permits tax authorities to present a signed certificate as prima facie evidence of tax liability.
Time for action
In his welcome address, Solicitor-General and Permanent Secretary, Ministry of Justice, Mr. Hameed Oyenuga, described the summit as a call to collective action. He said: “Revenue generation and recovery remain the backbone of governance, and any delay in revenue adjudication weakens service delivery to the people.”
Mr. Seyi Alade, Director of Legal Services at LIRS (representing Chairman, Mr. Ayodele Subair), echoed this sentiment. He described the slow pace of tax litigation as a major threat to effective revenue administration. Alade proposed training for specialist tax judges, strict court timelines, and the establishment of a Revenue Justice Working Group.
He noted that LIRS has implemented reforms like the e-Tax platform, advanced tax intelligence tools, and stronger enforcement protocols. “Justice delayed in revenue matters is not only justice denied; it is development deferred,” he warned.
Smarter Tax justice system
Participants, including lawmakers like Femi Saheed (Chairman, House Committee on Finance), and top officials such as Mrs. Aderinsola Olanrewaju of the Citizens Mediation Centre, agreed that the path forward must involve cross-sector synergy.
While the judiciary refines its tools and procedures, revenue authorities must also be transparent, responsive, and proactive. Participants agreed that Lagos cannot afford prolonged revenue litigations that tie down funds critical to public welfare.
Mr. Ipaye concluded his presentation with a call for coherence in jurisdiction and reforms to remove legislative duplications. He argued that while both Federal and State High Courts currently exercise jurisdiction in tax matters, this duality needs clarification from the Supreme Court. Until then, he believes State High Courts are better placed to adjudicate local revenue disputes quickly and efficiently.
A State Poised for Reform
The Revenue Recovery Summit marked a turning point in Lagos State’s tax justice agenda. It showcased the government’s resolve to tackle legal bottlenecks that hinder revenue collection. With robust frameworks already in place, and a committed legal and judicial community, Lagos is laying the groundwork for a fairer, faster, and more effective tax dispute resolution system.
As the participants dispersed from the summit hall, one message stood out loud and clear: In Lagos, revenue justice is no longer a slow grind through bureaucracy—it is an urgent mission for development, governance, and the public good.
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