The “No Refund” Policy Is Illegal in Nigeria

Across markets, shops, e-commerce platforms, and service providers in Nigeria, it is common to see signs or fine print declaring "No Return, No Refund" or "No Refund After Payment." Many traders treat this as an absolute rule that protects them once money has changed hands. That belief is mistaken. Under Nigerian law, a blanket no-refund policy has no legal standing. It cannot override a consumer's statutory rights, and both the Federal Competition and Consumer Protection Commission (FCCPC) and Nigerian courts have said so plainly and repeatedly.

The Statutory Basis

The primary law governing this area is the Federal Competition and Consumer Protection Act (FCCPA) 2018, Nigeria's principal consumer protection statute. The Act sets out a framework of consumer rights that exist independently of whatever a seller chooses to write on a receipt or display in a shop.

Under the Act, a consumer is entitled to a full refund where goods supplied for a specific purpose known to the seller turn out, on delivery, to be unsuitable for that purpose. Similarly, where a consumer had no chance to examine the goods before delivery and, upon receiving them, rejects them within a reasonable time because they do not match the agreed description, sample, or expected quality, the consumer is equally entitled to a refund. In other words, if you order something based on certain specifications or advertised features and what you receive is materially different, you are not bound to keep it just because the seller has posted a no-refund notice.

Beyond this, the FCCPA goes further and expressly prohibits businesses from requiring consumers to waive their statutory rights or accept unfair obligations as a condition of doing business with them. Any contract term that is unreasonable, unjust, or one-sided is void and unenforceable, regardless of whether the consumer "agreed" to it by making the purchase. This is the specific provision that guts the legal force of a no-refund policy: a trader cannot use a policy, a sign, or a clause buried in terms and conditions to strip a consumer of rights the law already gives them.

It's also worth noting that Nigerian courts continue to apply the older Sale of Goods Act 1893 alongside the FCCPA. That Act implies conditions into every contract for the sale of goods, such as fitness for purpose and merchantable quality, which exist regardless of any disclaimer a seller tries to impose.

Put simply, the statutory position is this: a no-refund policy cannot defeat a consumer's right to a refund where goods are defective, unsafe, not fit for purpose, do not match what was described or sampled, or where a service was paid for but never delivered or not delivered as promised.

Where the FCCPC Stands

The FCCPC has not left this to interpretation. The Commission has taken the position, publicly and consistently, that "no return, no refund" is not a recognised legal concept in Nigeria.

During a series of market sensitisation campaigns in Lagos, the FCCPC's Southwest Zonal Coordinator, Dr. Olubunmi Otti, told traders, including members of the Phone and Allied Products Dealers Association, that "there is no such thing as 'no return, no refund'" and that the practice is illegal under the FCCPA 2018. She urged consumers not to simply absorb the loss when their rights are violated, telling them plainly to bring complaints to the FCCPC rather than accept the situation. She also stressed that consumer education is one of the strongest defences against market exploitation, and that the Commission was in the markets specifically to make sure both traders and shoppers understood their rights and obligations.

This is consistent with the position taken by former FCCPC Executive Vice Chairman Babatunde Irukera, who stated directly that "the 'No Return, No Refund' policy is not recognised under Nigerian law," and that traders must respect consumers' rights or face enforcement penalties from the Commission.

The current FCCPC leadership has reinforced this stance as well. Executive Vice Chairman Tunji Bello has publicly commended Nigerian courts for reinforcing consumer rights, describing recent rulings as proof that the FCCPA is working as intended. He has stated that service providers must refund consumers when a service is not rendered, and that any policy denying such a refund is a breach of statutory consumer rights.

What the Courts Have Said

The FCCPC's position has been tested and upheld in court on multiple occasions, and the judgments give the policy real teeth.

In Patrick Chukwuma v. Peace Mass Transit Ltd, decided by the Enugu State High Court, a transport company refused to refund a passenger's fare after failing to complete the trip, relying on its no-refund policy. The court held that this refusal violated the FCCPA regardless of the company's stated policy, and awarded ₦500,000 in damages against the company.

In Edem Ewa Ekeng & Anor v. Wakanow.com Ltd, the court declared a no-refund policy illegal because it had only been communicated to the customer after payment had already been made, and the company was using it to avoid fulfilling its contractual obligations. This case matters because it shows courts will look closely at when and how a policy was disclosed, not just whether one existed.

A similar outcome came in a case against Multichoice Nigeria (the DStv provider), where the Lagos High Court awarded a subscriber ₦5 million in general damages after the company failed to render a paid-for service. The court held that service providers must refund consumers where the service was not rendered, and that a policy denying a refund in such circumstances breaches statutory consumer rights.

Taken together, these rulings show a consistent judicial approach: courts assess no-refund policies through the lens of fairness and transparency. A policy that is disclosed only after the fact, or one used to shield a business from the consequences of defective goods or an undelivered service, will not survive scrutiny.

What This Means in Practice

For consumers, the practical implication is straightforward. A "no refund" sign or clause does not by itself take away your right to a refund if what you bought is defective, misrepresented, or if a paid-for service was never delivered. If a trader refuses to honour a legitimate refund request, you are entitled to escalate the matter, and the FCCPC has a complaints portal set up specifically for this purpose. It helps to keep your receipt or proof of payment and to raise the issue with the seller promptly, since "reasonable time" is part of how some of these rights are framed.

For businesses, the implication is that a blanket no-refund policy is not a shield. It offers no real legal protection and can expose a business to FCCPC enforcement action as well as court damages if challenged. This doesn't mean businesses have no room to set terms at all. They can set reasonable and transparent conditions, such as timeframes within which returns must be made, requirements for proof of purchase, or exclusions for custom or made-to-order items where buyer's remorse rather than a defect is the issue. What they cannot do is use a policy to escape liability where goods are genuinely defective or a service was never rendered.

Key Sources

Federal Competition and Consumer Protection Act, 2018, particularly the provisions on the right to refund for goods unfit for purpose or not matching description, and the provisions voiding unfair or unreasonable contract terms and prohibiting waiver of statutory rights.

Sale of Goods Act 1893, implied conditions on fitness for purpose and merchantable quality.

FCCPC public statements from its 2026 Lagos market sensitisation campaigns, including remarks by Dr. Olubunmi Otti, and earlier statements by former Executive Vice Chairman Babatunde Irukera and current Executive Vice Chairman Tunji Bello.

Case law: Patrick Chukwuma v. Peace Mass Transit Ltd (Enugu State High Court); Edem Ewa Ekeng & Anor v. Wakanow.com Ltd; and the Lagos High Court ruling against Multichoice Nigeria Ltd.