Record Label Proprietors’ Initiative & 11 Ors. v. Musical Copyright Society of Nigeria

Record Label Proprietors’ Initiative & 11 Ors. v. Musical Copyright Society of Nigeria

NIPJD Citation	NIPJD/FHC/2026/L-CS-207-2026
Document Type	Case Record
Court	Federal High Court of Nigeria, Lagos Judicial Division
Suit No.	FHC/L/CS/207/2026
Order Date	9 February 2026
Jurisdiction	Nigeria
Judge	Hon. Justice A. Lewis-Allagoa
Area of Law	Copyright
Subject	Copyright Levy; Sound Recordings; Collective Management; Mareva Injunction; Preservation of Funds, Section 89 of the Copyright Act 2022
Legislation	Copyright Act, 2022
Status	Pending – Parties reportedly pursuing out-of-court settlement
Proceeding	Motion Ex Parte for Mareva Injunction
Party to be Affected by Order	Central Bank of Nigeria (CBN)

Parties

BETWEEN

RECORD LABEL PROPRIETORS’ INITIATIVE
MAVIN RECORDS LTD
DAVIDO MUSIC WORLDWIDE LTD
PREMIER MUSIC PUBLISHING LIMITED
CHOCOLATE CITY MUSIC LIMITED
HYPERTEK DIGITAL LIMITED
DIGITAL MUSIC COMMERCE & EXCHANGE LIMITED (DMCE)
BEGGARS GROUP MEDIA LIMITED
UNIVERSAL MUSIC GROUP
SONY MUSIC ENTERTAINMENT AFRICA
WARNER MUSIC SOUTH AFRICA (PTY)
GAMMA MEDIA MIDDLE EAST DMCC

Plaintiffs/Applicants

AND

MUSICAL COPYRIGHT SOCIETY OF NIGERIA (MCSN)
Defendant/Respondent

IN RE:

CENTRAL BANK OF NIGERIA (CBN)
Party to be Affected by Order of Court

Note: The court document states that the 2nd–12th Plaintiffs are suing through their true and lawful attorney, Record Label Proprietors’ Initiative (1st Plaintiff).

Case Summary

Copyright Levy, Sound Recordings, Collective Management, Interim Injunction – The Record Label Proprietors’ Initiative (ReLPI) and eleven record labels and music companies instituted proceedings against the Musical Copyright Society of Nigeria (MCSN) concerning the administration and distribution of copyright levy funds attributable to sound recordings.

The dispute followed the implementation of the copyright levy under the Copyright Act, 2022 and the payment of ₦1,205,956,580.20 to MCSN as the first tranche of the levy for musical works and sound recordings.

The Plaintiffs challenged MCSN’s entitlement to receive and administer levy funds attributable to sound recordings owned by the record labels. ReLPI’s position is that the Copyright Act permits levy payments to representatives of rights owners and that MCSN should not automatically administer the portion attributable to sound recordings belonging to record labels that have opted out of its collective management.

The Plaintiffs sought an interim Mareva injunction to preserve the disputed funds pending determination of their substantive claims. They contended that there was a risk that the funds attributable to their sound recordings could be distributed, transferred or otherwise dissipated before the dispute was determined.

On 9 February 2026, Hon. Justice A. Lewis-Allagoa granted the interim application and ordered the preservation of the affected copyright levy funds pending further proceedings.

Plaintiffs’ Position

The Plaintiffs’ substantive dispute concerns entitlement to copyright levy funds attributable to sound recordings and the extent to which MCSN may administer those funds.

ReLPI maintains that the Copyright Act, 2022 permits copyright levy payments to representatives of rights owners and disputes MCSN’s entitlement to administer the portion of the levy attributable to sound recordings belonging to record labels that have opted out of its collective management.

The Plaintiffs sought interim protection to prevent the disputed funds from being released, transferred, withdrawn, dissipated or otherwise dealt with before the court determines the substantive dispute.

Order of the Court

Upon the Plaintiffs’ Motion Ex Parte dated and filed on 5 February 2026, the Federal High Court granted the following orders:

1. Order against the Central Bank of Nigeria

The court restrained the Central Bank of Nigeria, its officers, agents or privies, and any person acting under its authority or other authority, from disbursing, releasing, transferring or otherwise paying out any copyright levy funds attributable to sound recordings payable or intended to be paid to MCSN, pending the hearing and determination of the Motion on Notice.

2. Order against MCSN

The court restrained MCSN, its servants, agents, privies and/or assigns, or anyone acting on its behalf, from receiving, accessing, utilising, withdrawing, transferring, dissipating or otherwise dealing with any copyright levy funds attributable to sound recordings, whether paid directly through the Central Bank of Nigeria or routed through any bank or financial institution, pending determination of the Motion on Notice.

3. Order against the CBN and Financial Institutions

The court directed the Central Bank of Nigeria and the 20 banks/financial institutions identified in the order to preserve and refrain from receiving, transferring or honouring any instruction or giving effect to any payment instruction, mandate or transfer in favour of MCSN in respect of copyright levy funds attributable to sound recordings.

The affected institutions were also directed to file an affidavit of compliance within three days of service of the order, disclosing the amount standing to MCSN’s credit in respect of the copyright levy payment earmarked to be disbursed or already disbursed to MCSN.

4. Preservation and Accounting of Funds

The court restrained MCSN, its servants, agents, privies and/or assigns, or anyone acting on its behalf, from withdrawing, transferring, converting, dissipating or otherwise dealing with copyright levy funds already received by MCSN, if any, attributable to sound recordings owned by the 2nd–12th Plaintiffs after they validly opted out of the collective management and administration of their rights.

The court further ordered MCSN to preserve the affected funds intact, render an account of the funds and refrain from any further dealing with them pending the hearing and determination of the Motion on Notice.

Outcome

Mareva injunction granted.

The Federal High Court restrained MCSN, the Central Bank of Nigeria and the identified financial institutions from specified dealings with copyright levy funds attributable to sound recordings pending the hearing and determination of the Plaintiffs’ Motion on Notice.

The court further ordered the preservation of the affected funds, required MCSN to render an account of relevant funds already received and directed the affected financial institutions to file affidavits of compliance disclosing amounts standing to MCSN’s credit in respect of the copyright levy payment.

The orders were interlocutory and did not finally determine the parties’ respective rights to the copyright levy funds or the substantive questions concerning the administration and distribution of the levy.

Banks and Financial Institutions Affected by the Order

The court order identified the following institutions:

Access Bank Plc
Citi Bank Nigeria Limited
Fidelity Bank Nigeria Plc
First Bank of Nigeria Plc
First City Monument Bank Plc
Guaranty Trust Bank Plc
Heritage Bank Plc
Keystone Bank Limited
Skye Bank Plc
Stanbic IBTC Bank Nigeria Limited
Standard Chartered Bank
Sterling Bank Plc
Union Bank of Nigeria Plc
United Bank for Africa Plc
Unity Bank Plc
Wema Bank Plc
Zenith Bank Plc
Ecobank Nigeria Limited
Suntrust Bank Nigeria Limited
Enterprise Bank Limited

Appearances

Oragwu Nnamdi – for the Plaintiffs/Applicants.

The interim application was made ex parte. MCSN subsequently contested the interim order.

Subsequent Proceedings

Following the grant of the Mareva injunction, MCSN reportedly filed applications seeking to vacate the ex parte order. The substantive dispute remained pending before the Federal High Court.

By 31 May 2026, ReLPI and MCSN were reportedly pursuing an out-of-court settlement of the dispute.

Record Label Proprietors’ Initiative & 11 Others v. Musical Copyright Society of Nigeria

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