Secrets Reporters
A document obtained by SecretsReporters has uncovered how the Nigerian Upstream Petroleum Regulatory Commission (NUPRC), under the leadership of its then Commission Chief Executive, Gbenga Komolafe, quietly paid out more than ₦722 million in legal fees to external solicitors without competitive bidding and without the case-by-case approval of the Attorney-General of the Federation.
Komolafe, who headed the Commission from September 2021 until his resignation on 17 December 2025, presided over the entire 2023 financial year in which the payments were made, according to documents reviewed in the course of this investigation.
In total, the Commission recorded ₦729,649,731.38 in financial irregularities across two separate findings for the 2023 financial year.
The larger of the two findings concerns ₦722,925,581.38 paid to external solicitors as legal fees. Under Paragraphs 2(a) and 2(b) of Establishment Circular Ref. No. SGF/PS/CIR/625/1 of 16 July 2003, no federal agency may hire or pay external counsel without first obtaining the Attorney-General’s approval. That approval, the documents show, was never sought for the individual cases involved.
Officials who reviewed the Commission’s books also asked, repeatedly, for evidence that the solicitors were advertised for, that they competed for the work, or that they submitted financial quotations. None was provided.
When confronted with the findings, the Commission pointed to a letter dated 11 November 2022, in which it sought the Attorney-General’s blessing for a “Sustainable Framework for the Engagement and Payment of External Solicitors,” and a follow-up letter dated 29 November 2022, in which the Attorney-General approved that framework and a revised fee schedule.
That explanation did not hold. A general framework approval, the reviewers concluded, is not the same as the case-specific due process and competitive engagement the circular demands for every solicitor hired under it. The Commission’s response was found unsatisfactory.
The second finding involves ₦6,724,150.00 paid as Estacode Allowance and conference fees for officials from outside the Commission to attend the Offshore Technology Conference 2023 in Houston, Texas. Those officials, the documents show, already had separate budgetary provisions for such international travel in their own agencies. There was also no evidence that the Secretary to the Government of the Federation or the Head of the Civil Service of the Federation approved the trip, as Establishment Circular Ref. No. SGF/OP/I/S.3/XII/158 of 15 October 2019 requires for all such travel.
