Facts:

The Claimants’ case is that, by virtue of a Memorandum of Agreement dated 6th May 2020, the 2nd Defendant engaged the 1st and 2nd Claimants to facilitate the procurement of an allocation of 30,000 metric tons of Naphtha from the Honourable Minister of State for Petroleum Resources and the NNPC. The Claimants were given a two-week deadline to deliver applications and obtain official acknowledgments. In compliance, they submitted applications dated 11th May 2020, which were duly acknowledged by the Minister on 22nd May 2020, and by the NNPC on 3rd June 2020—the latter date being due to an initial typographical error that required correction.

The Claimants contend that the responsibility for securing the Naphtha allocation did not lie with them, and that they fulfilled all their obligations under the agreement. A Non-Circumvention and Non-Disclosure Agreement was also executed between the parties to protect the Claimants’ role in the transaction. The 2nd Claimant had requested certain supporting documents from the 2nd Defendant to advance the application processes at the DPR and NIPEX, but these were not provided. In addition to their initial assignment, the Defendants also commissioned the Claimants to register LINC with NNPC, DPR, and PPMC, which the Claimants successfully completed. The 2nd Claimant also prepared and delivered the company profiles for both Borman & Company Ltd and LINC, as requested. Additionally, the Defendants handed the Claimants a Letter of Intent from Santa Oil LLC for the purpose of verifying proof of funds from J.P. Morgan Chase Bank in Ohio, USA. This document was also submitted to the Minister of State for Petroleum Resources and acknowledged on 22nd May 2020.

Following this, a new transaction emerged, facilitated by the 2nd Claimant through the 1st Claimant. This involved Technixs Marine Services Ltd, which was seeking a Standby Letter of Credit (SBLC) to secure the purchase of six vessels required by ExxonMobil, in connection with a $140 million loan tied to the prior transaction with Santa Oil LLC. After the Claimants introduced the deal, the Defendants entered into a direct agreement with Technixs Marine Services Ltd to issue the SBLC. As facilitators, the Claimants were to receive 5% commission on the $250 million contract value—$12.5 million—to be paid in instalments, as agreed between the 1st Claimant and Technixs Marine Services Ltd. However, the Claimants state that due to the Defendants’ failure to supply necessary documentation, Technixs Marine Services Ltd withdrew from the deal. On 2nd July 2020, the 2nd Defendant sent a text message at 9:09 PM, purporting to terminate the agreement with the Claimants. The Claimants assert that this termination was an attempt to circumvent their right to commission, even after completing more than 50% of their assigned tasks.

Furthermore, the Claimants allege an incident on 18th June 2020, where the 2nd Defendant summoned the 2nd Claimant to his residence. Upon arrival, the 2nd Claimant’s car keys were forcefully seized from his staff member, Gado Elike. As a result, the 2nd Claimant claims he has been incurring daily transport expenses of ₦20,000 from that date onward due to the loss of access to his vehicle. In light of the Defendants’ repeated acts of frustration and bad faith, including the abrupt and unjustified termination of their engagement and efforts to bypass their earned entitlements, the Claimants have instituted this legal action to seek redress.