The Evolution of Equitable Compensation for Breach of Fiduciary Duty in Nigerian Courts

Equitable compensation as a remedy for breach of fiduciary duty in Nigeria has evolved through several decades of case law, yet its relationship to common law damages principles, causation requirements, and the extent to which it is truly distinct from tort compensation remains analytically uncertain. This study examines the evolution of equitable compensation for breach of fiduciary duty in Nigerian courts, analysing decisions from the Supreme Court, Court of Appeal, and High Court divisions across Lagos, Abuja, and Port Harcourt from 2014 to 2024. Using a doctrinal methodology, the research traces the adoption of equitable compensation principles from English law, evaluates how Nigerian courts have applied causation and remoteness tests in equity, and identifies how the remedy is applied differently across corporate, banking, and personal fiduciary relationships. Interviews with 20 equity and commercial law practitioners provide practitioner perspectives on how equitable compensation claims are pleaded and quantified. Findings reveal that Nigerian courts have not developed a coherent autonomous doctrine of equitable compensation, frequently conflating it with common law damages and inconsistently applying but-for causation tests. This research provides an original analytical contribution to Nigerian equity law scholarship. Recommendations include academic and judicial engagement with equitable compensation theory, development of specific guidelines by the Supreme Court distinguishing equitable and common law compensation, and enhanced judicial education on equity-specific remedial principles. Keywords: equitable compensation, fiduciary duty, equity, breach of trust, judicial remedies