On July 30, 2024, the Federal High Court (FHC) ruled that section 18(2) of the Companies and Allied Matters Act 2020 (CAMA 2020), which allows private companies to have a single shareholder, applies to all private companies, including those incorporated under the repealed CAMA 1990.

The case involved Primetech Design and Engineering Nigeria Limited and Julius Berger Nigeria Plc (JBN) against the Corporate Affairs Commission (CAC). The CAC had refused to register changes in Primetech’s shareholding, citing that section 18(2) only applied to companies registered after the enactment of CAMA 2020. The FHC disagreed, stating that the provision applies to all private companies, regardless of their incorporation date. The court ordered the CAC to accept the changes and update Primetech’s records accordingly.