Dr Williams was a Nigerian national, resident in England. He claimed to have been the victim of a fraud instigated by the Nigerian State Security Services in 1986. He was induced to serve as a guarantor of a bogus transaction for importation of foodstuffs into Nigeria. As part of that transaction, Dr Williams paid over $6.5 million to his English solicitor, Mr Gale, to hold on trust for him. Dr Williams contended that Mr Gale then fraudulently paid out over $6 million to the Central Bank of Nigeria (“the Bank”), and pocketed the rest of the money. In 2010, Dr Williams commenced proceedings against the Bank for both dishonest assistance in a breach of trust and knowing receipt of trust property. The Bank argued that these claims were time barred. In Williams v Central Bank of Nigeria,1 a bare majority of the Supreme Court overturned the decision of the Court of Appeal and held that the limitation period for the claims against the Bank had expired.

The decision focused upon the Limitation Act 1980, s.21, which provides: