HON. JUSTICE ABIMBOLA OSARUGUE OBASEKI-ADEJUMO, (J.C.A) had this to say in the case of NGANJIWA v. FEDERAL REPUBLIC OF NIGERIA (2017) LPELR-43391(CA).

"It must be expressly stated that if a judicial officer commits theft, fraud, murder or manslaughter, arson and the likes,..... WHICH ARE CRIMES COMMITTED OUTSIDE THE SCOPE OF THE PERFORMANCE OF HIS OFFICIAL FUNCTIONS, he may be arrested, interrogated and prosecuted accordingly by the State DIRECTLY without recourse to the NJC.