Academic Records, Administrative Negligence and the University’s Duty of Care: A Critical Analysis of Victor v. Federal University of Technology, Akure (2026) 8 NWLR (Pt. 2044) 33

Abstract

The relationship between universities and students has evolved beyond one governed solely by academic discretion and institutional regulations to one increasingly characterised by enforceable legal obligations. Despite this development, uncertainty has persisted regarding the extent of university liability for negligence arising from the management of academic records, particularly in light of the traditional judicial reluctance to interfere in matters regarded as internal academic affairs. This has created challenges for students who suffer harm as a result of administrative incompetence and record-management failures. This article examines the Supreme Court's decision in Victor v. Federal University of Technology, Akure and analyses its contribution to the evolving jurisprudence on university liability and the duty of care owed to students. Adopting a doctrinal methodology, the study relies on judicial authorities, statutory provisions, and relevant literature in tort, educational, and administrative law. The article finds that the Supreme Court builds on earlier authorities concerning wrongful expulsion and the misrepresentation of academic standing, while strengthening the emerging doctrine of university accountability. The article concludes that the judgment is a landmark development in Nigerian educational law that enhances the protection of student rights and reinforces administrative responsibility within higher education institutions. It recommends the adoption of robust digital record-management systems, effective grievance mechanisms, regular record audits, timely correction procedures, and stronger administrative accountability measures to minimise institutional liability and improve university governance.