Introduction
The COVID-19 pandemic (“the Pandemic”) continues to negatively impact practically every sector in Nigeria and the oil and gas sector has not been spared. In a bid to respond to and address the challenges occasioned by the pandemic, the nation’s foremost oil and gas regulator, the Department of Petroleum Resource (the “DPR”), recently issued certain directives in response to the pandemic. The DPR issued these directives to guide operations in the Industry for the duration of the period that the Pandemic subsists. While the intervention of the DPR to guide operations in the sector in these challenging times is a welcome development, there are some issues arising regarding the legal effectiveness and fairness of the directives.
DPR Directives The key circular which forms the crux of this discussion was issued by the DPR on March 30, 2020 and is entitled “Re: Management of Covid-19 Outbreak – Update 2” (the “DPR Circular”). Its key clauses are as follows: