In Murmansk State Steamship Line v. Kano Oil Millers Ltd, City Engineering Nigeria Ltd v. Federal Housing Authority and Tulip Nigeria Ltd v. Noleggioe Transport Maritime SAS, the Supreme Court of Nigeria held that the limitation period for enforcing arbitral awards runs from when the cause of action for arbitration arose and not when the awards were made, unless they contain Scott v. Avery clauses. The purpose of this article is to analyse if and to what extent such decisions constitute denial of access to justice against arbitral award creditors.