Nigerian officials would not let them return home for the day, human rights lawyer Emmanuel Ogebe told reporters.
It has raised further questions about the Nigerian government's handling of the situation since nearly 300 girls were kidnapped by militants in north-eastern Chibok town in April 2014. Dozens escaped within hours but 219 remain captive.
In October 21 of the girls were freed by the terrorists following negotiations but officials had refused to let them return home.
Instead they were taken to Abuja for trauma counselling. The girls' requests to go home for Christmas were rejected.
The lawyer says on Christmas Eve the girls were moved closer to their parents and allowed a visit but they were still prevented from leaving or going to Christmas church services.
