JURISDICTION

  • EDITOR'S CHOICE
  • May 30, 2022
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  • Comments Off on ‘WHY WE DID NOT DISQUALIFY MAIKYAU’ – ECNBA

‘WHY WE DID NOT DISQUALIFY MAIKYAU’ – ECNBA

The Electoral Committee of the Nigerian Bar Association (ECNBA) has given reasons why it did not disqualify one of the leading presidential candidates, Mr. Yakubu Maikyau SAN from contesting the forthcoming NBA Elections.

In a letter obtained by CITY LAWYER and addressed to embattled Bar aspirant, Mr. Kayode Bello who wrote a petition to the electoral committee seeking the disqualification of the senior lawyer, the ECNBA ruled that it “has no jurisdiction over the complaint, as the subject matter of the petition is pending before the Legal Practitioners Disciplinary Committee (“LPDC”) the competent statutory body for adjudication.”

Dated May 27, 2022 and titled “2022 ELECTIONS OF NATIONAL OFFICERS OF THE NBA – RESOLUTION OF PETITION DATED 2 MAY 2022,” the electoral committee referred to Bello’s petition dated May 2, 2022 “and the response to the petition received from Mr. Yakubu Chonoko Maikyau, SAN, FCIArb (“the Respondent”) dated 12 May 2022.”

In the letter which was copied to Maikyau, the electoral umpire noted that Bello had “requested that the ECNBA disqualifies the Respondent from contesting for the office of the President of the Nigerian Bar Association (NBA).”

The ECNBA stated that it “has considered the petition and the response to same,” adding that aside from the jurisdictional hurdle which it was unable to surmount, “the power of the ECNBA to disqualify a person who wishes to contest for an office shall only crystallizes (sic) after a conviction of crime by a court of competent jurisdiction or if the candidate is found guilty of misconduct or professional impropriety by the LPDC by virtue of Part VII(e) and (f) Second Schedule of the Constitution.”

Sounding the death knell on Bello’s petition, the electoral committee wrote: “Consequently, your petition fails.”

In a petition addressed to the ECNBA Secretary and copied to CITY LAWYER, Bello had urged the ECNBA “to suspend the candidature of Mr. Y. C. Maikyau as the NBA presidential Aspirant, pending the determination of the disciplinary case against him at the Legal Practitioners Privileges Committee (LPPC) for his misconduct.”

Restating his grouse, Bello wrote: “In summary, Mr. Y.C. Maikyau who stands as presidential aspirant for the office of the NBA President in the forthcoming NBA election has lied to the LPPC that I did not show up at the Nigerian Law School for my Bar Final examination and he has used his office and position as the Senior Advocate of Nigeria to frustrate the reconciliation process between the Council of Legal Education and myself (Kayode Bello).

“The fact that Mr. Y.C. Maikyau lied to the LPPC that I did not or refused to show up for my Bar final examination in 2017 is/was tantamount to perverting justice and conspiracy to disobey the order of the Court.”

Maikyau however denied all the allegations in his response to the electoral body.

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  • EDITOR'S CHOICE
  • Mar 15, 2022
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‘INTERIM ORDER AGAINST REMOVAL OF UMAHI CANNOT STAND’

In this article, AKINTAYO BALOGUN, an Abuja based lawyer, asserts that there are several issues plaguing the legality and/or sustainability of the order of an Abakaliki High Court directing that Ebonyi State Governor Dave Umahi and his deputy must not be removed from office

On 10th March 2022, we were greeted with an Order granted Ex-parte (without hearing the other side), by a High Court of Justice sitting in Abakiliki, Ebonyi State (curiously filed just on 9th March 2022), wherein the Honourable Court in Suit No. HAB/13/2022 and vide Motion No: HAB/135M/2022, granted the prayers of the Defendants/Applicant as follows:

An interim order of this Honourable Court for seven days (7 days) (subject to renewal) is hereby granted, in view of its judgment in Suit No. HAB/13/2022 delivered on 28th day of February, 2022, being a judgment in rem, and having precedence over any subsequent contrary judgment. The Applicants hereto, Engr. David Nweze Umahi and Dr. Eric Kelechi Igwe shall accordingly remain and not be removed from office as governor and deputy governor of Ebonyi State respectively

It is easily deducible that this Ex-parte Order was made by the Ebonyi State High Court, following the judgment of the Federal High Court sitting in Abuja which had on the 8th Of March, 2022, declared the seat of the Governor, Deputy Governor, and 17 members of the House of Assembly vacant, following their defection to the All progressive Congress from the Peoples Democratic Party, a party under which they had been sponsored and elected to fill the various political seats in Ebonyi State. The Governor had informed a crowd the day after the judgment was delivered that he had hired a team of 17 SANs to prosecute an Appeal against the Judgement of the Federal High Court. However, while the said Appeal is believed to have been commenced, the same Engr. David Nweze Umahi and Dr. Eric Kelechi Igwe, addressed as Defendants/Applicants went gone back to the Ebonyi State High Court which had earlier on delivered a divergent Judgement to that of the Federal High Court, to seek and obtain the above-quoted reliefs, vide an Ex-parte application. We note that it is the same Suit Number that is contained in the heading of the instant Ex-parte Order that is also contained in the Judgement that had been earlier delivered on the 28th Day of February 2022 as stated in the Order. This means that it is one and the same suit where judgment had been earlier delivered that this Ex-parte Order is also being made and granted.

Several issues as to the legality and/or sustainability of the said Order have reason among pundits. We shall discuss these issues under the following subheads/issues for determination.

  1. Whether or not the Court ordinarily has not become functus officio upon the delivery of the judgment.
  2. Whether the Order made by the court does not amount to sitting on Appeal on its own judgment.
  3. Whether the Order made does not amount to a stay of execution of the Judgement of the Federal High Court sitting in Abuja
  4. Whether the declaration “An interim order of this Honourable Court for seven days (7 days) (subject to renewal ) is hereby granted, in view of its judgment in Suit No. HAB/13/2022 delivered on 28th day of February 2022, being a judgment in rem, and having precedence over any subsequent contrary judgment” does not amount to an attempt to oust the jurisdiction of any other court including a higher court.
  1. Whether the Court ordinarily has not become functus officio upon the delivery of the judgment.

It is a notorious fact that once a judgment is delivered, the Court becomes functus officio (that is, it has no power whatsoever to say or do anything in respect of the decision already made). They ordinarily have no powers to do or say anything in respect of the case again except to entertain certain applications as applicable under the rules of the honourable court.

Functus Officio was defined in the case of Buhari Vs INEC & Ors (2008) LPELR – 814 SC, where the Supreme Court held that a task performed; having fulfilled the function, discharged the office, or accomplished the purpose, and therefore of no further or authority. In the case of Chief Ozo Nwankwo Alor & Anor. Vs Christopher Ngene & Ors (2007) LPELR – 431 (SC); (2007) 17 NWLR (Pt.1062) 163, the Supreme Court said of functus officio: “A final order envisages that it is a permanent order made by the Court and the parties in respect of whom or against whom the order is made, cannot go back to the same Court to challenge or change that order. That Court, by virtue of the order, is functus officio and the only option open to the parties is by way of appeal against the order. This means that the rights of the parties have been determined to finality, and they cannot go back to the same Court on those rights.

It is an undebatable fact that the State High Court in Ebonyi which had earlier delivered a judgment in the same suit with Suit No HAB/13/2022, constituting the same parties, have become functus Officio, immediately upon the delivery of its judgment on the 28th of February 2022. The court has no business whatsoever in respect of the suit except to conduct a garnishee proceeding in respect of the monetary aspect of the judgment or to hear an application for stay of execution of the judgment. It is respectfully submitted that whatever statement, Order, or instruction, given by the same court, which are not contained in the type as envisaged under the rules of the honourable court are to all intents and purposes invalid and the court should immediately set it aside when it has the opportunity to do so. In this instant case, the final judgment was delivered on 28th February 2022. The court had no business whatsoever hearing any application that seeks to reinforce its earlier judgment. The judgment is already in force. What then necessitated this fresh order from a court when nothing has arisen within its ranks to change its judgment is still a thing of concern? As a matter of fact, the Ex-parte Order which seeks to reinforce the judgment the Ebonyi High court had earlier delivered, has no place in law. It is strange and unknown to the practice of law. 

  1. Whether the Order made by the court does not amount to sitting on Appeal on its own judgement.

The decision of the Ebonyi State High Court to make an Order reinforcing its earlier decision or making any pronouncement whatsoever in respect of an already decided case is the same as a court sitting on appeal over its own decision, whether in making a contrary statement or in reinforcing its judgment. The new Order made by the court will now open a flood gate of applications and submissions and room for a fresh argument on an already decided action. This ought not to be. The Court of Appeal held in thus case of EDO STATE HOUSE OF ASSEMBLY & ORS v. AGBEBAKU CITATION: (2018) LPELR-45056(CA)

“The general position of the law is that a Court cannot set aside its decision or the decision of a Court of coordinate jurisdiction made on the merits. However the Court has inherent power to set aside its decision when same are later found to be a nullity, obtained by fraud or mistakenly given under the impression of parties’ consent. That power does not extend to a Court sitting on appeal over its own decisions.

The Order of the Ebonyi State High Court under review does not seek to nullify its judgment, nor does the issue of fraud or mistaken impression arise. There is no basis for the said Order. The Court most respectfully has taken a decision to sit on Appeal over its own decision. What business has a court that has delivered judgment in favour of a particular party have in delivering another Ex-parte Order to reinforce its judgment?

  1. Whether the Order made does not amount to a stay of execution of the Judgement of the Federal High Court sitting in Abuja

As earlier stated, it is easily deducible that this Ex-parte Order was given since there is a divergent judgment coming from the Federal High Court, sitting in Abuja. Now the Court in Abakiliki held thus:

“The Applicants hereto, Engr. David Nweze Umahi and Dr. Eric Kelechi Igwe shall accordingly remain and not be removed from office as governor and deputy governor of Ebonyi State respectively”

This Order is a direct contrast and opposite to the Order of the Federal High Court in Abuja which had held that the as governor and deputy governor of Ebonyi State, having defected from the party on which platform they won the election, are deemed to have resigned their offices. The court in Abuja further ordered the Independent National Electoral Commission (INEC) to accept from PDP names of its members to replace the governor and deputy governor of Ebonyi State to serve out the remaining part of their tenure or, alternative, conduct a fresh election to replace the governor and deputy governor of Ebonyi State. Until there is an Order for a stay of execution of this judgment, issued by the very court that delivered the judgment or by a higher court, this judgment remains the law that ought to be obeyed. In the practice of law in Nigeria, an application to stay the execution of a judgment, is usually made to the same court that had earlier delivered the judgment. This is why the application is made simply by filing a motion and not an Originating process. Another court with coordinate jurisdiction, cannot order parties to directly disobey a judgment of a court, and worst still after judgment had been delivered on both sides.  See Order 31 Rule of the Federal High Court Civil procedure Rules 2019. See also Order 54 Rule 1 of the Ebonyi State High Court Civil Procedure Rules 2008.

A State High Court, making an order that technically stays the execution of the judgment of a Federal High Court is a strange practice, unknown to law and unpracticable. 

  1. Whether the declaration “An interim order of this Honourable Court for seven days (7 days) (subject to renewal ) is hereby granted, in view of its judgment in Suit No. HAB/13/2022 delivered on 28th day of February, 2022, being a judgment in rem, and having precedence over any subsequent contrary judgment” does not amount to an attempt to oust the jurisdiction of any other court including a higher court.

We respectfully submit that simply stating that the Ex-parte order of this Ebonyi State High Court has precedence over any subsequent contrary judgment” without specifically stating which court it has precedence over is an attempt by the court to oust the jurisdiction of any other court, INCLUDING a superior court. Ordinarily, the only court that can set aside this instant order, is the Court that granted it based on certain grounds or a higher court. However, stating plainly that this Ex-parte Order of the Ebonyi State High Court has precedence over any subsequent contrary judgment automatically means that whoever gives a contrary judgment, ruling or opinion, whether a lower court, court of coordinate jurisdiction or a higher court, same is invalid and should be discountenanced. This we most respectfully submit is an enormous gaffe from the State High Court. How do you use such an Order to oust any other subsequent Order or judgment, without specifying or limiting who the subsequent Order is coming from? What makes the judgment have precedence over any subsequent contrary judgment? The use of the phrase “any other subsequent Order” is too wide, too lose, and dangerous.

Conclusion

We must state with the utmost respect to the Counsel and to the court that the processes filed before the Ebonyi State High Court that had earlier delivered a judgment, amounts to an abuse of court process and same must be disconnected from the practice of law in Nigeria. The Court cannot afford to continually receive, produce or argue documents that are unknown to the practice of law in Nigeria.

The courts must do all that is necessary to protect its integrity and appellation with jealousy. The courts cannot allow themselves to be tossed around like a game of chess or allow themselves to be controlled by the winds of time. It is popularly said that whenever a matter is brought before a court of competent jurisdiction for determination, it is not the parties that are on trial but the judiciary. The judiciary must always come out with its head up high. Additionally, legal practitioners should endeavour to advise their clients appropriately and not to allow the desperation of litigants and especially politicians to determine their line and style of practice. Within a few years, the politicians you see today will be gone or would have lost political relevance, but the legal profession spans an entire lifetime. The few pleasures and earnings of the moment should not be allowed to put an indelible stain on the profession. I hope the judiciary can retrace its steps on this issue.

Akintayo Balogun Esq., LL.B (Hons), BL, LL.M, is a legal practitioner based in Abuja, FCT. akinson6@gmail.com.

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  • EDITOR'S CHOICE
  • Mar 09, 2022
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  • Comments Off on FHC LACKS JURISDICTION TO REMOVE UMAHI, SAYS OKUTEPA

FHC LACKS JURISDICTION TO REMOVE UMAHI, SAYS OKUTEPA

In this opinion article which he posted today on the CITY LAWYER WhatsApp platform, fiery Bar Leader and Election Petition lawyer, MR. JIBRIN OKUTEPA SAN argues that the Federal High Court lacks the constitutional power to unseat Ebonyi State Governor Dave Umahi

Today the a Federal High Court sitting in Abuja had ordered the Governor Ebonyi State Chief Dave Umahi and his Deputy Chief Eric Kelechi Igwe to vacate their offices on account of their defections from PDP to APC. The plaintiff in the matter was PDP. The learned trial judge based his judgment, from what I gathered from the news making rounds that the votes that brought the Governor and his Deputy to power were votes of PDP and not personal votes of the duo, and therefore the duo were not capable of transferring the votes to APC. Before I make further comments let me be clear. I am not a member of any of the Nigerian Political parties and I have no political affinity with any. My comments are purely to interrogate the constitutional validity of the decision and the jurisdiction of the court to make the orders and declarations it made.

This judgment on the superficial level seems very attractive and well intentioned to instill political sanity in our otherwise reckless political terrains. But beyond this and also scoring political debates, is there jurisdiction in the Federal High Court to make the orders it made, in the light of, and upon a dispassionate construction and interpretation of Nigerian Constitution 1999 as amended. I do not think so. I will therefore endeavor to draw our attention to the procedures for removal of governor and his deputy and the authority or institution that has jurisdiction to do so as provided in our constitution.

There is no dispute that the Nigerian Constitution provides that there shall be a governor and a deputy governor for each states of the Federation. See section 186 of the 1999 constitution. There is equally no doubt that for purposes of election to the office of the governor and deputy governor they do so on the platforms of political parties. This very much is conceded. But after elections, declaration and swearing in of the Governor and Deputy Governor, the Constitution has set out how they duo can be removed from office, who has the powers to remove them and which court can decide if their term of office has come to an end.

Section 188 of the 1999 Constitution deals with who can remove a Governor or Deputy Governor from office. It is the House of Assembly after following the due processes set out in the constitution. No matter the political iniquities committed by the Governor and his Deputy there is no jurisdiction in the Federal High Court to remove them from office or ordered their removal from office.

There is no power and jurisdiction in the Federal High Court to determine and declare that by constitutional misconduct of defecting to another political party other that the party upon which the Governor and the Deputy Governor were elected their seats had become vacant and to order the conduct of election to their offices. Jurisdiction to made post election declarations and orders as made by the Federal High Court is not in our constitution. Section 251 of the 1999 constitution as amended in subsection 4 limited the jurisdiction of Federal High Court to determine whether the seat of a member of House of Representatives has become vacant or that of members of senate.

It appears that the draftsman of our constitution did not contemplate that when a governor defects or his deputy then he or she must vacate the office. If that were to be the case, the constitution would have said so. See section 68(1) (g) of the 1999 Constitution. When there is a dispute whether the term of office of a member of House of Assembly, Governor or Deputy Governor has become vacant or that they have ceased to hold their respective offices by whatever allegations, only the state High Court has jurisdiction to entertain such complaints. See section 272 (3) of the Constitution.

Clearly from the reading of the entire Nigerian Constitution, it is submitted with respect that while one must celebrate the jurisprudential logic and reasoning in the judgment under review, which is thought provoking and accord with moral demands to see that our democracy is well nurtured and follow best international practices and standards, such logic and reasoning cannot be situated within any of the well known cannons of interpretations.

The Supreme Court set the cardinal principles governing the interpretation of constitutional provisions as enunciated in the case of Rabiu vs The State (1980) 8-11 SC 130, that Courts should whenever possible and in the interest of justice lean to the broader interpretation unless there is something in the text or the rest of the constitution indicating that the narrower interpretation will best carry out the objects and purposes of the Constitution. This very much his lordship Adekeye, JSC as he then was said in the case of the Attorney General of Nasarawa State vs. Attorney General Of Plateau State(2012) LPELR-9730(SC) at 62, paras. B-C) when his lordship said Constitution must be read as a whole to determine the object of particular provisions.

This is what the Supreme Court said: It is a settled principle of interpretation that whenever a Court is faced with the interpretation of a Constitutional provision, the Constitution must be read as a whole in determining the object of the particular provision. This requirement places a duty on the Court to interpret related Sections of the Constitution together. See Nafiu Rabiu v. The State (1980) 8 – 11 SC 130 at 148; (1980) 8 – 11 SC (Reprint) 85 and Bronik Motors & Anor v. Wema Bank Ltd (Supra). In Hon. Justice Raliat Elelu-Habeeb (Chief Judge of Kwara State) v. AG Federation & 2 Ors (2012) 2 SC (Pt.1) 145, this Court stated thus:- “The duty of the Court when interpreting a provision of the Constitution is to read and construe together all provisions of the Constitution unless there is a very clear reason that a particular provision of the Constitution should not be read together. It is germane to bear it in mind the objective of the Constitution in enacting the provisions contained therein. A Section must be read against the background of other Sections of the Constitution to achieve a harmonious whole. This principle of whole statute construction is important and indispensable in the construction of the Constitution so as to give effect to it.

Guided by the above decisions and other decisions of our superior courts of record, it is my submission that the decision of the Federal High Court in this case suffers seriously from jurisdictional fatalities and may not stand when challenged. The question of independent candidate does not arise in this case.

Clearly the constitution has set out how a Governor and Deputy can be removed from office after they had assumed duties. The law is that where the law has set out how a thing is to be done and in this case the Nigerian Constitution has set out how to remove Governor and Deputy only that procedures must be followed. This much the Supreme Court has said per Garba JSC. Hear Garba JSC.

“In IAL 361 Inc. v. Mobil Nig. Plc (supra), the law was restated at page 2 that:- “And the law is sacrosanct that where there is a non-compliance with a stipulated precondition for setting a legal process in motion, any suit instituted in contravention of the pre-condition provision of the relevant law, is incompetent and a Court of law, is for that reason, lacking in jurisdiction/power to entertain it.” The cases of Western Steel Works Ltd. v. Iron & Steel Workers Union of Nigeria (1986) 3 NWLR (pt. 30) 617, Ajanaktl v. C.O.P. (1979) 3 & 4 SC, 28, and Gambari v. Gambari (1990) 5 NWLR (pt. 152) 572 are cited and relied on for that position of the law. This Court, per Musdapher, JSC, (former CJN) in the case of Owoseni v. Faloye (2005) 14 N WLR (pt. 496) 719 at 740 had stated in the lead judgment, that:- “Now, in my view, the Court of Appeal is perfectly right in the statement of the law to the effect that where a statute prescribes a legal line of action for the determination of an issue, be it an administrative matter, Chieftaincy matter, or a matter for taxation, before going to Court.” Oguntade, JSC, in his concurrent decision emphasized at page 757, that: “It is important to stress that laws which prescribed that some procedural steps to be taken to resolve a dispute before embarking on actual litigation are not and cannot be treated or categorized as ousting of the jurisdiction of the Court. Indeed, if such laws do so, they would be in conflict with the provisions of the Constitution. Such laws, only afford the body to which such disputes must be referred to in the first instance an opportunity to resolve the dispute if it can before recourse to the Court. In other words, they serve the purpose of preventing actual litigation in Court where it is possible or desirable to resolve the dispute.” Then in Ogologo v. Uche (2005) 14 NWLR (pt. 945) 226 at 245, Belgore JSC (former CJN) restated, emphatically, that:- “Where a law has given exclusive power to a body to decide, the Court cannot come in before that body has exercised that power. Court can come in only where there is exhaustion of all remedies before that body and Court will then be able to decide whether that power had been exercised lawfully.” See also Okomalu v. Akinbode (2006) 9 NWLR (pt. 985) 338 (SC). From these authorities, it is clearly incontestable, legally, that where the provisions of a statute or law prescribe some internal mechanisms by which, remedies or reliefs for some grievance/s could be sought and to be followed or complied with by a party before instituting a legal action in a Court of law over the same grievance/s, the party has no discretion or option, but to exhaust all the remedies provided for by the statute or law first, before going to Court as the Court’s jurisdiction in such circumstance, will be put in abeyance pending the completion of the internal mechanisms for the remedies. I refer to ORAKUL RESOURCES LIMITED & ANOR V. NIGERIAN COMMUNICATIONS COMMISSION & ORS (2022) LPELR-56602(SC) Per GARBA, JSC at PP. 26-29, paras. D-A

Clearly the procedures adopted by the PDP in seeking the removal appears with respect outside of the contemplation of our constitution.

But let us wait and see what the other higher courts in the land will say, but until then it does not lie in the mouth of the Governor or his Deputy to say they will not obey the orders. Their remedies are not in acting contemptuously but in ventilating their dissatisfactions by due process.

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CITY LAWYER cannot guarantee the completeness, accuracy of the data and content of the website, nor that it is up to date at all times. CITY LAWYER accepts no liability for any direct or indirect damage of any kind whatsoever that arises from, or is in any way related to the use of the website or its accessibility or lack thereof. The assertions and opinions expressed in articles, announcements and/or news on this website reflect the views of the author(s) and do not (necessarily) reflect the views of the webmaster, the internet provider or CITY LAWYER. CITY LAWYER can in no way whatsoever be held responsible for the content of such views nor can it be held liable for any direct or indirect damage that may arise from such views. CITY LAWYER neither guarantees nor supports any product or service mentioned on this website, nor does it warrant any assertions made by the manufacturers or promoters of such products or services. Users of this website are always recommended to obtain independent information and/or to perform independent research before using the information acquired via this website.