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FAILURE TO COMPLY WITH MANDATORY PROVISION OF THE ELECTORAL DECREE WILL WARRANT A STRIKE OUT

Dictum

The case of Chatjok v. Kato and others is relevant. The appellant was the petitioner at the Election Tribunal. In his petition, the petitioner claimed that the 1st and 2nd respondents were not qualified to contest the chairmanship election of Kachia Local Government council, Kaduna State in that the 1st respondent was still a public servant in the employment of Kaduna state Ministry of Works and Transport while the 2nd respondent was an ex-convict. The 2nd respondent was alleged by the appellant to have been convicted of the offence of house-breaking by Area Court I Zonkwua. During the hearing of the petition, a preliminary objection on point of law was raised on behalf of the 1st and 2nd respondents that the appellant’s petition did not comply with the requirements of paragraph 5(1) (c) of schedule 5 to Local Government (Basic constitutional and Transitional provisions) Decree No.36 of 1998 and as such the petition was defective and a nullity. Learned counsel to the appellant conceded to the objection and urged the tribunal to exercise its discretion and strike out the petition without costs. The petition was therefore struck out under the provision of paragraph 5(6) of schedule 5 to the Decree. The Court of Appeal held that where an election petition does not state the scores of the candidates as required under paragraph 5(1) (C) of Decree No.36 of 1998, the Election Tribunal has the discretion to strike out the petition. This is more so when the petitioner cannot amend the petition.

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WHERE CIVIL AND CRIMINAL INGREDIENTS ARE INTERTWINED IN AN ELECTION PETITION

I take the line of thought of the respondents in that it is not enough to allege, non-compliance with the Electoral Act, the Petitioner now Appellant ought to establish by concrete evidence not only the non-compliance but that it was substantial to vitiate the election. Nothing other than that would suffice. Also the petitioner cannot...

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Primarily, the law is well settled that the results declared by INEC (1st Respondent) in an election enjoy a presumption of regularity. In other words, they are prima facie correct. See Section 168(1) of the Evidence Act 2011, recently applied by the Supreme Court in ATUMA V. APC & ORS (2023) LPELR-60352 (SC) where JAURO,...

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RESULT ANNOUNCED BY INEC IS PRESUMED TO BE CORRECT

The law is trite that the results declared by INEC enjoy a presumption of regularity. In other words, they are prima facie correct. The onus is on the petitioner to prove the contrary. See Buhari v. Obasanjo (2005) 13 NWLR (Pt. 941) 1; Awolowo v. Shagari (1979 ) 6 – 9 SC 51; Akinfosile v....

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CANNOT TESTIFY ON POLLING UNIT RESULT IF NOT POLLING UNIT AGENT

This witness is not fit to testify on polling unit result not being a polling unit agent. His testimony on the polling unit is hearsay and shall therefore be discountenanced with … The testimony of PW26 is not reliable in this case. Testimony was to the effect that he was the Party Chairman, and never served as an Agent in any of the polling units or wards but monitored the election. His testimony can at best be described as hearsay and not reliable. We so hold.

— K.M. Akano, J. Edeoga v Mbah (2023) – EPT/EN/GOV/01/2023

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INTERPRETATION OF SECTION 134(2) OF THE CFRN

It is obvious that states of the Federation and the Federal Capital Territory, Abuja were lumped together as a group by Subsection (2) (b) above. What differentiates the constituents of the group is their names and nothing more. One of them is called Federal Capital Territory and the rest called states of the Federation. Subsection...

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IF THE RESULT OF AN ELECTION IS NOT AFFECTED SUBSTANTIALLY, THE PETITION WILL FAIL

If there is evidence that despite all the non-compliance with the Electoral Act, the result of the election was not affected substantially, the petition must fail. In other words, the Election Tribunal, must, as a matter of law, dismiss the petition; and that accords with section 146(1) of the Electoral Act. — Niki Tobi, JSC....

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