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ALL ELECTION PETITIONS LIE AS OF RIGHT TO THE COURT OF APPEAL

Dictum

In the case of Awuse v. Odili (2003) 18 NWLR (pt. 851) 116 at 119, Ejiwunmi JSC supported the lead judgment of I.L. Kutugi JSC quoted the provision of Section 246 (1) (b) (ii) of the 1999 Constitution as amended and said of the Section as follows: “An appeal to the Court of Appeal shall lie as of right from the decision of the Governorship Election Tribunal on any question as to whether any person has been validly elected to the office of Governor”. “Though the word “any” when used as an adjective is defined in Longman Dictionary of the English Language thus: “One or some indiscriminately, whichever is chosen”. It would appear that the word “any” qualifying “question” was deliberately used by the law makers to indicate that an appeal to the Court of Appeal was not limited only to hearing appeals only to whether any person has been validly elected to the office of Governor —– It follows therefore that the provisions of Section 246 (1) allows appeals to lie to Court of Appeal in respect of interlocutory decision of the Governorship Election Tribunals and the other tribunals named in that section of the Constitution”.

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RIGHT OF APPEAL AGAINST INTERLOCUTORY DECISION IN AN ELECTION TRIBUNAL

In the case of Maduako V Onyejiocha (2009) 5 NWLR (pt. 1134) 259 at 280 the Court of Appeal Per Eko JCA held as follows:- “By way of emphasis, I wish to add that the decision of the Supreme Court in Alhaji Atiku Abubakar & Ors V. Alhaji Umaru Musa Yar’Adua & Ors SC 288/2007 of 25th January, 2008 (reported in (2008) 4 NWLR (pt. 1078) 465 Per Niki Tobi JSC, leave no doubt in me that an aggrieved party has right of appeal against an interlocutory decision of an election tribunal. That right is a constitutional right by dint of Section 246 (1) (b) of the 1999 Constitution, which is in Pari materia with Section 233 (2) (3) of the Constitution under which Atiku V. Yar’Adua case was decided”.

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ONLY A PRACTICE WHICH IS CONTRARY TO THE ELECTORAL ACT CAN BE A GROUND TO QUESTION AN ELECTION

As I stated earlier, the electronic transmission of results of an election is not expressly stated anywhere in the Electoral Act, but was only introduced by the 1st Respondent in its Regulations and Guidelines, 2022 and in the INEC Manual for Election Officials, 2023. By Section 134(2) of the Electoral Act, 2022 only an act or omission which is contrary to the Electoral Act, 2022 can be a ground for questioning an election. Thus, complaints relating to non-compliance with provisions of the Regulations and Guidelines or the Manual of Election Officials are not legally cognizable complaints for questioning an election. In interpreting Section 138(2) of the Electoral Act, 2010, which is similar to Section 134(2) of the extant Electoral Act, 2022, the Supreme Court held in NYESOM V PETERSIDE (supra), at page 66 67, paras. F-C, as follows: “The above provisions appear to be quite clear and unambiguous. While the Electoral Commission is duly conferred with powers to issue regulations, guidelines or manuals for the smooth conduct of elections, by Section 138(2) of the Act, so long as an act or omission regarding such regulations or guidelines is not contrary to the provisions of the Act itself, it shall not of itself be a ground for questioning the election.” See also: JEGEDE v INEC (2021) LPELR-55481(SC) at 25 – 26 at paras. A – D.

— H.S. Tsammani, JCA. Peter Obi & Anor. v INEC & Ors. (2023) – CA/PEPC/03/2023

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GROUNDS UPON WHICH AN ELECTION CAN BE QUESTIONED

The Electoral Act, 2022 in an explicit manner, has laid out clearly grounds upon which an election can be questioned in Section 134 thereof. Then there is Section 135 of the said Act which looks like a proviso to Section 134. For a proper appreciation of the intendment of the law, Section 134 and 135 of the Electoral Act must be considered together.

— H.S. Tsammani, JCA. Atiku v PDP (CA/PEPC/05/2023, 6th of September, 2023)

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STATING ADDRESS FOR SERVICE IN AN ELECTION PETITION

Paragraph 4 (4) of the First Schedule to the Electoral Act, 2022 provides as follows: “Paragraph 4 (4); “at the foot of the election petition, there shall also be stated an address of the petitioner for service at which address documents intended for the petitioner may be left and its occupier. We have carefully gone through the petition filed by the Petitioner and we hold that the Petitioner complied with the provision of paragraph 4(4) of the First Schedule to the Electoral Act 2022. This is because the Petitioner copiously stated at the foot of the election petition, his address for service, at which address documents or all Court processes relating to this petition may be served on the Petitioner and the Petitioner equally indicated who the occupier of that address is.

— A. Osadebay, J. APC v INEC & Ors. (EPT/KN/GOV/01/2023, 20th Day of September, 2023)

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PARTY WHO ALLEGES NONCOMPLIANCE HAS THE LEGAL BURDEN

It is trite that a Petitioner who alleges non-compliance with Electoral Act has the legal burden to establish such non-compliance and show how the non-compliance substantially affected the result of the election. See: LADOJA v AJIMOBI (2016) LPELR-40658(SC) at page 29, paras. A E; and SHINKAFI V YARI (2016) LPELR-26050(SC) at pages 19 – 20, para. C.

— H.S. Tsammani, JCA. Peter Obi & Anor. v INEC & Ors. (2023) – CA/PEPC/03/2023

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FORGERY IN INEC FORM MUST BE PROVED BEYOND REASONABLE DOUBTS

False information in INEC Form EC9 which is an affidavit, amounts to lying on oath and is invariably, a crime. Being a crime, its commission must be proven beyond reasonable doubt.

– Aboki JSC. APC v. Obaseki (2021)

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