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Monday, 19 June 2017

CIVIL LITIGATION: PRINCIPLES AND DRAFTING IN ELECTION PETITION


JURISDICTION AND COMPOSITION
1.      GOVERNORSHIP ELECTION TRIBUNAL (SECTION 285(2) CFRN)
Composition
a)      The Chairman------ Judge of the High Court
b)      Two other Members appointed from the Judge of the High Court, kadis of sharia court… other members of the Judiciary not below the rank of Chief Magistrate
QUORUM: The Chairman and at Least One Member.

2.      NATIONAL AND STATE HOUSES OF ASSEMBLY ELECTION TRIBUNAL (SECTION 285(1) CFRN, SECTION 133(2)(b) Electoral Act.
Composition
c)      The Chairman------ Judge of the High Court
d)      Two other Members appointed from the Judge of the High Court, kadis of sharia court… other members of the Judiciary not below the rank of Chief Magistrate
QUORUM: The Chairman and at Least One Member.

3.      COURT OF APPEAL ( SECTION 239 CRFN 1999)
a)      Whether any person has been validly elected into the office of the President or Vice-President
b)      Whether the term of office of the President or Vice-President has ceases
c)      Whether the office has become vacant.
QUORUM: Three Justices of the Court of Appeal

TAKE NOTE: An election petition must be presented at the registry of the appropriate court or tribunal. Presenting the petition in a wrong court or tribunal is a fundamental error which cannot be rectified. OGBOLUMANI V OKOBI

Thus, a petition filed at a wrong tribunal shall be struck out, and where it is not subsequently re-filled before the appropriate tribunal within the 21 days period, it becomes statute barred.

TIMELINES AND EFFECTS
1.      
    The Election Tribunal is constituted not later than 14 days before the day of the election AND its Registries must be opened for business seven days (7) before the election
STATUTE: SECTION 133(3) a & b ELECTORAL ACT.

2.      Time to File Election Petition? (SECTION 285(5)CRFN 1999)
(PETITIONER).Must be filed within 21 days from the date of the declaration of the result of the election

EFFECTS;
a)      There is no extension of time within which to file the Petition
b)      Failure to file the petition within 21 days, the petitioner loses his right to relief and he is statute barred. KAMBA V BAWA, MOGHALU V NGIGE
(RESPONDENT), he is to file reply within 14 days of the service of the petition.
PETITIONER’S REPLY: He is to file reply in answer to new issues raised within 5 days from the day he received the respondent’s reply
3.  
       PRE-HEARING NOTICE (Paragraph 18 of the First Schedule of the E.A)
Time to apply: Within 7 days of filling and service of the last pleading; either Petitioner’s reply or Respondent’s reply.

EFFECTS;
a)      He can bring a motion for extension of time if he fails to apply within 7 days; provided it is within the 180 days for the hearing of the case

Time for Pre-hearing: It must be completed within 14 days of its commencement.
4
.      Time to File final Written Address after close of Hearing of Petition
a)      The last person to call evidence will file within 10days after the close of evidence
b)      The other party shall file his own written address within 7 days of receipt of the first party written address
c)      The first party who files will reply on point of law within 5 days after the service of the other party’s address.

N.B: What determines the First party is the rule of the last shall be the first, so if the Petitioner concludes his evidence and the respondent do not call any evidence then the Petitioner will be first, but if the respondent calls evidence then he respondent shall be the First.

5.      Time to Deliver Judgment? (SECTION 285(6) CFRN 1999)
Must be delivered in writing within 180 days from the date of filing the petition

EFFECTS:
a)      The time cannot be extended or enlarged it is like Mount Zion which cannot be moved
b)      The tribunal no longer has jurisdiction to hear the petition and this applies to re-hearings. ABUBAKAR V GONI
6.    
       APPEAL
a.       Time to File Appeal:  within 21 days from the date of the decision of the Tribunal. SECTION 143 E.A
b.      Time to Dispose the Appeal: Within 60 days from the date of the delivery of the Judgment of the Tribunal or of the Court of Appeal.
c.       Time to Compile Records of Proceedings: 10 days from the date of the Notice of Appeal
d.      Briefs of Argument;
i.                    Appellant: Within 10 days from the date of Service of the Records of Proceedings
ii.                  Respondent: Within 5 days from the date of service of the Appellant’s Brief
iii.                Reply: Within 3 days of Service of Respondent’s brief.
(CODE: 10-5-3…..)
            EFFECTS: The Time specified cannot be extended. MARWA V NYAKO
7. 
     Substitution of Parties
a)      A party can only validly withdraw a candidate if done not less than 45 days before the election

COST AND EFFECTS

FILING FEES: This is must be paid and the Petitioner should receive the Receipt of Payment of the filing fees from the Secretary/ Registrar.

EFFECTS: If you fail to pay the filing fees, it renders the petition invalid and it will be struck out unless the tribunal orders otherwise. EZEANI V OKOSI

N.B: If the petitioner pays part payment it is not fatal especially where the error is that of the Secretary of the tribunal. In such a case there would be Stay of Proceedings pending the full payment of the filing fees.

SECURITY FOR COSTS: At the time of presenting the petition, the petitioner must deposit #200,000 with the tribunal.

EFFECTS: If he fails to pay it is not fatal but the proceeding will be stayed until the security for cost is extracted from the petitioner. NWOBODO V ONOH, PARAGRAPH 2(4)

N.B: There shall be a further deposit of #200, 000 to make up for the costs of service of notices, registered postings, and all other expenditures which may be occasioned by the petitioner

PARTIES TO AN ELECTION PETITION
1.      PETITIONER: This is the person that presents or files the petition. We have 2 categories of persons that can file an election petition; (SECTION 137(1)]

      a)      A Candidate in an Election
     b)      A political Party which participated in the election.

N.B: A person who was validly nominated and cleared but is unlawfully excluded by INEC can also file an election petition either alone or with his political party. PPA V SARAKI

2. RESPONDENT: [SECTION 137(2) ELECTORAL ACT;
      a)      The person whose election is complained of (The person who won the election
      b)      The political party whose candidate won the election
      c)      INEC.

GROUNDS OF PETITION
1)      That a person whose election is questioned was, at the time of the election, not qualified to contest the election;

2)      That the election was invalid by reason of corrupt practices or non-compliance with the provisions of Electoral Act

3)      That the respondent was not duly elected by majority of lawful votes cast at the election; or

4)      That the petitioner or its candidate was validly nominated but was unlawfully excluded from the election.

STATUTE: SECTION 138(1) (A) – (D) ELECTORAL ACT 2010 AS AMENDED
CASE: OBI v. ENWEREM.

EXPLANATION ON THE GROUNDS

ALMIGHTY RULE: Grounds that are not within the provisions of the act would lead to dismissal of the Petition. DOUKPOLAGHA V GEORGE [1992]4NWLR (PT.236) 444

FIRST GROUND: That a person whose election is questioned was, at the time of the election, not qualified to contest the election

The provision of 1999 CFRN provides for grounds of disqualification. These grounds are basically the same except for variation in age qualification for persons contesting election into various offices.
a)      Presidential Election: Section 137---------------------- Age: 40years
b)      Governorship Election: Section 182--------------------Age: 35 Years
c)      National Assembly: Section 66-------------------------Age: 35 Years
d)      House of Assembly: Section 107------------------------Age: 30 Years

The grounds for disqualification are;
        i.            He is not a citizen of Nigeria
N.B: The president and Governor must be citizen of Nigeria by Birth.
      ii.            
           He has been elected into such office at any two previous occasions (applicable to President and Governor only)
    iii.           
           He is adjudged a lunatic or a person of unsound mind
    iv.            
           He is an undischarged bankrupt
      v.           
           He is under a death sentence or a sentence of imprisonment for an offence involving dishonesty or fraud
    vi.           
                      Within a period of less than ten (10) years prior to the election, he has been convicted and sentenced for an offence involving dishonesty or he has been found guilty of a contravention of the Code of Conduct
   vii.       
                     He is employed by the public service of the Federation or of a State and he does not resign, withdraw, or retire from such employment thirty (30) days before the date of the election.
In MBUKURTA v. ABBO where it was held that a person on leave of absence was still in the employ of his employer for the period of leave had not met the requirements of resignation, withdrawal or retirement
 viii.  
                        He is a member of a Secret Society and

    ix.            He has presented a forged certificate to the Independent National Electoral Commission.

      x.            He must be a member of a Political party and
    xi.            He is sponsored by that Political Party

  xii.            He should be educated up to at least School Certificate level or its equivalent.

N.B: The position of the law is that an indictment is not sufficient to deny a citizen eligibility to contest unless and until he has been prosecuted and found guilty by a competent court of law. AMAECHI  V INEC

COMMENCEMENT AND FRONTLOADING
An Election Petition is commenced by PETITION

The PETITION must be accompanied with the following documents;
a)      A list of the witnesses that the petitioner intends to call in proof of the petition
b)      Written statements on oath of the witnesses; and
c)      Copies or list of every document to be relied on at the hearing of the petition.
Paragraph 4(5) of the First schedule to the Electoral Act as amended

EFFECTS: Failure to comply with this frontloading requirement is that the petition would not be accepted for filing by the Registrar. ACN V LAMIDO, Paragraph 4(6) of the First schedule to the Electoral Act as amended

THE CONTENT OF THE PETITION
1.      Heading of the appropriate tribunal or court
2.      Petition Number
3.      Names of Parties interested in the Election Petition
4.      The right of the Petitioner to bring or present the petition
5.      The holding of the election, the result of the election, the scores of the candidates and the person returned as winner
6.      Grounds for the petition
7.      Facts in support of the grounds of the Petition
8.      Prayers and reliefs sought
9.      Address for service and occupier
10.  Signature of the petition or his solicitor, if any, named at the foot of the election
Para. 4(1) First schedule to Electoral Act

N.B: By Paragraph 4(7) of the First schedule to the Electoral Act as amended, failure to comply with the above requirements or any of them renders the petition defective and it may be struck out.

THE DRAFT OF PETITION
IN THE NATIONAL ASSEMBLY ELECTION PETITION TRIBUNAL OF DELTA STATE OF NIGERIA
HOLDEN AT ASABA
PETITION NO:.......  
ELECTION TO THE NATIONAL ASSEMBLY FOR ASABA NORTH SENATORIAL DISTRICT HELD ON SATURDAY THE 4TH OF APRIL 2014                                                                              
BETWEEN
1.      DR. VINCENT BROWN  ............................................................1ST PETITIONER
2.      NATIONAL NIGERIAN PARTY……………………………….
AND
1. CHIEF BEN OKAGBUE………………………………….
2. UNITY CONGRESS PARTY……………………………..                    
3. INDEPENDENT NATIONAL ELECTORAL COMMISSION ......... RESPONDENT       
THE PETITION OF DR.VINCENT OF NO 2 UCHE ROAD, ASABA NORTH, DELTA STATE, WHOSE NAMES IS SUBSCRIBED
1.      Your Petitioner, Dr. Vincent Brown of No 2 Uche Road, Asaba. Delta State, was a candidate in the senatorial election of Asaba North Federal Constituency of Delta State held on 4TH of April, 2014
2.      The Petitioner contested the said election under the platform of National Nigerian Party.
3.      The 1st Respondent who contested the election under the Unity Congress Party was declared winner of the election by the 3rd Respondent on the 5th of April 2014 despite the irregularities and corrupt practices in the conduct of the election.
4.      The result of the election as announced by the 3rd Respondent are as follows;
RESULT OF THE ELECTION
CANDIDATE                                                                                   NUMBER OF VOTES
Dr. Vincent Brown (Petitioner)      
5,419
Chief Ben Okagbue (1st Respondent)   
8,341
Invalid Votes 
200

TOTAL VOTES CAST                                              13960
D2ATE OF THE ELECTION:  4th OF APRIL 2014
NAME OF THE RETURNING OFFICER: PROFESSOR DERIN MUSA
GROUNDS ON WHICH THE PETITION IS BROUGHT
1. The 1st Respondent who was declared winner of the election by the 3rd Respondent was not as at the time of the election was not qualified to contest same.
2. That the election was invalid by reason of corrupt practices and non-compliance with the provision of the Electoral Act 2010
FACTS IN SUPPORT OF THE PETITION
1)      That the 1st Respondent is an ex-convict having been convicted and sentenced to three years imprisonment for forgery sometimes in November, 2009.
2)      At about the hour of 11am there were incidents of over voting perpetrated by the agents of the 1st and 2nd Respondents at Asaba Ward B & C and at their instance or to their knowledge and these acts of over voting were brought to the attention of the 3rd  Respondent
3)      There was incidents of ballot box snatching at Asaba Ward A, Unit 1 by 2 Unity Congress Party politician namely Kofo Masa and Paul Zahara for the 1st and 2nd Respondent
4)      There was unlawful campaign by agents of the 1st Respondent at the venue of the election

PRAYERS
WHEREOF the Petitioner prays as follows
i)                    A DECLARATION that the 1st Respondent was not qualified to contest the Asaba North Federal Constituency legislative election of Delta State held on 4TH of April 2014
ii)                  AN ORDER DECLARING that the return of the 1st Respondent as the member of the Senate of the National Assembly by the 3rd Respondent in the election held on 4th April 2014 is null and void
iii)                AN ORDER FOR A RE-RUN for the Senatorial District of Asaba North Federal Constituency, Delta State on a date to be fixed by the 3rd Respondent.

DATED this 10th day of April, 2014                                                    
_____________________
Petitioner’s Counsel
S.O DERIN Esq,
Group4hub & CO,
5, Uche Road, Asaba,
Delta State.                                                                                                     
ADDRESS FOR SERVICE:
Petitioner
No 2 Uche Road, Asaba. Delta State
OCCUPIER
DR. VINCENT BROWN
1. 1st Respondent
89, Ebiti Road, Asaba.

OCCUPIER
Chief Ben Okagbue

2. 2nd Respondent
UNITY CONGRESS PARTY
House 10, Salma Estate, Asaba.

OCCUPIER
CHIEF UGO VALENTINE

3. 3rd Respondent
Independent National Commission
26 Independent Way, Asaba.

OCCUPIER
INDEPENDENT NATIONAL ELECTORAL COMMISSION


                                    --------------------------------------------------
                                                Dr. Vincent Brown

            Signed before me this------------ day Of -----------------20-------------
                                                -------------------------------------
                                                            Secretary

PRE-HEARING SESSION AND SCHEDULING

 THE PURPOSE: At this stage the Tribunal addresses the following matters;

a)      Dispose of all matters which can be dealt with on Interlocutory Application
b)      Give such directions as to the future course of the petition
c)      Fixing clear dates for hearing of the Petition
d)      Hearing and determination of objections on Point of law
e)      Formulation and settlement of issues
f)       Amendment and further and better Particulars…..etc

THE PROCEDURE;

RULE 1
Within 7 days after the filing and service of petitioner’s reply or respondent’s reply, the petitioner applies for the pre-hearing notice in Form TF008. The application is by Motion on Notice, Affidavit and Written Address. Note that if the petitioner fails to apply within the prescribed seven (7) days, he can bring a motion for extension of time within which to apply for the pre-hearing notice. Provided it is within the 180days for the hearing of the case.
      Then the Tribunal issues the Pre-Hearing notice accompanied by a Pre-hearing Information Sheet in FORM TF009.

RULE 2
Where the Petitioner fails to apply for the Pre-Hearing Notice, the Respondent can either;
a)      Bring the Application OR
b)      Apply for an Order dismissing the Petition via Motion which must be served on the Petitioner. PARA 18(3) FIRST SCHEDULE

RULE 3
Where both parties fail to apply for Pre-Hearing Notice, the Tribunal shall dismiss the Petition as an ABANDONED PETITION. 

EFFECT: The order of dismissal is final and the tribunal or court shall be functus officio. SALVADOR V INEC

ATTENDANCE AT THE PRE-HEARING SESSION
Attendance of parties at the Pre-Hearing Session is Mandatory;
a)      If the Petitioner fails to attend, the Petition will be dismissed…PARA 18(11)
b)      If the Respondent fails to attend Judgment will be entered against him…PARA 18(11)

N.B: Such Judgment can be set aside upon an application made by the Respondent within 7 days of the Judgment with order as to cost of #20,000. The application to set aside must be accompanied by;
a) An undertaking to participate effectively in the Pre-Hearing Session signed jointly by the respondent and his Legal Practitioner

N.B: This does not apply to dismissal. ANPP V REC AKWA IBOM

TIME FOR COMPLETION OF PRE-HEARING SESSION
The pre-hearing session must be completed within fourteen (14) days of its commencement. See paragraph 18.

HEARING OF THE PETITION

MAIN RULE:
Election Petition is to be heard in an open court or tribunal. The notice of the time and place of the hearing is to be given by the Secretary or registrar to the Parties at least five (5) days to day fixed for hearing----- PARA 20(1)

RULE 1
On the date fixed if None of the Parties are present, the Tribunal shall strike out the petition and no application can be brought to re-list except good cause is shown. PARA 46(1)

RULE 2
On the date fixed, if only the Petitioner appears and is present, the petitioner will be asked to prove his case, if burden of proof lies on him and Judgment will be given. PARA 46(2)

RULE 3
On the date fixed , if only respondent appears and present, the respondent shall be entitled to final judgment of dismissing the petition. PARA 46(3)

STANDARD OF PROOF IN ELECTION PETITION
The General Standard of Proof in election petition is on preponderance of evidence in accordance with Section 135 Evidence Act.

However, where there is allegation of fraud or crimes such as bribery and forgery under corrupt practices have to be proved beyond responsible doubt. NWOBODO V ONOH, AKEREDOLU V MIMIKO.

ORDERS THE COURT OR TRIBUNAL CAN MAKE
a)      Where the court or tribunal finds that the returned candidate was not validly elected on any ground, the tribunal or court shall nullify the election.

b)      Where the court or tribunal finds that the person returned had the majority vote cast but was not qualified to contest the election; a fresh election shall be entered.

c)      Where the court finds that the candidate returned did not secure the majority of valid votes cast at the election, the court or tribunal shall declare as elected the candidate who scored the highest votes cast at the election and satisfied the requirements of the constitution and the Electoral Act. See section 143, Electoral Act as amended.

d)      That the person returned as winner was validly returned and thus, dismiss the election

e)      The court may uphold the petition and order that the person returned was not validly returned on grounds of lack of qualification, then orders a fresh election. See section 140(2) Electoral Act as amended.

f)       Order a fresh election in whole or in part for irregularity.

APPEAL OF TRIBUNAL DECISION

TIMELINES;
a)      Within 21 days from the date of the decision of the tribunal you file appeal
b)      Appeal must be disposed of within 60 days from the date of the delivery of the Judgment of the tribunal.

FINAL APPEAL
Appeal from the National and State House of Assembly Election Tribunal lie to the Court of Appeal. This appeal is as of right. See section 246(1)(b) CFRN as amended.
 It must be noted that the decision of the Court of Appeal in respect of appeals arising from the National and State House of Assembly Election Tribunal shall be final. See section 246(3) CFRN.

TWO-STEP APPEAL
Appeals from the decision of the Governorship Election Tribunal lies to the Court of Appeal as of right and if parties not satisfied can also appeal to the Supreme Court as of right. SECTION 233(2)(e) CFRN

ONE-STEP APPEAL
Appeal lies from the decision of Court of Appeal sitting as Presidential Election Tribunal to the Supreme Court as of Right. SECTION 233(2)(e)(i) CFRN

                                    THE END
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