ADEGOROYE V. ALLIANCE FOR DEMOCRACY (2003)

Background

This case arose from the actions of Ademola Adegoroye, Olusegun Mimiko, Akerele Adu, and Olusola Agbesua, who were party members of the Alliance for Democracy (AD) in Ondo State, aiming to contest for the gubernatorial primaries in the forthcoming 2003 elections. Despite purchasing nomination forms and complying with necessary fees, these individuals were excluded from the screening and nomination process as the party had purportedly nominated the incumbent governor, Chief Adebayo Adefarati.

Issues

The primary issues presented in this appeal include:

1. The trial Judge’s ruling that the suit was premature.
2. Justiciability of a party's internal matters.
3. The competency of a ground of appeal that alleges both error in law and misdirection.

Ratio Decidendi

The Court held that the appellants failed to exhaust the internal mechanisms provided by the AD’s guidelines before resorting to the courts. Therefore, their case was premature, lacking justiciability and merit.

Court Findings

The court found that:

1. The absence of a screening decision made by the party should not be equated with a lack of decision altogether, as there was substantial evidence pointing towards the party’s decision-making process to exclude the appellants.
2. The plaintiffs’ letter of protest did not comply with procedural requirements set forth in the party guidelines, which necessitated a formal appeal.
3. The decision-making power concerning candidate nominations resides solely with the political party according to the provisions of the Electoral Act, 2002, and sections of the Nigerian Constitution.

Conclusion

Ultimately, the appeal was dismissed with the cross-appeal of the 1st and 2nd defendants allowed, thereby affirming that the matter was not justiciable in a legal context and should not warrant judicial intervention as it pertained to the internal affairs of a political party.

Significance

This case reinforces the principle of self-regulation within political parties in Nigeria. It establishes that judicial intervention in partisan electoral processes is limited, especially in matters defined as internal to the party's governance structure. The judgment highlights the importance of adhering to party guidelines and emphasizing the exhaustion of internal remedies before escalating disputes to court.