AKINREMI V. SULEIMAN (2022)

Background

This case arose when the plaintiffs, comprising members of the All Progressives Congress (APC), challenged the results of a ward congress held in Kano State on July 31, 2021. They claimed to have won the congress but were allegedly not recognized due to a corrupt reporting of the outcomes.

Issues

The main issues in this appeal include:

1. Whether the court assumed jurisdiction correctly regarding the plaintiffs' claims as pre-election matters.
2. Whether the conduct of a political party ward congress is justiciable or an internal issue.
3. Whether the court possessed the requisite territorial jurisdiction over the matter.
4. The locus standi of the plaintiffs to bring the suit.
5. Whether the evidence was improperly evaluated by the court.
6. The implications of non-joinder of necessary parties.
7. Whether there was a need for a plenary trial given the complexities of the evidence.

Ratio Decidendi

The Court determined that:

1. The suit centered on an internal party congress rather than on candidate nominations for an election. Thus, the matter was not a pre-election issue as defined by section 285 of the Constitution.
2. The High Court of the Federal Capital Territory had no jurisdiction to adjudicate on matters that did not arise within its territorial scope, particularly since the facts pertained to a congress in Kano State.
3. The plaintiffs' allegations constituted an intra-party dispute, rendering the issues non-justiciable.

Court Findings

The court found that:

1. Even if the plaintiffs filled nomination forms, the controversy surrounding the election process indicated significant disputes that could not be resolved via originating summons.
2. The failure to join necessary parties (the newly elected ward executives) did not invalidate the proceedings, as such non-joinder did not affect the competence of the suit.
3. The originating summons procedure was improperly used in this case, given the contentious nature of the claims.

Conclusion

The appeal was allowed, and the trial court's judgment was set aside on the grounds of lack of jurisdiction and improper procedure being employed.

Significance

This case is pivotal as it clarifies the jurisdictional boundaries concerning internal party matters in Nigeria, particularly emphasizing the importance of adhering to established legal frameworks governing the conduct of political parties and their congresses.