Background
This case arose from the dispute regarding the internal processes of the All Progressives Congress (APC) during its ward congresses held on July 31, 2021, in Kano State. The respondents, led by Muttaka Bala Sulaiman, sought legal recognition of their election as members of the ward executive committees, arguing that the party’s actions contravened its internal regulations and the Electoral Act.
Issues
The case presented several legal questions:
- Was the lower court correct in classifying the lawsuit as a pre-election matter under sections 285(14)(a) - (c) of the Constitution and section 87(9) of the Electoral Act?
- Did the lower court have jurisdiction to resolve a non-justiciable ward congress dispute?
- Was the court correct in its territorial jurisdiction to hear a matter arising from events in Kano State?
- Did the court err in its evaluation of the evidence presented?
Ratio Decidendi
The Court of Appeal allowed the appeal, ruling that:
- The dispute was an internal party matter and therefore non-justiciable; the court lacked jurisdiction.
- Jurisdiction is grounded in the geographical area where a dispute arises, and the trial court lacked the territorial jurisdiction to adjudicate on matters occurring outside its jurisdiction.
- The classification of the matter as a pre-election issue was misapplied, as the requirements of sections 285(14) and 87(9) were not satisfied.
Court Findings
The Court concluded that:
- The respondents were not ‘aspirants’ as defined by electoral statutes; thus, their claims relating to intra-party disputes arising from the ward congresses were not actionable in court.
- The framework in place for elections and party congresses sufficiently indicated that intra-party disputes, such as those regarding ward executives, fall outside judicial purview.
Conclusion
The judgment of the Federal Capital Territory High Court was nullified for lack of jurisdiction, reaffirming the principle that internal disputes of political parties are resolved internally and are not justiciable in courts.
Significance
This case underscores the limitations of judicial intervention in the internal affairs of political parties, reinforcing the principle that courts respect the autonomy of voluntary associations in managing their internal matters.