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AMINU BASHIR IBRAHIM V. BABANGIDA ALASAN YAKUDIMA (2021)

case summary

Supreme Court of Nigeria

Before Their Lordships:

  • Ibrahim Tanko Muhammad JSC
  • Olukayode Ariwoola JSC
  • John Inyang Okoro JSC
  • Paul Adamu Galumje JSC
  • Uwani Musa Abba-Aji JSC

Parties:

Appellant:

  • Aminu Bashir Ibrahim

Respondents:

  • Babangida Alasan Yakudima
  • All Progressive Congress
  • Independent National Electoral Commission
Suit number: SC. 465/2019

Background

This case concerns an appeal by Aminu Bashir Ibrahim against the decision of the Court of Appeal affirming a lower court's ruling. Ibrahim alleged that he won the All Progressive Congress (APC) primary elections for the Dala Federal Constituency but was wrongfully denied candidacy in favor of Babangida Alasan Yakudima. His claims led to a series of judicial proceedings starting from the Federal High Court.

Issues

The core issues to be resolved were:

  1. Was Yakudima validly nominated as the APC candidate?
  2. Did the appellant's suit violate section 285(9) of the 1999 Constitution, rendering it statute-barred?
  3. Did Ibrahim have the requisite standing to bring this suit?

Ratio Decidendi

The Supreme Court dismissed the appeal, holding that:

  1. Documentary evidence is considered superior, and oral evidence is inadmissible to contradict documented results unless fraud is proven.
  2. The internal affairs of a political party regarding candidate nominations are non-justiciable unless there is a clear breach of the party's guidelines.
  3. The grounds of appeal adequately stated grievances without ambiguity, making them competent.

Court Findings

The Court found that:

  1. The evidence provided by the elected committee chairman indicated that the primary election was conducted fairly, and Yakudima was indeed the valid candidate.
  2. The appellant's application exceeded the statutory timeline under section 285(9), filed too late to constitute a valid legal action.
  3. As Ibrahim was still a public servant at the time of filing, he lacked proper standing, per section 66(f) of the Constitution.

Conclusion

The Supreme Court ruled that the earlier judgments were upheld as sound. Ibrahim's allegations of malpractices were not substantiated with corroborative proof against Yakudima's nomination.

Significance

This judgment underscores the importance of adhering to the statutory timelines indicated in electoral law and reinforces the principle that internal party nominations fall under the domain of party discretion, reflecting the non-justiciable nature of political party prerogatives in Nigeria.