Background
This case arises from the National Assembly primary elections held by the All Progressives Congress (APC) for the Kwande/Ushongo Federal Constituency in Benue State. Engr. George T.A. Nduul, the appellant, participated in the primaries, where he contested against Barr. Benjamin Wayo, the first respondent. The primaries took place on December 10, 2014, with Wayo emerging as the winner by securing the highest number of votes.
However, Nduul contested Wayo's candidacy, claiming that Wayo did not meet the necessary qualifications, including failure to pay nomination fees and present screening certificates at the primary venue. Displeased with the outcome, Nduul lodged a complaint with the party's appeal committee, which initially sided with him by recommending that he be considered the party's candidate. Nevertheless, the party later reversed this decision and confirmed Wayo's candidacy, leading to Nduul filing an originating summons at the Federal High Court.
Issues
The Supreme Court was tasked with determining several key issues, including:
- Whether the lower courts erred in allowing Wayo to contest based on claims of false information regarding his qualifications.
- The significance of adherence to the party’s internal rules governing candidate selection.
- The implications of proper notice and opportunity for fair hearing within the party’s procedural framework.
Ratio Decidendi
The Court held that:
- The burden of proof lies on the party asserting any irregularity in the qualification of a candidate.
- Election committees must adhere to their prescribed guidelines, and an appeal is often required to contest complaints within the party structure.
- The right to a fair hearing must be accorded to all parties affected by committee decisions.
Court Findings
In its judgment, the Supreme Court emphasized that the ultimate decision about the nomination process rests with the political party, provided they follow their established rules. The Court recognized that Nduul failed to substantiate his claims adequately, particularly regarding Wayo’s qualifications. Furthermore, it reinforced that termination of employment does not equate to disqualification unless stipulated under existing laws.
Conclusion
Ultimately, the Supreme Court dismissed Nduul’s appeal, affirming the decisions of the lower courts which had ruled in favor of Wayo's eligibility to contest in the elections.
Significance
This case is significant as it outlines the boundaries of judicial intervention in the internal affairs of political parties in Nigeria, stressing that parties must adhere strictly to their own guidelines when selecting candidates. It also serves as a reminder that allegations of misconduct or unverifiable claims need to be firmly substantiated for an appeal to succeed.