Background
The case of Oluwaseun Owolabi v. Seun Adesanya & Ors centers on a dispute following a primary election within the Peoples Democratic Party (PDP) in Ogun State. The appellant, Owolabi, argued that he was the rightful candidate after being nominated but was excluded from the primary election held on 23 May 2022, where the 1st respondent, Seun Adesanya, was declared the winner. The crux of the case involves questions of judicial jurisdiction and the timing of the appellant's suit in relation to the statutory framework provided by the 1999 Constitution of Nigeria.
Issues
The Supreme Court considered several key issues:
- Jurisdiction: Whether the lower court had jurisdiction to entertain the appeal.
- Statute Bar: Whether the suit was statute barred due to the timing of its filing in relation to the primary election.
Ratio Decidendi
The Supreme Court ultimately dismissed the appeal. The court highlighted that the date of the primary election, which was 23 May 2022, was crucial in determining the timeline for filing a pre-election matter. The Court maintained that the 14-day filing period stipulated under section 285(9) of the Constitution includes the date of occurrence of the event being contested.
Court Findings
The court found that:
- The cause of action indeed accrued on 23 May 2022, which was when the primary election occurred.
- The appellant filed his suit one day after the statutory deadline, making it statute barred.
The court noted that both the trial court and the Court of Appeal earlier established that the appellant's action was unfounded due to late filing.
Conclusion
Due to the failure to file the claim within the stipulated timeframe, the appeal was dismissed. It was confirmed that time starts running on the date of the event of the primary election.
Significance
This ruling underscores the importance of adhering to the procedural requirements of election law, particularly the strict timelines for filing pre-election matters. The judgment reaffirms that failure to comply with these timelines can result in the loss of the right to contest election outcomes, thereby reinforcing the integrity of electoral processes in Nigeria.