PRINCESS STELLA ADAEZE ODUAH V. SENATOR MARGERY CHUBA OKADIG (2019)

Background

This case involves a dispute arising from the primary election conducted by the People’s Democratic Party (PDP) for the Anambra North senatorial district held on December 7, 2014. Senator Margery Chuba Okadigbo, the 1st respondent, claimed victory in the primaries, asserting that she scored the highest votes and was duly returned by the returning officer. However, the party's national assembly electoral panel, led by Alhaji Adamu Mu’azu, refused to accept the results. Okadigbo sought declaratory and injunctive relief from the Federal High Court, which ultimately struck out her suit for lack of jurisdiction.

Issues

The case raised several significant legal issues:

1. Whether the Federal High Court had jurisdiction to entertain the 1st respondent's amended originating summons.
2. Whether the trial court's jurisdiction could be activated when the primary election results were not challenged as having been conducted improperly.

Ratio Decidendi

The Supreme Court held that:

1. Jurisdiction is a critical threshold issue; any absence renders proceedings void regardless of the conduct.
2. The Federal High Court can only exercise jurisdiction in matters that fall within its legally defined parameters, which in this case did not apply since the 1st respondent admitted the legitimacy of the primary election.

Court Findings

The court found that the 1st respondent's claims did not raise any challenge to the conduct of the primaries. Her admission that the election complied with the regulations of the Electoral Act effectively removed her case from the jurisdiction of the Federal High Court pursuant to section 87(9) of the Electoral Act. The court emphasized that the election’s internal affairs were not justiciable and the courts cannot interfere in the nomination processes as this falls under the domestic concerns of political parties.

Conclusion

The Supreme Court allowed the appeal filed by Princess Stella Adaeze Oduah (SC.384/2017) and struck out the originating summons from the Federal High Court, determining that there was no jurisdiction to entertain the suit based on the claims presented. The appeal filed by the 1st respondent (SC.278/2017) was rendered academic and subsequently dismissed.

Significance

This case is significant in its interpretation of jurisdiction relative to election-related matters in Nigeria. It underscores the duality of jurisdiction between Federal and State High Courts in pre-election disputes and reaffirms the principle that courts must refrain from intervening in a political party’s internal decision-making processes when such decisions comply with established electoral regulations.