In
this essay, we shall firstly consider those things that are to be taken into
consideration before igniting the judicial review process against an
administrative exercise of judicial power. That is to say, the considerations
for igniting the judiciary review administrative actions. But, note that
judicial review is a kind of inquest with a view to examining the legality or
otherwise of the action of a particular agency of government with a view to
determining its legality or declaring it null and void.
Requirements to be
satisfied before an action for Judicial Review is Maintained
These
requirements enable the court to have the jurisdictional competence or capacity
to review the administrative action or adjudication. The requirements are
examined herein below:
1.
The Issue of Locus Standi: A court of law cannot
concern itself with the suit of a busy body or a meddlesome interloper. Before
a person can competently invoke the jurisdiction of the court, he must have a
legitimate grievance to ventilate not doing so on behalf of another person; he
must have the standi to sue. This is a fundamental consideration. It is the
right to sue. The issue of locus standi is inextricably interwoven with the
issue of jurisdiction
2.
The Suit must not be
Hypothetical, Academic, Speculative or Remote: This
is because a court of law will not concern itself with such cases. An analogy
could be drawn from America, where the „doctrine of ripenness‟
applies. This doctrine is to
the effect that
a suit must
be ripe for
hearing, not merely academic or speculative. Accordingly,
if the suit is not ripe, the implication is that the
court with not have the
jurisdiction to hear
the matter. Thus,
as provided for in section 42 and
46 of the 1979 and 1999 Constitutions,
respectively, if there is a present
infraction of your right, there will be no problem of jurisdiction as
the court will hear the complainant/plaintiff. But if you complain of an action
which is proposed to be taken, there is an anticipated breach or a breach which
is imminent; the suit may not be entertained. Thus, the suit should not be one
that poses hypothetical questions; it must be a life case; a complaint
bordering on present or imminent injury.
3.
The Matter must be
Justiciable:
This is self explanatory. The provisions of Chapter II of the 1999 Constitution (as amended) is relevant in
determining the justiciability of an administrative action.
4.
Statute of Limitation: The law here is this,
namely that if a time is limited for the doing of something, any action
commenced after the limitation period will be incompetent. For instance, the Public Officers Act, 2004 at section 228 stipulates that every
action under that section must be commenced within three months, or else the
action will be incompetent and unmaintainable.
Grounds upon
which Judicial Review
of Administrative Action/Adjudication may be Predicated:
Broadly,
there are two grounds upon which judicial review of administrative action may
be predicated. They are:
1.
The
ground of ultra vires, and
2.
The
ground of breach of Natural Justice and Fair Hearing.
The
ultra vires ground will be involved
when you are complaining about administrative action performed by an
administrative agency performing ministerial or administrative functions.
However, where the administrative agency is performing a judicial function,
example administrative adjudication the proper ground to challenge such action
will be failure to observe the principle of fair hearing and natural justice.
In other words, given that an administrative agency may perform legislative,
executive (administrative) and judicial functions, and the administrative capacity
can be divided into ministerial or pure administrative; the proper ground to
challenge such an action will be want or absence of authority, which is ultra vires. Also, if the administrative
agency is performing a legislative function or in its legislative capacity, the
proper ground to challenge such an action will still be ultra vires, But, if the administrative agency is acting in its
judicial capacity, the ground of challenge will be breach or absence of natural
justice and fair hearing. The key distinguishing factor between administrative
and judicial power is that whereas the former does not involve exercise of
discretion; the latter involves exercise of discretion.
These
grounds will now be briefly considered seriatim.
Ultra Vires as a
ground for Judicial Review of Administrative Action
Literally,
ultra vires means outside or beyond
power or outside jurisdiction.
The
determination of this gives rise to a critical examination of the relevant
section of the statute. By the doctrine of ultra
vires any power exercisable by anybody or person or authority must have
legal basis to be competent. The legal basis may be the constitution, or a law
passed by the National Assembly or any executive order or instrument. The power
exercised must be traceable to an enabling power. Accordingly, it is expected
that a repository of power must act within the confines and contemplation of
the enabling power or instrument; failing which his action will be declared ultra vires and ipso facto unenforceable and ineffective.
The
doctrine normally occurs in a variety of ways. These are substantive ultra vires otherwise
known as want or excess of jurisdiction, procedural
ultra vires otherwise known as
defective procedure, use
of power for
an improper purpose
otherwise known as
abuse of discretion or
jurisdiction, unreasonableness and no evidence or absence of evidence,
justification or reason.
These
aspects of the doctrine of ultra vires will
now be considered seriatim.
Substantive Ultra Vires (Want or Excess of
Jurisdiction).
This
aspect of the ultra vires doctrine
mandates that an administrative agency or organ must act within the scope,
ambit or contemplation of its authority. That is to say, within the province or
parameters of his authority, failing which it will be said to have acted
without authority or in want of competence or jurisdiction. The want of
competence or authority may arise in either of the following ways; where there
is no legal backing, when the action is taken by a wrong person or body, when
the body authorized to act is improperly constituted or appointed, when action
is taken in respect of a wrong person or subject matter and when a wrong order or
penalty is imposed by the person or authority or body authorized to act. These
will now be explained.
a.
Absence of Legal Backing
Here there is no legal
backing based on the constitution or any other law to act. Such act is without
power traceable to a particular instrument or enactment. There is a total lack
or absence of capacity. There is absence of “warranto”. This is a very grave
case of ultra vires as is reflected
by the following judicial authorities.
In Re Maclean Okoro Kubanja (1974) 1 All NLR 269, the plaintiff was a
Chief Magistrate in the public service of mid-west state. He received a letter
asking him to accept a transfer from the post to another post in the mid-west
Ministry of Justice or consider himself to have been summarily removed from the
public service of the state. The plaintiff then applied to the Benin High Court
for an order of certiorari to quash the proceedings Public Service Commission.
The matter finally went to the Supreme Court which held that certiorari would
lie, as it was manifest that the relevant Public Service Commission of the
state was acting contrary to the terms of its establishment or in excess of its
jurisdiction in not complying with the provisions of the Civil Service
Regulations.
Also, in Dr. Sofekun v. Akinyemi & Ors (1980)
5-7 SC 1, where a public servant was dismissed by the Public Service
Commission, following in the result of an investigation panel, the Supreme
Court found that the dismissal was not done in accordance with the proper law.
b.
Action taken by the wrong
person or body
Here, if the enabling act
authorizes a particular person to do an act; it is only that person that can
delegate the power to do the thing in question unless there is a proper and
legal sub- delegation of power. Consistent with this position is the case of Vine v. National Dock Labour Board (1959)
AC 588, where disciplinary powers over dock workers were properly delegated
by the National Board to a Local Board with the National Board‟s approval. The Local
Board sub- delegated these powers to a disciplinary committee which purported
to dismiss Vine. The House of Lords held that the dismissal was void, since the
true meaning and intent of the scheme is that these duties shall only be
carried out by the carefully balanced board to which they are directly
entrusted under the scheme, the Local Board.
c.
When the body, authorized
to act is improperly appointed or constituted
A tribunal is improperly
constituted or appointed, if in setting it up, the principle of natural justice
such as nemo judex in causa sua is
contravened. The position is the same where the ground for appointment as
stipulated in the enabling Act is not strictly followed.
Thus, in Head of the Federal Military Government v.
Dr. Nwachukwu (1976) NMLR 151 an order nisi
of prohibition was granted against the ad
hoc investigating Committee/Disciplinary panel set up by the Council of the
Petroleum Training Institute, to prevent any further consideration by the
panel, because the principle of natural justice - nemo judex in causa sua - had been violated.
Here, the appellant had
applied for an order of prohibition to prohibit the panel from sitting on the
ground that, since the members of the panel were also members of the council,
by which it was appointed, and to which it was to report, their appointment
placed them in a position of being not only accusers but also judges in their
own cause, contrary to the principles of natural Justice.
Also, in Lawson v. Local Authority (1944) 10 WACA
228 the applicant was charged with failing to pay income tax and was
convicted. When the matter came to the West African Court of Appeal, his
conviction was set aside on the ground that it was the same individual, who in
his capacity as administrative officer prosecuted the case that also in his
capacity as Magistrate tried the case.
d.
Action taken in respect of
a wrong person or subject matter.
This is well illustrated
by the decision in White and Collins v.
Minister of Health (1939) 2 KB 838, where a local authority with power
under the Housing Act, 1936, to acquire land compulsorily for housing,
provided that it was not part of any “park, garden or pleasure ground” gave an
order and the owner of land affected by the order succeeded in invalidating it
in the High Court by showing that the land was in fact park land although the
land had been confirmed by the Minister of Health after a public inquiry.
Also, in Sule Katagun & Ors. v. Roberts, the
Supreme Court affirmed the decision of the Lagos High Court granting a
declaration that the plaintiffs retirement by the commission was ultra vires and void because the power
the commission purported to have exercised belonged not to it, but to the
Minister, who was empowered by section
9(1) of the Pensions Act to
retire public servants compulsorily after they had attained the age of
forty-five years. Thus, the action must be taken or directed against the person
which the law stipulates should be concerned or else, the action will be ultra vires. And when the subject matter
is expressly stipulated, the same rule applies.
e.
When a wrong order or
penalty is imposed by the person or
authority or body authorized to act
This is in tandem with the
case of J. Allen & Co Ltd. v.
Provincial Police Officer (1972) 2 ECSLR
(Pt. 18) 390 where the
court in construing
the Abandoned Property
(Control the Management) Law,
1968, came to the conclusion that the legislative or the Military Governor of
Benue – Plateau state never intended that the committee should exercise the
power of sale over the abandoned property. Consequently, the purported exercise
of power was declared ultra vires.
Again, in R. v. Minister of Transport Ex. Parte
Upminister Services Ltd. (1934) 1 KB 277, the Minister of Transport was
authorized to hear appeals from applications to traffic commissioners for
licenses, but was not entitled to deal with revocations of licenses, and when
on appeal he purported to direct the future revocation of a license, the courts
quashed his decision on the ground that it was ultra vires.
Defective Procedure or
Procedural Ultra Vires
This
occurs where there is non-compliance with procedure laid down by law in the
exercise of the power. It is therefore imperative that the donee of power must
scrupulously observe the procedure laid down for the exercise of the power,
failing which the power so exercised may be vitiated through the
instrumentality of the doctrine of ultra vires. However, for a particular
procedural non-compliance to be ipso
facto material for procedural ultra vires, such a procedure must be
mandatory and imperative.
In
some cases, where the requirements are in the nature of conditions precedent to
the assumption or exercise of jurisdiction, failure to comply would render all
subsequent proceedings ultra vires and
void. The courts will also quash the decision of a tribunal for non-compliance
with any statutory requirement requiring notice to be given to the parties.
Thus, in Rayner v. Stopney Corporation
(1911) 2 Ch. 312, a local authority’s failure to comply with a regulation requiring
the service of
a notice before
making closing order
in respect of
an ‘unfit house’, giving
particulars of right of appeal was held to render its proceedings void. Finally,
the courts will intervene and set aside any decision or order given in
violation of a procedural requirement; particularly if its failure to intervene
would leave uncorrected a gross injustice or miscarriage of justice.
Use of Power for Improper Purpose
or Motive
This
arises where power has been exercised in bad faith so as to achieve a purpose
other than the one for which the power was conferred: Roberts v. Hopwood (1925) AC 578. There it was held that an
administrative action can certainly be challenged on the ground that it was
made in bad faith. A case that aptly illustrates this ground of ultra vires is that of Sydney Municipal Council v. Compbell (1925)
AC 338, where the council was empowered by statute to acquire land by
compulsory purchase in order to make streets or to carryout improvement in or
to remodel the city. The council made a compulsory purchase order to acquire
land ripe for development not for any of these authorized purposes; but in
order to realize later the increase profit in the land‟s value. The Privy Council
held that an injunction should be granted against the council.
Lastly,
want of good faith and intention to direct the exercise of the power towards
the attainment of the competent goal can be established by showing that the
authority deliberately admitted and acted on extraneous matters and irrelevant
considerations, or that material and relevant matters and considerations were
deliberately excluded or ignored.
Unreasonableness
It
is well settled that a public body invested with statutory power must act in
good faith and it must act reasonably – per Lord Macnaughten in Mayor of West Minister v. London and
North-Western Railways (1905) AC 426. It was on the ground of
unreasonableness that the House of Lords quashed the decision of the Borough
Council to increase the minimum wage of its employees to an excessive level: Roberts v. Hopewood.
Again,
in Associated Provincial Picture Houses
Ltd. v. Wednessbury Corporation (1948) 1 KB 223, Lord Greene MR stated that
“a decision of a public authority can be off-set, if it is unreasonable in the
sense that the courts consider it to be a decision which no reasonable
authority would have taken; but not what the court considers to be reasonable
”. The facts were that the plaintiffs who were proprietors of a cinema theatre
in Wednessbury, sought to obtain from the English Court of Appeal a declaration
that a certain condition imposed by the defendant (the corporation of
Wednessbury) on the grant of a license for Sunday performances in their cinema was
ultra vires. Their counsel submitted
that the imposition was unreasonable and that consequently it was void or ultra vires.
Also,
in Adeyemi Durojaiye v. Commissioner,
Ministry of Works, Attorney General Lagos State & Ors (1976) 6 CCHCJ, 1327,
the plaintiff sought for a declaration that the letter withdrawing the
approval of his building plan, while he had commenced building on the land, was
null and void. He alleged that the third defendant was unduly influenced by a
third party in withdrawing the approval, because the latter had interest in the
land on which the plaintiff had already commenced building. It was held that
such withdrawing of the building plan was ineffective for not being reasonably
exercised.
Furthermore,
in Ibadan City Council v. Odukale (1972)
All NLR (Pt. 2) 319; (1973) 3 UILR 490, the respondent, who was the
plaintiff in the lower court, complied with the relevant bye law, but was
refused permit by the chairman of the defendant council. The reason for his
refusal was that he wanted the respondent, who belonged to a different
political party, to change to the Nigerian National Democratic Party, which was
the party in control of the council. The court held that, in the absence of any
evidence to the contrary, it would be unreasonable to infer that the conditions
stipulated for the grant of permit by the council included becoming a member of
or declaring for the political party in control of the council.
No Evidence
This
ground is based on the authority of the dictum of Uwaifo JSC, in Igbe v. Governor of Bendel State and Anor,
which relied on the opinion of Lord Denning in Ashbridge Investment Ltd. v. Minister of Housing and Local Government
(1965) 1 WLR 1320, where no evidence was listed as a separate ground for
challenging the Minister’s
decision that a certain building was a house, his Lordship stating that it
seems that the court can interfere with the Minister’s decisions if he has
acted on no evidence or if he has come to a conclusion t o which on the
evidence he could not reasonably come or if he has given a wrong interpretation
to the words of the statute, or if his taken into account what he ought not to
have taken into account or vice versal or
has otherwise gone wrong in law.
Breach of the Doctrine of
Natural Justice as a ground for Judicial Review of Administrative Action
The
legal conception of natural justice presupposes that natural justice connotes
two things; namely, the principle of audi
altarem partem and nemo judex in
causa sua. Whereas the former means that both parties must be heard, the
latter means that a person should not be a judge in his own case/cause. This
principle is constitutionally recognized in section 36(1) of the 1999 CFRN which grants a citizen entitlement
to fair hearing. By that provision,
natural justice summarily means fair hearing. The courts always insist on the
application of the rule of natural justice only to acts and decisions
classified by them to be judicial or quasi judicial as well as those which
infringe upon people’s
rights recognized by law; not to acts or decisions classified as administrative
or which affects privileges or licenses.
Generally,
provided the administrator strictly observes the terms of a power conferred on
it by statute the courts cannot question or interfere with an exercise of that
statutory power. But, since, the administrator is not legally trained and does
not observe the rules of court; he is expected to act fairly by observing the
rules of natural justice. That tribunals must act fairly in the performance of
their functions is illustrated by the case of Board of Education v. Rice where Lord Melbourne opined that “the
Board of Education must act in good faith in listening fairly to both sides …
always giving a fair opportunity to those who are parties in the controversy to
correct or contradict anything prejudicial to their view.
Audi Altarem Paterm
Section 36(2)(a) of 1999
CFRN provides
for this arm of natural justice. The principle, involves a consideration of the
following issues:
(a)
Notice
Notice must be adequate
and reasonable. In Cooper v. Wardsworth
Board of Works, the court in holding that the board ought to have given
notice to the plaintiff before subjecting him to such a fantastic loss opined
that, he who shall decide anything, without the other side having been heard,
although he may have said what is right, will not have done what is right. Also
in Ridge v. Baldwin Lord Ried opined
that an officer cannot lawfully be dismissed without first telling him what is
alleged against him and hearing his defence and explanation.
(b)
Time
In Local Government Board v. Alidge, the court opined inter alia, that when the duty of
deciding an appeal is imposed, those whose duty it is to decide must act
judicially and they must give to each of the parties the opportunity of
adequately presenting the case made. Moreover, section 36(6)(b) of the 1999 Constitution provides that every
person who is charged with a criminal offence shall be entitled to be given
adequate time and facilities for the preparation of his defence. The reason for
this may be found in section 36(5) of the same constitution which provides for
the presumption of innocence.
(c)
Adjournment
Where necessary,
adjournment is granted to enable a party to present his case adequately. But,
tribunals cannot grant adjournments on frivolous grounds in order not to delay
proceedings: Daniel Aladabe
v. Account Disciplinary Tribunal. In R. v. Medical
Appeal Tribunal Midland Region,
it was held that refusal to grant an adjournment to allow the production of a
consultant doctor’s
report was an error of law and contrary to natural justice.
(d)
Legal representation
This depends on the facts
and circumstances of each case. In Pett
v. Greyhound, Racing Association, the court held that a trainee who was
under a serious charge of dragging a dog about to compete for a race, was
entitled to be represented by counsel or solicitor when a tribunal was
considering the matter relating to his reputation or livelihood since, if found
guilty, he may be suspended or have his training license withdrawn. In R. v. Secretary and State House Dept Ex parte
Tarrant, the court laid down the following considerations for the determination
of the need for legal representation:
1)
the nature of the charge or complaint and the potential
penalty;
2)
The capacity of the parties to present their cases;
3)
whether any point of law is likely to arise;
4)
procedural difficulties which parties may encounter that may
affect the proper presentation of their cases such as the need for cross
examination;
5)
the need for speed in taking decisions; and,
6)
the need for fairness as between the parties and authority.
(e)
The Nature of hearing
The rule does not
guarantee oral hearing once the parties are placed on the same footing. In Local Government Board v. Arlidge – it
was held that an opportunity to be heard need not be oral unless oral hearing
is expressly prescribed. Also the rule does not mean that a person must have
his right determined by the person who heard the evidence at first
instance. Lastly, on authority of Miller v. Minster of Housing and Local
Government, Lord Denning opined that hearsay is clearly admissible before a
tribunal; but in admitting it, the tribunal must observe the rules of national
justice.
(f)
Cross Examination
This depends on the facts and circumstances of
each case. In R.v. Commission for Racial
Equality Ex-parte Quarte & Rotton, the court held that where the hearing
is of a criminal nature as opposed to merely administrative, opportunity to
cross-examine ought to be allowed.
Based
on the foregoing, it can be said that natural justice is a doctrine of variable
content. But, three features standout (a)
the right to be heard by an unbiased tribunal (b) the right to have notice of charges of misconduct (c) the right to be heard in answer to
those charges.
Take Notice that the court will
always hold the strict compliance with audi
altarem paterm rue in the following instances (1) where there is an existing dispute to be decided (2) when a person’s livelihood is at stake (3) where the decision will deprive a
person of office or status and (d) where
property interests is at stake.
Criminal Element in Audi Altarem Paterm
The
law is that where an allegation of crime is involved, it is the court set up
under the constitution that has jurisdiction:
section 36(4) of the 1999
Constitution. By that
section whenever any person is charged with a criminal offence he shall
unless the charge is withdrawn, be entitled to fair hearing in public within a
reasonable time by a Court or tribunal. An attempt to equate administrative
tribunal with that mentioned above is always rejected by the court.
In
Adesoyi, Fagade v. Unife – it was
canvassed that the student disciplinary board that recommended the dismissal of
the applicant for assault and arson was a tribunal for the purpose of section 36(4) supra. The court rejected
this argument and held that „tribunal‟ for the purpose of the section can only mean a
tribunal established by law for the purpose of trying a particular offence.
Thus, where an administrative matter has a criminal content, such an
administrative matter becomes a criminal matter only to be taken to court for
resolution before the administrative can legally assume jurisdiction: Garba v. UNIMED.
Nemo Judex in Causa-Sua
Literally,
this means that, a person shall not be a judge in his own cause; in other
words, anyone who is trying the interest of another party should be
disinterested in such a matter. The rule of nemo
judex in causa sua is to the effect that no man can be plaintiff or
prosecutor in any action and at the same time sit in judgment to decide in that
particular case: United Dairies v. Bath
Justices, per Atkin J.
Thus,
where a party has an interest in a matter in which he is to preside, he should
refrain from taking part in the decision otherwise, he may be deemed to have
been biased. The maxim applies in both administrative and judicial matters; it
is the rule against interest and bias. Additionally, there are other aspects of
interests or bias which depend upon the test of “a real likelihood of bias” as
enunciated by Blackburn J. in R. v.
Cambridge Justices, Ex. Parte Pearce (1955) 1 B 41, where he opined that
“to disqualify a person from acting in a judicial or quasi-judicial capacity
upon the ground of interest (other than pecuniary or proprietary) in a matter
of the proceeding, a real likelihood of bias must be shown”.
Being,
a party to a matter does not necessarily mean being a plaintiff or defendant,
but one may be disqualified or held to be bias because of the role he played in
ad judication. Example a person who acts as a prosecutor and also takes part in
taking the decision will have the decision open to nullity. For instance, in Alakija v. Medical Disciplinary Committee (1959) 4 FSC 38 the inquiry was conducted
in a manner contrary to principles of Natural Justice in that the Registrar,
who was in fact the prosecutor, took part in the committee’s deliberations. This was
also the case in Gani Fawehimi v. Legal
Practitioners Disciplinary Committee (1982) 3 LR 319.
Furthermore,
the most important thing to note when this doctrine is in issue is to bear in
mind the statement of Lord Hewart in R.
v. Sussex, Jusitces, Ex Parte McCARTHY, where he stated that “it is not
enough to say that justice is done, it should manifestly and undoubtedly be
seen to be done”.
Similarly,
bribery and corruption and pecuniary or proprietary interest in the subject
matter of controversy would disqualify a person. Personal relationship with the
parties to the case will also nullify the decision. This relationship may be
personal as with friendship, affinity or consanguinity, professional or
vocational, employer/employee or even political. In all this the court presumes
that there may be likelihoods of bias. Therefore such adjudicator ought to
refrain from taking part in the adjudication.
The
courts have tried to make distinction between domestic tribunal and those
tribunal with judicial trapping in adjudication of natural justice rule. In the
latter, the courts have insisted on strict application of the doctrine.
Opinions are diverse on the former. However, there is the agreement that
whether a tribunal is domestic or judicial, those who are to take decisions
must act fairly. REID J. was in support of the dictum of Lord Elborne in Board of Education v. Rice supra, when
he opined that Natural Justice requires that the procedure before any tribunal
which is acting judicially shall be fair in all circumstances.
Again,
it is not enough for a person to hold that he is not biased by virtue of his
position, he can be disqualified if a third party or a reasonable man could
view that by virtue of his position, he is likely to be biased: Kokoye v. CBN.
Exceptions to the nemo judex in causa sua principle
a.
Necessity: If by law a person is
the only competent person to judge or decide a matter, he should not
be disqualified nor
should he abandon
his responsibility for
the fear of offending against the rule of bias. For
instance, it is popularly thought that if a lawyer, a member of the legal
profession is tried and either convicted or acquitted by a judge of the High
Court or other superior courts, such an acquittal or conviction should be set
aside because both the
lawyer and the
judge who handled
his case belong
to the same profession, thus raising the issue of
real likelihood of bias. This should not be so because in any case where a
lawyer commits an indictable offence, he should be tried by a judge learned in
law as a matter of necessity and the outcome of such trial should not be set
aside on grounds of reasonable suspicion of bias;
b.
Statutory Exclusion of the
Rule: An act of the National Assembly can exclude
the operation of the rule by authorizing a person to hear and determine a case
in which he is held personally interested. In State v. Oba Ogunleye, it was held that the Nemo Judex rule can be
overridden by statute and necessity.
c.
Waiver: A party in a suit might
waive this fundamental right of natural justice in the course of proceedings
either by consent or lashes and acquiescence.
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