Election Petition Litigation: Key Legal Issues To Note By; Prince Ikechukwu Nwafuru

Introduction

Election Petition Litigation is a very critical component of
post electioneering process especially in a developing country such
as Nigeria where mis-trust, corruption and manipulations of
electoral process often make it impossible for losers in electoral
contests to heed the call to exhibit grace in defeat and move on.
The rare sportsmanship displayed by the former President, Goodluck
Ebele Jonathan in congratulating the current President even before
the result was declared and in refusing to challenge the outcome of
2015 Presidential election at the Election Petition Tribunal/Court
of Appeal has remained the exception rather than the rule.

Whilst it is my hope that those who lost in the last
Presidential and National Assembly Elections held on 23 February
2019 and those who will lose in the Governorship and State Houses
of Assembly elections scheduled to take place on 09 March 2019
should demonstrate the hackneyed sportsmanship and sheath their
litigation swords, however, the point must be made that it is
within the constitutional right of any contestant to challenge the
outcome of  any election where he or she feels strongly that
there are cases of irregularities, corrupt practices or substantial
non-compliance with the laws. Without doubt, petitioners have
reclaimed their stolen mandates at the Tribunals and appellate
courts in the past. Thus, rather than being viewed only from the
myopic prism of being lawyers’ cash cow, election petition
litigation should be considered in a broader perspective as it
often turns out to be the true test of credibility of our electoral
process. Of course I am not unmindful of the herculean task of
proving election petition in Nigeria. To successfully prove
election petition in Nigeria is akin to looking for a needle in a
haystack. Nonetheless, at the minimum, the process should have some
psychological and soothing effects on losers who feel cheated. More
importantly, the process offers an avenue to interrogate the
credibility of the election itself.  Beyond this, recent
reforms and amendments witnessed in our electoral laws came about
as a result of the interplay of arguments of counsel and
proceedings at election petition litigation. For instance, as it
relates to the 2015 elections, yours truly was in one of the legal
teams at the various Governorship Election Tribunals and up to the
Supreme Court, who pressed the card reader arguments and the need
to amend the Electoral Act to make provision for the use of the
device in the conduct of elections. Our arguments stemmed from the
fact that there is no provision for the use of card reader in the
Electoral Act 2010 (as amended) as only the use of Voters’ Register
was envisaged in the Act. In other words, the INEC Guidelines which
provide for the use of card reader, being a subsidiary legislation
cannot override the provision of the Electoral Act. This apparent
lacuna was exploited by election petition lawyers at the Tribunals
in respect of the 2015 elections. Interestingly, our arguments have
led to the amendment of the Electoral Act to make the use of card
reader mandatory except that the amendment is yet to receive the
assent of the current President as a result of back and forth that
has characterized the Electoral Act, 2018 Amendment Bill.

That said, this non-exhaustive guidepost is meant to draw
attention to the critical legal issues in election petition
litigation as experience has shown that minor mistake or tardiness
of counsel is capable of ruining one’s political career at the
Tribunal and Appellate Courts. However, this highlight is merely a
guide and should not be taken as a substitute for proper legal
advice.

Time is of the Essence – Election Petition is sui
generis

Unlike other civil matters, the timeline for the litigation of
election petition dispute is constitutionally provided. This gives
rise to the popular aphorism that time is of essence in election
petition and also accounts for the sui generis nature of
proceedings at the Election Petition Tribunals. Unlike in regular
courts where extension of time application is a norm and often
considered harmless and innocuous, at election petition Tribunal,
parties must comply with the time provided in the Constitution and
Practice Directions. In the case of PDP V. INEC &
ORS(2014) LPELR-23808(SC), the Supreme Court put the
point succinctly as follows:

“It has been stated in quite a number of decisions in this Court
that election matters are sui generis and as such must be conducted
strictly in compliance with the rules guiding them. Thus by Section
285(7) of the Constitution of the Federal Republic of Nigeria,1999
(as amended) this Court shall hear appeals from the Court of Appeal
arising from election matters within sixty (60) days from the date
of the delivery of the judgment appealed against. In order to
regulate and manage the 60 days allotted by the Constitution, the
Practice Directions has prescribed time within which each party is
to comply with the processes leading to the hearing of the appeal.
It is thus my view that in the circumstance such as this, no party
is allowed to default and then turn around to plead the
Interpretation Act. The combined effect of section 285 (7) of the
1999 Constitution (as amended) and paragraph 6 of the Practice
Directions is that they limit the doing of any act to the period
prescribed therein. Any action done outside the period
prescribed is, to say the least, a nullity. The use of the word
“shall’ in paragraph 6 of the Practice Directions, makes it
mandatory. No party or this Court has any discretion in the
matter. The 26th respondent was served on 22nd
August, 2014. Its time started to run from that same date
irrespective of the fact that it was served at 4.00 pm or
thereabout. Accordingly it’s time for filing its brief expired on
26th August, 2014. The subsequent filing of the brief on 27th
August, 2014 was done outside the time allowed by the Practice
Directions. See: CPC V. INEC (2011) 18 NWLR (Pt. 1279) 493; ACN V.
Nyako…”

From the foregoing, extension of time application is ruled out
at the Election Petition Tribunals as anything done outside the
prescribed time limit is null and void. This is not to say that
lawyers do not apply for extension of time at the Tribunals as most
of them often argue that the above decision for instance, applies
only to time provided under the Constitution and does not extend to
time provided under the various Rules and Practice Directions.
Similarly, the Rules under the 1^st Schedule to the
Electoral Act and Federal High Court Civil Procedure Rules, 2009
which apply when there is a lacuna in the 1^st Schedule,
both give parties right to seek extension of time in appropriate
cases. However, given the decisions of Court on this point, any
party applying for extension of time does so at his own risk. As
noted by the Supreme Court in PDP v. INEC, neither the Tribunal nor
the Court has discretion to extend time in election petition
proceedings. With this in mind, parties should be aware of time
limit provided under the Constitution and various Rules and
Practice Directions regulating proceedings at election petition
Tribunals and Court.

A petitioner or Cross-petitioner has 21 days to file or present
the petition or a cross-petition and time start counting from the
date of declaration of results. The respondent has 5 days to file a
memorandum of appearance. However, non-filing of a memorandum of
appearance shall not bar the respondent from defending the petition
provided he files his Reply not later than 21 days. Paragraph 12 of
the 1^st Schedule to the Electoral Act also allows the
Respondent to file his Reply within 14 days while the Petitioner
has 5 days to file the Petitioner’s reply. In practice, Respondents
often opt for the 21-day option for filing of Reply as it clearly
affords them more time. Paragraph 14 (2) (a-b) of the
1^st  Schedule and the case of
 Ngige Vs Obi [2006] 14 NWLR (pt.
999) 1 are to the effect that no amendment affecting the substance
of the election shall be allowed after the 21 days provided for
filing of petition. In practice, amendment of the petition no
matter how inconsequential after 21 days is often opposed
vehemently by the opposing counsel.

After the close of pleadings, there will be pre-hearing session.
The purpose of the pre-hearing session is to dispose all
interlocutory matters, giving such directions for expeditious and
economic and urgent disposal of the matter. Please note that any
Application made outside pre-hearing session must have a relief
specifically seeking the leave of the Court to hear such
application outside the pre-hearing session. The petitioner shall
within 7 days after filing and service of the Petitioner’s Reply or
7 days after the filing and service of the Respondent’s reply, as
the case may be, apply for the issuance of pre-hearing notice.
Trial is commenced after pre-hearing. Petitioner has 14 days to
prove his case, while Respondent has 10 days. After trial, the
Respondent shall file his Final Written Address within 10 days,
while Petitioner has 7 days and then 5 days for the Respondent to
file a Reply on point of law. The Tribunal has 180 days to deliver
its judgment from the date of filing of the petition.

In respect of appeal, the Appellant shall file his Notice Appeal
within 21 days from the date of the decision
appealed against whether interlocutory or final. The Appellant is
expected to file his Brief of Arguments within 10 days of receiving
the Records and serve same on the respondents immediately. The
Respondent shall file in the Court, his own Brief of Arguments
within 5 days of service of the Appellant’s Brief. The Appellant
may file his Reply Brief within 3 days of the service of the
Respondent’s Brief. Every Brief and Reply shall not exceed 40
pages. Any appeal arising from the decision of the Tribunal to the
Court of Appeal shall be determined within 60 days from the date of
the delivery of Judgment of the Tribunal or Court of Appeal.

Know your Grounds and seek proper reliefs

In terms of content, the petition should contain the parties
interested. When there is a complaint against any official of
Independent National Electoral Commission (INEC), it is proper to
sue INEC rather than the named official who committed the
infraction and this also extends to criminal allegation as the
Tribunal does not have jurisdiction to try electoral offences. All
that is required is to prove the allegation of crime beyond
reasonable doubt. It has however, been argued that in cases
involving criminal allegation against INEC official, it is better
to join the offending official so that he can personally answer for
the crime except that such joinder often makes the petition clumsy
and acts as a clog in the proceedings. Strategically and given the
time constraint, it is safer to join only INEC rather than the
offending official. The petition must also contain facts relating
to the holding of the election, the scores of the candidates and
the person returned as the winner of the election. See
Ojong v. Duke (2003) 14 NWLR
(pt.  841) 581 on the effect of not stating
scores of the candidates who contested the election in body of the
petition. Non-compliance renders the petition void. The petition
should also contain the grounds upon which the petition is based
and reliefs sought by the petitioner. Frontloading is part of
election petition litigation. Whilst the petitioner has the option
of filing alongside the petition, copies or list
of documents to be relied on, the Respondent is only permitted to
file copies of documents. There is no justification for this
discriminatory provision which gives the petitioner the option of
filing list of documents but restricts the Respondent to
copies only. Obtaining copies of documents from
INEC within 21 days is not an easy task. In preparing the petition,
the petitioner must be wary of unwieldy grounds. Section 138 (1)
(a)-(d) of the Electoral Act, 2010 (as amended) lists the grounds
upon which an election may be questioned to wit:

1. that a person whose election is questioned was at the time of
   the election not qualified to contest the election
2. that the election was invalid by reason of corrupt practices or
   non-compliance with the provisions of this Act.
3. that the respondent was not duly elected by a majority of
   lawful votes cast at the election or
4. that the petitioner or its candidate was validly nominated but
   unlawfully excluded from the election.

In the case of Dim C.O. Ojukwu v. Alhaji Umaru
Yar’adua & Ors (2009) 12 NWLR (pt. 1154) 50 at
142 the Supreme Court, per Muhammed, JSC emphasized
the need to comply with the grounds as stated in the Electoral Act.
As noted by the Apex Court:

“Although election cases are sui generis; the general law is
that procedures, or conditions provided by a statute within which a
petition can be initiated, and except where the statute admits of
exemptions, such procedures or conditions must be complied with in
order to inject life into the petition. Thus, claims or petitions
must be made within the dictates of the statutory procedures. Where
grounds set out in an election petition are not in conformity with
the provision of section 145 of the Act, those grounds are liable
to be struck out for incompetence. This is because such ground(s)
are the initiating processes which ab initio must be solid, valid
and competent”

In Goyol v. INEC (No.2) (2012) 11 NWLR (pt.1311) 218
at 299 the Court of Appeal held that the use of ‘or’
in section 138(1) of the Electoral Act 2010 (as amended) connotes
an alternative or an option. Consequently, corrupt practices and
non-compliance should not be joined together as one ground in an
election petition. The principle is that where a statute provides
for a particular method of performing a duty regulated by statute
that method, and no other, must have to be adopted.

In seeking reliefs in a petition, it is improper for a
petitioner who pleads facts and seeks a declaration that the
respondent did not score the majority of lawful votes cast at the
election to plead facts and also pray that the election be
annulled. In ONUIGWE v. EMELUMBA (2010) ALL FWLR (PT. 517)
698 at 732, the Court of Appeal held that: it is a
contradiction in terms for a petitioner in an election petition to
ask that an election be declared void and at the same time ask that
he be declared the winner. This is because if the election is void,
there would be no winner and the logical consequence would be a
by-election. A Petitioner cannot have his cake and eat it. He
cannot ask for avoidance of the whole election and still benefit
from the nullification by being returned under the void election.
Also in DINGYADI v. WAMMAKO (2008) 17 NWLR (PT. 1116) 395 AT 447,
the Court held that a petitioner who has challenged the regularity
of the conduct of the election is not entitled to be returned as
the candidate duly elected with the majority of the valid and
lawful votes cast at the election. With these decisions, the fate
of a petitioner whose grounds of petition are not in line with the
provisions of section 138(1) of Electoral Act, 2010 (as amended)
and whose reliefs are contradictory is settled.

Pleadings/Proof

It is elementary principle of law that evidence cannot be
adduced in proof of facts not pleaded. The nature of pleadings in
election petition depends largely on the ground upon which the
election is being challenged. The Supreme Court emphasized the
importance of pleadings and the need to specifically plead material
facts in election petition in the case of Ojukwu v.
Yar’adua (2008) 4 NWLR 435 (pt. 1078) at
page 462.

Where a petition is based on the ground of substantial
non-compliance with the provisions of Electoral Act, the petitioner
must not only plead and prove substantial non-compliance but must
also plead and prove that the non-compliance substantially affected
the result of the election.  Non-compliance with the
provisions of the Act without more is not sufficient to invalidate
an election.  See Buhari v Obasanjo (2005) 2 NWLR
(pt.910) 241; Yusuf v Obasanjo (2005) 18 NWLR (pt.956)
96.  It follows that where insufficient facts or
none at all are pleaded to establish substantial effect of the
non-compliance on the result of the election, no reasonable cause
of action has been made out. Some species of allegations deserve
some particulars. Where disenfranchisement of voters is alleged,
such facts must be pleaded and proved “polling unit by polling
unit” ward by ward, and the persons best eligible to testify as to
what happened in the polling units are the polling agents. See
Ucha & 1 other v Elechi & 1774 others (2012) 13
NWLR (pt.1317) 330. In fact, as often said in
election petition parlance, the polling unit is the foundation upon
which the pyramid of an election process is built and this was very
much the view of the Supreme Court in the case of Nwobodo v. Onoh
(1984) 1 SCNLR 1. The standard of proof required to prove
allegation of disenfranchisement in an election petition, was
demonstrated by the Supreme Court in NGIGE V. INEC (2015)
1NWLR (Pt. 1414) P. 281  as follows:

“A voter is disenfranchised when his right to vote is taken
away. That is to say he claims to be registered but was not allowed
to vote. When would the court be satisfied that voters were
disenfranchised?

• The disenfranchised voters must give evidence to establish the
  fact that they were registered but were not allowed to vote.
• The voters card and voters register for the polling unit must
  be tendered.
• All the disenfranchised voters must testify to show that if
  they were allowed to vote their candidate would have won the
  election. See Ucha v. Elechi (2012) 13 NWLR (Pt. 1317) 330;

Thus, to succeed in allegation of disenfranchisement of voters,
the petitioner ought to have called all the disenfranchised voters
or as many of them that would show that if they were allowed to
vote, their members added up, the petitioner would be the winner as
he would have more votes. If this is not done, then it is fatal to
the issue of voters being disenfranchised. In relation to
allegation of over-voting, to prove it, the petitioner needs to
tender the register of voters for the entire constituency, the
ballot boxes containing the ballot papers and the statement of
result from all or at least the affected polling stations in the
constituency. The petitioner would then proceed to demonstrate and
establish from those documents tendered, how the over-voting
occurred. He must then establish through evidence that, the total
number of votes cast at the election exceeded the total number of
votes on the register. See INIAMA V AKPABIO (2008) 17 NWLR
(Pt.1116) p.225 and AWUSE V ODILI (2005) 16 NWLR (pt.952)
p.416.

More recently the Supreme Court in SHINKAFI & ANOR V. YARI
& ORS (2016) LPELR-26050(SC) held that to prove over-voting,
the petitioner must do the following: 1. tender the voters’
register. 2. tender the Statement of Result in the appropriate
forms which would show the number of registered accredited voters
and number of actual votes. 3. relate each of the documents to the
specific area of his case in respect of which the documents are
tendered. 4. show that the figure representing the over-voting if
removed would result in victory for the petitioner. Note that the
Supreme Court decision above and other subsequent related decisions
do not recognize the card reader Report as a means of proving
over-voting. This is because the card reader requirement is not
part of the Electoral Act yet as the Act thereof only recognizes
the Voters’ Register.

Documents tendered in the course of proceedings, must be tied to
specific aspects of the case for which the documents are tendered
by leading evidence of the purport of the document in relation to
that aspect of the case. It is not the duty of the Tribunal to
speculate as to the purport of the documents or to forage in the
multitude of documents dumped by the petitioners’ counsel for the
purport of the documents. Dumping of documents on the Tribunal
without linking same to one’s case is fatal. See PDP
& Anor. v. Abari & Ors (2009)
LPELR-4835(CA).

Similarly, where a petition is premised on allegation of corrupt
practices, the requirement is even higher being a criminal
allegation, the particulars must be pleaded and proof is beyond
reasonable doubt. The law is that allegations of thuggery, violence
and hijacking election materials are criminal allegations which
must be proved beyond reasonable doubt. In ANPP V Usman 
(2008) 12 NWLR (Pt 1100) 1 @ 86, Aboki JCA stated the law thus: An
allegation of falsification of result is criminal in nature, the
position of the law is that it must be proved beyond reasonable
doubt. In Abdulmalik v Tijani (2012) LPELR-19731(CA) the Court
stated the ingredients for establishing fraudulent cancellations,
mutilations and alterations of electoral results with the following
words:

“It is trite that a Petitioner who based his case on fraudulent
cancellations, mutilations or alterations must establish two
ingredients, i.e.

1. “That there were cancellations, alterations or mutilations in
   the electoral documents, and
2. “That the cancellations, alterations or mutilation were
   dishonestly made with a view to falsifying the result of the
   election.

“The two ingredients must both be established together before
the result of an election can be cancelled on those grounds. “This
Court in Terab vs Lawan (1992) 3 NWLR Part 231 Page 569 at 594
Paragraphs C-D, held as follows: ‘While it is true that some of
these forms show that alterations and cancellations were made on
them, it has not been made clear at what stage the alterations and
cancellations were made . . . Falsification of results at the
election in December 1991 is a criminal offence which requires
proof beyond reasonable doubt.  See Nwobodo vs. Onoh (1984) 1
SC Page 1 at 118-119’.”

Similarly, allegation of alterations of results need to be
specifically pleaded to show at what stage the alterations was made
as was held in Terab vs Lawan (1992) 3 NWLR (Pt 231) 569. It is
suggested that allegation of crimes should be pleaded distinctly
from non-compliance allegation so that it will set a stage for
severance of pleadings at the pre-hearing session when necessary.
It is not uncommon to see petitioners applying for severance of
allegation of corrupt practices from those of non-compliance. The
Supreme Court has held in the case of Udom Gabriel Emmanuel v.
Umana Okon Umana & 5 Ors- (2016) LPELR-40659(SC) that the
appropriate avenue to apply for severance of pleadings is at the
pre-hearing session and not in the final written address or brief
of arguments as often done by some lawyers. Thus, clarity in
pleadings will aid the petitioners to severe when appropriate as it
will be a difficult task to severe pleadings where the allegation
of corrupt practices are inextricably intertwined with the
non-compliance such that severance becomes near impossible.

For a petition premised on the ground that the respondent did
not score the majority of lawful votes case, the Court in ANOZIE V.
OBICHERE (2006) 8 NWLR (PT 981) 140 AT 155-156 noted that it is an
invitation to compare and contrast figures. To establish the
complaint there must be proper tabulation of the registered voters,
the total number of votes cast, the votes scored by each
candidate.

Lastly, where the petition is on the ground of qualification, it
is submitted that the ground must be confined to qualification
under the Constitution. There is always the tendency to import the
provisions of the Electoral Act when challenging the qualification
of the Respondent to contest the election. The Tribunal and Courts
often frown at that. Distinction must be drawn between the
qualification that usually ground pre-election matters and the one
that supports election petition. In SAIDU V ABUBAKAR [2008] 12 NWLR
(PT 1100) 201 at 265 the Court of Appeal dealt with the issue of
qualification as a ground for challenging an election under section
145(1)(a) of the Electoral Act 2006 which is impari
materia with section 138(1)(a) of the Electoral Act 2010 (as
amended) when it held as follows:

“The question whether or not a person is qualified to contest an
election within the meaning of section 145(1) (a) of the Electoral
Act 2006 is to be determined exclusively by reference to the
constitutional requirements for qualification to contest.
THEREFORE, A PETITIONER CAN ONLY SUCCEED IN A COMPLAINT FOUND ON
SECTION 145(1) (A) OF THE ACT IF H ALLEGES FACTS AMOUNTING TO A
CONSTITUTIONAL BAR.” (Emphasis supplied).

The Electoral Act cannot expand the criteria for qualification
to contest an election under the constitution as such attempt is
null and void. See In ATTORNEY GENERAL OF ABIA STATE V ATTORNEY
GENERAL OF THE FEDERATION (2002) 6 NWLR (Pt 763) Pg 264.

Application for stay of proceedings not
relevant

Unlike in traditional civil matters where upon filing of an
appeal, the Appellant may apply for a stay of proceedings, the
situation is different in election petition proceedings. Paragraph
18 of the Practice Direction expressly provides that an
interlocutory appeal shall not operate as a stay of proceedings nor
form a ground for a stay of proceedings before a Tribunal.

Know the Rules

Litigation in election petition Tribunals and Courts are
governed by the electoral laws, Rules and Practice Directions.
Practitioners must take note of the relevant provisions of the
Constitution, Electoral Act, 2010 (as amended); Rules of Procedure
for Election Petitions, Election Petition Practice Directions,
2011; Court of Appeal Practice Directions for election Petition;
INEC Guidelines and Manuals and the Evidence Act, 2011. The Civil
Procedure Rules of various Court also apply where there is a lacuna
in the Practice Directions and Rules, For instance, the Federal
High Court (Civil Procedure) Rules 2009 applies at the Tribunal
level whilst the Court of Appeal Rules, 2016 and the Supreme Court
Rules, 1999 (as amended) apply on Appeal. Please note that election
petition Rules and Practice Directions are often reviewed from time
to time and it is important that litigants and their legal
representatives keep pace with developments in this area.

Conclusion

The season is here again for election petition galore and
lawyers who play in this space are already positioning themselves
for the juicy briefs. It is important that we appreciate the
peculiarity of the exercise and the rules that regulate the
proceedings. Instances where lawyers and even very senior lawyers
lose election cases on grounds of technicalities and mistake of
counsel should be minimized. Legal practitioners engaged in these
all-important exercise should demonstrate high level of dexterity
and adroitness in handling election petition as the stakes are high
and margin of errors should be low or non-existent. In the same
vein, judges engaged in election petition are encouraged to focus
more on substantial justice rather than technicalities often seen
in some of the decisions. It is suggested that the Tribunal members
should remove the garb of traditional civil matters and appreciate
the peculiarity of the election petition litigation particularly in
time management. For the neophytes, though the Rules and the
Practice Directions are there to guide all, there is no crime in
seeking assistance from experienced hands and where necessary
partnering with them to achieve clients’ objectives. Election
petition has nothing to do with the age of a lawyer at the Bar as
what counts is experience. I have seen and heard a very senior
lawyer argue confidently that the Evidence Act does not apply to
proceedings at the Election Petition Tribunal. His arguments
elicited not only laughter from the Tribunal chairman but also
earned him some scornful comments. Again, the point must be made
that the usual excuse of “mistake of counsel” given by lawyers in
ordinary civil matters may not avail litigants whose processes are
not proper before the Tribunal or Court. The Court of Appeal ably
and aptly percolated the principle that undergirds the strictness
and stringency of election petition proceedings in the case of GEBI
v. DAHIRU (2012) 1 NWLR (PT. 1282) 560 at 617 thus: “Due to the
special nature of election proceedings, any default in complying
with a mandatory procedural step which otherwise could either be
cured or waived in ordinary civil proceedings would have fatal
consequences in electoral proceedings.”

About the author:

Prince is a Lagos based lawyer with special focus on corporate
and commercial Litigation and Dispute Resolution. He was in the
team of lawyers involved in most of the highly-complex election
petitions arising from the 2015 general elections at the Election
Petition Tribunals and up to the Supreme Court.

2019 Elections:NIPR Calls for Inclusive
Government for Integration
The Nigerian Institute of Public Relations (NIPR) congratulates the
people of Nigeria on the successful conclusion of the 2019
Presidential Election.

We are pleased to note that for the first time in Nigeria, 73
candidates contested for the coveted Office of the President
Federal Republic of Nigeria. This is a remarkable testimony that
our democracy is becoming more popular and attractive. The high
number of candidates is also a clear demonstration of the increased
confidence, interest and willingness of citizens to contribute at
the highest level in the development of the nation. We commend the
Independent National Electoral Commission (INEC) for showing
considerable capacity in managing such high number of presidential
candidates.

We congratulate His Excellency, President Muhammadu Buhari,
GCFR, the candidate of the All Progressives Congress (APC), who was
declared winner of by the INEC. We also congratulate His
Excellency, Alhaji Atiku Abubakar, GCON of the People’s Democratic
Party (PDP), as well as the other 71 candidates and their political
parties, not only for their spirited efforts but also for towing
the path of peace in managing the outcomes of the elections. We
also wish to commend the relevant security agencies for the part
they played in ensuring the security of life and property in
different parts of the country.

We encourage any aggrieved candidates or parties to follow the
processes provided within the laws of the federation in challenging
the results. That is also an essential element of democracy. We
commend the main opposition candidate, His Excellency Alhaji Atiku
Abubakar for opting to follow the process of the rule of law than
allowing his followers resort to violence.

At the end of the day, the interest of the Federal Republic of
Nigeria should remain paramount. We urge Mr. President to walk his
talk of running an inclusive government, by taking decisive and
urgent steps towards national reconciliation, integration and
unity. May we always be reminded that, ‘though tribe and creed may
differ in brotherhood we stand.’

Being the foremost professional Institute responsible for
regulating, nurturing, grooming, promoting and deploying
appropriate public relations expertise in Nigeria, we urge the
federal government to always take advantage of this vital tool in
refining and enhancing the image and reputation of the country.

Mukhtar Sirajo
President, Nigerian Institute Public Relations (NIPR)