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THE EFFECT OF BIAS ON A JUDGE

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On the subject of bias, I make bold to say that the allegation once made is a serious one. This in my opinion is more serious because in this instance, the integrity of the Judge is being attacked. The language of bias is indicative of a deliberate action by the Judge to look outside the law and the facts to decide a matter. Accusing a judicial officer of bias is to say that the judicial officer is not fit to take over the responsibility of such great honour and a direct affront to the oath of office that he took on the day he was sworn in. In fact, a Judge is a representative of God on earth and therefore should imbibe the principle of justice and therefore jealously guide this divine calling. To be a judicial officer takes more than knowledge of the law and been intelligent but must more requires good character in both the strict and general sense of the word. An appeal on grounds of bias is a challenge on the character, the integrity of the judicial officer. It is a challenge that takes away from him the covering of decency as a judicial officer. I am going into all that to drive home the point that lawyers should be very careful in accusing a judicial officer of bias except when there is convincing evidence to buttress that. I make bold to say that the time has come for disciplinary action to be taken against lawyers who accuse a Court or Judge of bias which he can not establish. Once a Court has been accused of bias, unfortunately it cannot be taken back and no matter how clean the judicial officer is, there is a dent on his integrity even if it is by one person who earlier held him in high esteem. – EBIOWEI TOBI, J.C.A. Abdul v. State (2021)

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NIGERIAN JUDGES AND POLITICIANS MUST NOT BE FOUND MINGLING

I see from Exhibit EP2/34 the need for Nigerian Judges to maintain a very big distance from politics and politicians. Our Constitution forbids any mingling. As Judges, we must obey the Constitution. The two professions do not meet and will never meet at all in our democracy in the discharge of their functions. While politics as a profession is fully and totally based on partiality, most of the time, judgeship as a profession is fully and totally based on impartiality, the opposite of partiality. Bias is the trade mark of politicians. Non-bias is the trade mark of the Judge. That again creates a scenario of superlatives in the realm of opposites. Therefore the expressions, “politician” and “Judge” are opposites, so to say, in their functional contents as above; though not in their ordinary dictionary meaning. Their waters never meet in the same way Rivers Niger and Benue meet at the confluence near Lokoja. If they meet, the victim will be democracy most of the time. And that will be bad for sovereign Nigeria. And so Judges should, on no account, dance to the music played by politicians because that will completely destroy their role as independent umpires in the judicial process. Let no Judge flirt with politicians in the performance of their constitutional adjudicatory functions. When I say this, I must also say that I have nothing against politicians. They are our brothers and sisters in our homes. One can hardly find in any Nigerian community or family without them. There cannot be democracy without them and we need democracy; not despotism, oligarchy and totalitarianism. They are jolly good fellows. The only point I am making is that their professional tools are different from ours and the Nigerian Judge should know this before he finds himself or falls into a mirage where he cannot retrace his steps to administer justice. That type of misfortune can fall on him if the National Judicial Council gets annoyed of his conduct. Ours are not theirs. Theirs are not ours. I will not say more. I will not say less too. So be it.

— Niki Tobi, JSC. Buhari v. INEC (2008) – SC 51/2008

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INTERPRETATION FOR THE APPOINTMENT & REMOVAL OF JUDICIAL OFFICERS

It is for the foregoing reasons that I hold the view that in the resolution of the issue at hand, the entire provisions of the 1999 Constitution in Sections 153(1)(i)(2), 271(1), 292(1)(a)(ii) and paragraph 21 of Part 1 of the Third Schedule to the Constitution of the Federal Republic of Nigeria 1999 dealing with the appointments removal and exercise of disciplinary control over Judicial Officers, must be read, interpreted, and applied together in resolving the issue of whether or not the Governor of a State and the House of Assembly of a State can remove a Chief Judge of a State in Nigeria without any input of the National Judicial Council.

– Mahmud, JSC. Elelu-Habeeb v. A.G Federation (2012)

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IF GOVERNOR IS ALLOWED TO APPOINT & REMOVE JUDICIAL OFFICERS WITHOUT NJC

If the Governor alone is allowed to, in exercise of his Executive power, appoint directly, and discipline judicial officers of his State, this may, no doubt, lead to avoidable corruption and prevent judicial officers from carrying out their functions freely and without any intimidation by the Executive. Judicial Officers may become stooges of the Governor of the State for fear of been removed from office unceremoniously.

– PETER-ODILI, JSC. Elelu-Habeeb v. A.G Federation (2012)

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WHEN A JUDGE SITS BOTH AS A JUDGE AND JURY

It is quite another thing when a Judge sits both as trial – Judge and jury. In this connection we draw attention, with approval, to the observations of the West African Court of Appeal in R. v. Adebanjo & ors. (1935) 2 WACA 315: “…..We think it (is) going altogether too far to demand that a Judge, sitting as both judge and jury, should commence his judgment by directing himself as to the burden of proof, the doctrine of reasonable doubt, and the elements which constitute the offences with which the accused is, or are, charged. To our minds it must be presumed that a learned Judge, sitting as both Judge jury, has directed himself aright in matters of law unless the contrary appears from the judgment……..” (Underlining supplied by this court) – See (1935) 2 WACA at P. 321 per Atkin, J.

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DUE PROCESS FOR REMOVAL OF A STATE JUDGE

This is because any exercise of power to remove a Chief Judge must be based on his:
1. Inability to discharge the functions of office or appointment;
2. The inability to perform the functions of his office could arise from infirmity of the mind or of body;
3. For misconduct or
4. The contravention of the code of conduct.
All these conditions or basis for the exercise of power to remove a State Chief Judge must be investigated and confirmed by credible evidence and placed before the Governor and the House of Assembly before proceeding to exercise their power of removal granted by the Section of the Constitution.

– Mahmud, JSC. Elelu-Habeeb v. A.G Federation (2012)

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FOREKNOWLEDGE OF FACT CONSTITUTES BIAS

Foreknowledge of fact in such circumstance is an aspect of bias, as he did not come to the dispute with an openness of mind that would enable him to hold an even scale and he should therefore have been disqualified from hearing the appeal.

– O.O. Adekeye, JSC. Womiloju v. Anibire (2010) – SC.211/2002

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