The Supreme Court reached a unanimous decision on 19 June to merge the two lawsuits launched against the Electoral Commission.
This move followed the EC’s decision to revise the voters’ register before the general election this December.
Asaase Radio publishes the consolidated writ that will be presented to the court later today.
IN THE SUPERIOR COURT OF JUDICATURE
IN THE SUPREME COURT OF GHANA
ACCRA – A. D. 2020
WRIT NO. J1/9/20
NATIONAL DEMOCRATIC CONGRESS PLAINTIFF
- ELECTORAL COMMISSION OF GHANA DEFENDANTS
WRIT NO. J1/12/20
H/NO. BN34, BREMAN KOKOSO,
- ELECTORAL COMMISSION OF GHANA
- THE ATTORNEY-GENERAL DEFENDANTS
STATEMENT OF CASE OF THE 2ND DEFENDANT IN WRIT NO. J1/12/2020
Respectfully, on 12th June, 2020, the plaintiff in Writ No. J1/12/2020, invoked the original jurisdiction of this Court for the following reliefs endorsed on his writ of summons:
- A declaration that upon a true and proper interpretation of article 45(a) of the 1992 Constitution of the Republic of Ghana the Electoral Commission’s constitutional and statutory mandate to compile the register of voters for the conduct and supervision of all public elections and referenda is spent saving only the power reserved in the Commission to revise and expand the register of voters at such periods as may be determined by law.
- A declaration that the Electoral Commission’s decision to compile a new register of voters is inconsistent with and a violation of article 45(a) of the 1992 Constitution of the Republic of Ghana.
- A declaration that Regulation 1(3) of the Public Elections (Registration of Voters) (Amendment) Regulations, 2020 (C. I. 126) is inconsistent with and violates the provisions of article 42 and 45(e) of the 1992 Constitution to the extent that it excludes Birth Certificates issued to Ghanaians as a mode of identification and/or establishing qualification to be registered in the register of voters.
- A declaration that Regulation 1(3) of the Public Elections (Registration of Voters) (Amendment) Regulations, 2020 (C. I. 126) is inconsistent with and violates the provisions of article 42 and 45(e) of the 1992 Constitution to the extent that it excludes the existing Voter Identification Card as a mode of identification and/or establishing qualification to be registered in the register of voters.
- An order directed at 1st Defendant to include under Regulation 1(3) of the Public Elections (Registration of Voters) (Amendment) Regulations, 2020 (C. I. 126) the existing Voter Identification Card as issued by 1st Defendant as evidence of identification.
- An order directed at 1st Defendant to include under Regulation 1(3) of the Public Elections (Registration of Voters) (Amendment) Regulations, 2020 (C. I. 126) a birth certificate as evidence of identification.
- Any other order or orders as to this Honourable Court may deem fit.
The institution of the instant action follows the hearing and adjournment by this Court for judgment of another suit WRIT NO. J1/9/2020 entitled NATIONAL DEMOCRATIC CONGRESS vrs. 1. THE ATTORNEY-GENERAL 2. ELECTORAL COMMISSION in which similar reliefs are claimed as in the instant action. In view of the commonality of the questions of fact and law that arise for determination in both suits, this Court on 19th June, 2020 ordered a consolidation of the two actions and subsequently ordered plaintiff to file his statement of case by 12 pm on Monday, 22nd June 2020 and the defendants by close of business on Tuesday, 23rd June, 2020.
For convenience, the first action by the National Democratic Congress (NDC) – Writ No. J1/9/2020 – will be referred to as the “First Suit”. The instant action is referred to as the “Second Suit”.
This statement of case will be prepared in the following order:
- Facts of Case.
- Observations on reliefs claimed by Plaintiff herein.
- Summary of 2nd Defendant’s case.
- Substantive arguments in opposition to the instant action
I. Does the Constitution require the 2nd Defendant to prepare the voters’ register only once
II. On the evidence, the register of voters is overbloated.
III. Regulation 1(3) of C. I. 126 is not inconsistent with articles 42 and 45(e) of the Constitution. as there will be no disenfranchisement of potential voters.
IV. An utilisation of old voter ID card and birth certificates will undermine the credibility of the register of voters and imperil the right to vote.
For the purpose of ensuring clarity in the presentation of the submissions, we will introduce various subheadings under the various topics, as and when necessary.
FACTS OF CASE
- In 2019, the 1st defendant herein determined that the register of voters on basis of which it performed its primary function under article 45(c) of the Constitution to “conduct and supervise public all elections and referenda” was not credible. 1st Defendant thus initiated steps to prepare a fresh register of voters for the conduct of elections in Ghana. It presented a programme to the Executive for release of funds for the exercise. The Executive approved the programme and included the required funding for it in the budget for 2020. The Parliament of Ghana, composed of representatives from plaintiff political party, invited the 1st Defendant to justify its programme. Parliament indeed approved the budget for a new register of voters after due justification by the 1st Defendant.
- The rationale for the preparation of a new register of voters was stated to Parliament as, to protect the right to vote and offer only qualified Ghanaians the opportunity to register and exercise their franchise as stipulated under Article 42 of the Constitution.
- The 1st Defendant on 15th March, 2020, laid before Parliament a constitutional instrument proposing an amendment to the Public Elections (Regulation of Voter Registrations, 2016 (CI 91). On 25th March, 2020, the proposed constitutional instrument was withdrawn. A fresh proposed constitutional instrument was laid again on the same 25th March, 2020. A day after the proposed constitutional instrument had been laid before Parliament, i.e. the 26th day of March, 2020, the NDC, plaintiff in the First Suit, filed its writ claiming the reliefs endorsed thereon. The proposed constitutional instrument on which basis the NDC filed its writ, was subsequently withdrawn by the Electoral Commission, 1st defendant herein on 31st March, 2020. However, the NDC did not withdraw its suit.
- Another constitutional instrument proposing an amendment to the Public Elections (Regulation of Voter Registrations, 2016 (CI 91) was subsequently laid in Parliament by the 1st defendant herein on 31st March, 2020. All through this, the NDC’s action, the First Suit, was still pending in this Court.
- On Wednesday, 10th June, 2020, the constitutional instrument entered into force after a debate by Parliamentarians and a vote thereon by Parliament and a consequent satisfaction of the mandatory twenty-one siting days stipulated under article 11(7) of the Constitution. The constitutional instrument, numbered as C. I. 126. C. I. provides thus:
“In exercise of the powers conferred on the Electoral Commission by Article 51 of the Constitution, these Regulations are made this………………day of……………….2020. Regulation 1 of CI 91 amended The Public Elections (Regulation of Voter Registrations, 2016 (CI 91) is amended in Regulation 1;
- by substituting for sub-regulation (3) of
“(3) A person who applies for registration as a voter shall provide as evidence of identification one of the following;
(a) a passport
(b) a national identification card or
(c) one voter registration identification guarantee form as
set out in Form One of the Schedule, that has been
completed and signed by two registered voters;” and
- by the substitution for sub-regulation (4) of
“(4) Despite paragraph (c) of sub-regulation (3), a registered
voter shall not guarantee the identity of more than ten
- It is the case of plaintiff that the 1st Defendant’s power to compile the register of voters is exercisable only once and that same is exhausted upon completion of compilation of the register of voters. Any fresh exercises can be only in the nature of a “revision” and not “compilation”. In effect, plaintiff contends that the only voter registration exercise lawfully embarked upon in this country is the one conducted in 1992 for the 1992 Presidential and Parliamentary elections. Plaintiff purports to rely on a distinction in meaning between the words “compile” and “revise” used in article 45(a) of the Constitution which stipulates thus:
“The Electoral Commission shall have the following functions –
- To compile the register of voters and revise it at such periods as may be determined by law”.
- Further, plaintiff contends that the exclusion of existing voter ID cards and birth certificates from being used as proof of identity for future registration purposes amounts to an invalidation of these cards. This act, according to plaintiff, is unreasonable and without any constitutional basis as it places an unnecessary burden on persons who have been duly registered as voters. A birth certificate is the primary evidence of citizenship and therefore, in the plaintiff’s estimation, its exclusion from the list of instruments to be used as means of identification, is unreasonable as it would deprive many Ghanaians of an opportunity to register. These birth certificate and voter ID card holders would now be required to have other persons vouch for them in the course of registration if they cannot present a valid passport or National ID card. Plaintiff avers that this is unreasonable.
OBSERVATIONS ON RELIEFS CLAIMED BY PLAINTIFF HEREIN
8. Respectfully, we observe that the instant action is materially and substantially the same as the First Suit filed by the NDC. The only difference is that, whereas the First Suit was filed at a time when there was no constitutional instrument in force and thus, that action was devoid of a cause of action, incompetent and clearly sinned against the stipulations of the Constitution as held by this Court in New Patriotic Party v. National Democratic Congress [1999-2000] 2 GLR 506, the instant action was filed at a time when there was a constitutional instrument validly enacted by the 1st defendant in accordance with article 11(7) of the Constitution and in pursuance of powers conferred on it by the combined effect of articles 45(a) and 51.
9. The Court will note that the only new reliefs plaintiff herein claims, and which are not part of the reliefs claimed in the First Suit, are the ones relating to the non-inclusion of a birth certificate as means of establishing qualification to be registered in the upcoming voter registration exercise. The first two reliefs claimed herein border on a challenge of the constitutional mandate of the 1st Defendant to compile a new register of voters, which was also claimed by plaintiff in the First Suit, albeit subsequently struck out by the Court as abandoned. Reliefs (iv) and (v) repeat the claim in the First Suit alleging unconstitutionality in relation to the non-inclusion of “the existing Voter Identification Card” as an instrument of identification in the upcoming voter registration exercise. Reliefs (iii) and (vi) introduce a challenge to the constitutional propriety of the non-inclusion of a birth certificate as means of identification in the voter registration exercise to be undertaken by 1st Defendant within a week from today.
10. It is our humble submission that the case for and against the non-inclusion of a birth certificate in C. I. 126 is the same as the case for and against the use of the “existing Voter Identification Card”. To that extent, all the arguments canvassed in opposition to the First Suit will hold in the instant case. In view of the joinder of both causes, the Court is urged to adopt mutatis mutandis all the submissions and material offered by the same defendants herein in opposition to the First Suit, in addition to the instant submissions and further evidence to be filed by both 2nd defendant herein in her affidavit in verification.
SUMMARY OF 2ND DEFENDANT’S CASE
- In these submissions, the 2nd Defendant will demonstrate, with irrefutable figures and statistics from recognised official sources, i.e. institutions and agencies of State, that:
i. The 1st Defendant has power to compile a new register of voters as such periods as may be prescribed by law. The claim that the power to compile a new register of voters is exercisable only once is outrageous, unreasonable and absurd.
ii. The current register of voters is overbloated and not fit for purpose. Statistics relating to the population of Ghana in 2012 and 2016 overwhelmingly support the proposition that the total numbers of registered voters recorded for those elections are most incredulous and inconceivable. The official population projections across all districts in Ghana as at June, 2020 rather render dubious and doubtful a contention that the current register of voters in Ghana is supposed to validly contain about 18 million names.
iii. Consequently, the right to vote is seriously impaired by the existence of an overbloated register of voters.
iv. Further, the three means of identification of an applicant for registration as a voter prescribed by C. I. 126 are most viable and potent to be deployed as means of registering the number of potential voters projected to be registered by the 1st Defendant in the voter registration exercise billed to take place from 30th June, 2020.
v. The use of voter ID cards issued in registration exercises subject to irregularities occasioned by, regulations which either did not comply with the constitutional safeguards of proof of eligibility, or regulations whose application was gravely compromised by the 1st Defendant, will neither reasonably improve the credibility of the current register of voters nor protect the right to vote.
vi. The use of birth certificates under the current circumstances where the authenticity of birth certificates and accuracy of information contained therein cannot reasonably be vouched for, will gravely endanger a due protection of the right to vote.
vii. The exclusion of the birth certificate and existing voter ID card does not imperil the right to vote. Regulation 1(3) of C. I. 126 is consistent with articles 42 and 45(e) of the Constitution as it assures that only Ghanaians of full age and sound mind register to vote.
SUBSTANTIVE ARGUMENTS IN OPPOSITION TO THE INSTANT ACTION
Does the Constitution require the 2nd Defendant to prepare the voters’ register only once?
- Respectfully, the first two reliefs claimed on the writ of summons raise the issue whether the power of the 1st Defendant under article 45(a) to compile a register of voters is exercisable only once. The plaintiff contends that the 1st Defendant exercised its power to compile a register of voters for the conduct of the 1992 Presidential and Parliamentary elections. In 1995, the 1st Defendant revised the register of voters which according to plaintiff, was deemed to have been compiled in 1992 by virtue of section 22(1) of the transitional provisions of the Constitution, 1992, after 1st Defendant has enacted the Public Elections (Registration of Voters) Regulations, 1995 (C. I. 12). Plaintiff submitted that “the effect of section 22(1) of the transitional provisions read together with article 45(a) of the 1992 Constitution, is that the compiled register given the 1st Defendant by the Constitution shall be revised at such periods”. Plaintiff thus submits that the power of the 1st Defendant to compile a new register of voters is spent, leaving only the power to revise. In essence, the only voter registration exercise lawfully embarked upon in this country is the one conducted in 1992 for the 1992 Presidential and Parliamentary elections. At paragraph 6.15 of his statement of case, plaintiff, without any authority, purports to rely on a distinction in meaning between the words “compile” and “revise” used in article 45(a).
- Respectfully, we find these submissions preposterous, absurd and strained. In our submission, we contend that there is no genuine issue of interpretation raised by the first 2 reliefs claimed by 2nd Plaintiff warranting an invocation of the original jurisdiction of this Court, in spite of the valiant effort of plaintiff to force a constitutional issue. The interpretation of the Constitution urged by plaintiff on the Court is implausible and unrealistic. The language of article 45(a) of the Constitution is clear and devoid of any ambiguity. Article 45(a) contains one unbroken sentence. The plaintiff, unjustifiably, seeks to break up the provision into two parts and submit that the words “at such periods as may be determined by law” is in reference to only the latter part of the sentence and not the earlier part thereof. This is unacceptable. We invite the Court to take account of the specific formulation of article 45(a) and the unavoidable indications provided by the provision itself to conclude that an attempt to fracture up the provision is totally unreasonable, far-fetched and unwarranted.
- In so submitting, we urge the Court to take due cognisance of the absence of any punctuation in article 45(a) to aid the Court in arriving at the conclusion that the framers of the Constitution clearly intended the words to be read together, and not broken up, fractured or disaggregated. Section 14 of the Interpretation Act, 2009 (Act 792) which this Court held in Ayine v. Attorney-General (unreported) 13th May, 2020, to be applicable for the purpose of interpreting the Constitution, stipulates that “punctuation forms part of an enactment and may be used as an aid to its construction”. The presence of a punctuation in article 45(a) in the nature of a comma or semi-colon, it is submitted therefore, could have formed a reasonable basis for the understanding of article 45(a) that Plaintiff seeks to foist on the Court. In the absence of same, it is submitted, that the provision should be read together. There is nothing therein suggesting otherwise. The Electoral Commission may in its discretion undertake both functions at such periods as may be determined by law. This is the ordinary and natural meaning of the words in article 45(a).
- The plaintiff’s understanding of the meaning of article 45(a), carefully looked at, is most implausible and defeatist of the primary object and purpose of the functions of the 2nd Defendant to conduct and supervise public elections in Ghana in an efficient and credible manner. The construction being placed on the plain words of the provision sins against the rule of interpretation firmly established in this Court as most helpful and constructive – the purposive approach. The Plaintiff rather advances the illogical and most far-fetched interpretation possible.
- Another reason why we submit that Plaintiff’s contentions are manifestly absurd is that, same flies in the face of the clear stipulations in article 297(b), (c) and (f) of the Constitution. In our submission, article 297 contains express stipulations to guide and aid an interpretation of the Constitution itself. In view of the fact that the Constitution is only required to set out in broad terms principles for the exercise of the powers of government and relationship between the various organs of State, and therefore cannot determine with the requisite degree of specificity the manner of the exercise of those powers, article 297 contains some principles to illuminate the provisions of the various Chapters of the Constitution. Article 297 provides thus:
“(b) where a power is conferred or a duty is imposed, the power may be exercised and the duty shall be performed, from time to time, as occasion requires;
(c) where a power is given to a person or authority to do or enforce the doing of an act or thing, all such powers shall be deemed to be also given as are necessary to enable that person or authority to do or enforce the doing of the act or thing;
(f) words in the singular include the plural, and words in the plural include the singular.”
- In our submission, article 297(b), (c) and (e) clearly reinforce each other and further buttress the point that the power of the 2nd Defendant to compile a voters register may be exercised from time to time, and not only once. Plaintiff owed a duty to read the Constitution as a whole, and not narrowly, if at all, before invoking this Court’s original jurisdiction and purporting to raise an issue of constitutional interpretation.
- The foregoing submissions underscores the fact that plaintiff merely transformed his misunderstanding of a constitutional provision into an action invoking the original jurisdiction of this Court. This highlights a growing tendency on the part of practitioners to invoke the original jurisdiction of the Court purely on account of their own palpably erroneous, strange and far-fetched construction of clear words int eh Constitution. In our submission, if this Court were to entertain an action for an interpretation of the Constitution on account of a clearly absurd meaning placed on some constitutional provisions, this Court will be flooded by hundreds, if not thousands, of actions purportedly invoking the original jurisdiction of the Court.
- This Court in Writ No. J1/14/207 James Kwabena Bomfeh v. Attorney-General (unreported), judgment dated 23rd January, 2019, upheld the submission of the Attorney-General that a constitutional issue is not raised on account of plaintiff’s absurd, strained and far-fetched understanding of clear provisions in the Constitution. A person cannot assert a manifestly absurd meaning contrary to the very explicit meaning and effect of clear words in the Constitution and expect this Court to find a genuine issue of interpretation to have been raised in his action.
- In Writ No. J1/28/2018 Mayor Agbleze & 2 Others vrs. 1. The Attorney-General 2. Electoral Commission (unreported) dated 28th November, 2018, when a plaintiff through a palpably strained interpretation of article of the Constitution, invoked the jurisdiction of the Court to challenge the creation of new regions, this Court per Kotey JSC (Prof) held, at page 9 of the decision that:
“The Plaintiffs must have misread or misunderstood the clear provisions made in the various clauses of Article 5 of the Constitution ….
If we were to accede to Plaintiff’s counsel’s invitation, the floodgate would be open for parties to place rival meanings on any provision of the Constitution and that alone should be sufficient to trigger this court’s interpretative powers, a step that would create chaos in the functioning of the Court.”
We respectfully pray for the Court to apply the ratio decidendi of these cases and dismiss the plaintiff’s claim that the power of the 1st defendant to compile the register of voters is exercisable only once, as utterly frivolous and not raising any genuine issue of constitutional interpretation.
ON THE EVIDENCE, THE REGISTER OF VOTERS IS OVERBLOATED
- Respectfully, we will in the course of this statement of case present submissions to show that the allegation of a potential disenfranchisement of voters as a result of Regulation 1(3) of C. I. 126, is at best speculative and conjectural. Presently, however, we are constrained to demonstrate that the current register of voters, having regard to the population of Ghana in the relevant years of 2012, 2016 and 2020, is overbloated, unreliable and grossly deficit in credibility. We hasten to say that the further endeavour on our part is without prejudice to the fact that the burden of proof lay on the plaintiffs herein to prove the material particulars of all the allegations made by them with sufficient clarity and substantial evidence.
Please see: Sections 11 (1) and 14 of the Evidence Act, 1975 (NRCD 323) as well as Asare-Baah III & Others v. Attorney-General & Electoral Commission  SCGLR 463.
- Further, article 297(d) of the Constitution having explicitly conferred on the 2nd Defendant the power to amend or revoke any constitutional instrument previously made by it, raises a presumption of regularity regarding an expression of regularity thereunder. For the avoidance of doubt, article 297(d) provides thus:
“where a power is conferred to make any constitutional or statutory instrument, regulation or rule or pass any resolution or give any direction, the power shall be construed as including the power, exercisable in the same manner, to amend or to revoke the constitutional or statutory instrument, regulation, rules of resolution or direction as the case may be.”
- Thus, having duly exercised the power conferred by article 297(d) to amend the Public Elections (Registration of Voter Regulations), 2016 (C. I. 91), through the laying before Parliament of a proposed constitutional instrument under article 11(7), a presumption of regularity is raised in respect of the instrument. A plaintiff before this Court who makes a claim of unconstitutionality, bears the full burden of proving each material allegation of unconstitutionality.
- The effort by 2nd Defendant to procure the relevant figures about the population of Ghana in the years 2012, 2016 and 2020 is merely out of a duty to assist the Court and not out of a desire to help plaintiff discharge his burden. By a letter dated 18th June, 2020, the Office of the Attorney-General enquired from the Government Statistician, Prof. Samuel Kobina Annim, statistics relating to:
i. The total population of Ghana as at June, 2020.
ii. Of the total population of Ghana, how many are Ghanaian citizens.
iii. Of the total population of Ghana, how many are Ghanaians aged 18 and above.
iv. The total population of Ghana in 2016.
v. Of the total population of Ghana, how many were Ghanaian citizens.
vi. Of the total population of Ghana, how many were Ghanaians aged 18 and above.
vii. The total population of Ghana as in 2012.
viii. Of the total population of Ghana, how many were Ghanaian citizens.
ix. Of the total population of Ghana, how many were Ghanaians aged 18 and above.
The enquiry made by the A-G is annexed to the affidavit in verification and marked Exhibit “AG 1”.
- By a reply dated 22nd June, 2020, the Ghana Statistical Service provided clear answers to all of the above questions. The reply from the Statistical Service provided categorical answers to all of the above questions across districts and all the sixteen (16) regions of Ghana providing figures for each. Same is attached to the affidavit in verification and marked as Exhibit “AG2”.
- The Court will see that for the year 2012, Exhibit AG2 shows that:
i. The total population of all ages of all persons in Ghana was 25,824,920
ii. The population of all Ghanaians (all ages) was 25,196,653
iii. The population of Ghanaians (18+) was 13,892,604
- For 2016, Exhibit AG2 shows that:
i. The total population of all ages of all persons in Ghana was 28,308,301
ii. The population of all Ghanaians (all ages) was 27,619,396
iii. The population of Ghanaians (18+) was 15,227,421
- For 2020 (showing projections as at June, 2020), Exhibit AG2 discloses that:
i. The total population of all ages of all persons in Ghana is 30,955,204
ii. The population of all Ghanaians (all ages) is 30,201,691
iii. The population of Ghanaians (18+) was 16,650,476
- Respectfully, the irrepressible conclusion from the official information about the population of Ghana given by the Statistical Service of Ghana, the body clothed with constitutional functions under article 186(2) of the Constitution to collect, compile, analyse and publish socio-economic data on Ghana, is that the register of voters since 2012 has been overbloated. Remarkably, this Honourable Court has had opportunity to receive evidence about the over bloated nature of our voters register. In In re: Presidential Election Petition; Akufo-Addo, Bawumia & Obetsebi-Lamptey (No.4) v. Mahama, Electoral Commission & National Democratic Congress (No.4)  SCGLR (Special Edition) 73, the Court heard evidence on the register of voters used for the 2012 Presidential and Parliamentary elections. In the judgment of Adinyira JSC, who concurred in the majority verdict dismissing the petitioners’ claims, it was noted that the register of voters initially given by the Electoral Commission to the various political parties showed a figure of 13,917,366 as the total number of registered voters. However, the total number of registered voters produced to the Court after cross-examination by the parties showed a figure of 14,168,890. This disclosed a difference of 241,524.
- In our submission, whether the total number of registered voters in 2012 was 13, 917, 366 or 14, 168, 890, the evidence from the Government Statistician undoubtedly showed that the register of voters was hugely overbloated, filled with ineligibilities and indeed, unconstitutional, to the extent that “Exhibit AG2” shows that the population of Ghanaians (18+) was 13,892,604. It is impracticable and unfeasible how all the various total number of registered voters produced by the Electoral Commission for 2012 can exceed the total number of Ghanaians aged 18 and above. Unmistakably, the Court will note that this clear evidence of overbloating of the register of voters was as a result of the registration of voters pursuant to the Public Elections (Registration of Voters) Regulations, 2012 (C. I. 72), whose implementation the Electoral Commission categorically varied with a Training Manual to its officers authorising the registration of persons who show up without proof of eligibility set out in the law.
- The awful spectacle of an overbloated register of voters continued to 2016, when the Electoral Commission announced a figure of 15,712,499 as the total number of registered voters, in the face of the clear evidence stated in “Exhibit AG2” – the official statistics from the Government Statistician, that the population of Ghanaians (18+) was 15,227,421. A figure of 15,712,499 can be seen on the website of 1st Defendant as the total number of registered voters for the 2016 elections. Respectfully, I ask the same question, how can the total number of registered voters exceed the population of Ghanaians aged 18 and above?
- The final analysis we make of Exhibit AG2 is that, the Court will note that the current projected population of Ghanaians (18+) as at June, 2020 is 16,650,476. Quite surprisingly, the plaintiff in the First Suit, the NDC, claimed at paragraph 64 of its Statement of Case that “in terms of the number of persons on the voter register and with issued voter cards, they are over 18,000,000”. We urge the Court is urged to totally disregard this wild and unfounded allegation by the NDC that about 18 million people are supposed to be on the register of voters. Same is one of the many baseless allegations of fact for which reason they strenuously come to this Court with the vile motive of protecting an incredulous register of voters. The credibility of the register of voters itself having been clearly refuted by the official statistics from the Government Statistician, the authority clothed with constitutional under article 186(2), none of the parties herein has any basis to bandy any unsubstantiated figure about or extrapolate that there is supposed to be over 18 million people.
- In all of the analyses we have made, we need to point out that it is definitely not all Ghanaians aged 18 and above who turn out to register to vote. In all democracies around the world, about 20% to 255% of those qualified to vote may not register to vote. So, in terms of those actually expected to be on the register of voters, we can safely conclude that for Ghana’s “registerable population” of 16,650,476, about 13,320,381 may be expected to be on the register of voters, a far cry from out the outrageous unfounded figure of 18,000,000 stated at paragraph 64 of the Statement of Case of First Plaintiff, the NDC.
- Respectfully, out of curiosity, we ask, how can the plaintiffs in these Consolidated Suits be enamoured of a register produced by a system patently flawed and potentially suppressive of the will of the Ghanaian voter? In our submission, every political party ought to be interested in a register of voters which has a greater likelihood of ensuring an upholding of the right to vote and thus, the will of the people. There, thus, can be no question about the legitimacy or importance of the State’s interest in undertaking a process which boosts the integrity of the register of voters. The state’s interest in an orderly administration and accurate recordkeeping provides a sufficient justification for carefully identifying and verifying the details of all applicants for registration with a system that can best assure of same. This Court reiterated this position in Abu Ramadan & Nimako (No.2) v. Electoral Commission & Attorney-General [2015-2016] 1 SCGLR 1, when it stated per Wood CJ, that there is the need to “safeguard the entire registration process” and protect it “…from underage persons, non-citizens and voter fraudsters alike, in order to avoid the process being perceived as flawed.”
- It was held in the United States case of William Crawford v. Marion County Election Board 553 U.S. (2008), that. “there was a real risk that voter fraud could affect a close election’s outcome.”
- Respectfully, we find it worthy to repeat observations made by us in our Legal Submissions filed on 8th June, 2020 in the First Suit, that the overbloating of our register of voters is largely attributable to the severe flaws and fundamental defects of the registration processes in 1995 and 2012. We have shown to the Court that the register of voters prepared in 1995 pursuant to the processes set out in C. I. 12 failed to satisfy the constitutional standard of proof of eligibility and thus lent itself to significant breaches.
- C. I. 72 of 2012 revoked C. I. 12 of 1995. Regulation 1 of C.I. 72 attempted to bring the eligibility criteria in compliance with article 42 of the Constitution. However, a major problem associated with registration conducted under C. I. 72 was the use of voter ID cards obtained under C. I. 12 as proof of identification of a potential applicant for registration to vote. This only resulted in a carryover of the flaws with C.I. 12. Thus, C. I. 72 only attempted a cosmetic cure for the palpable violation of the right to vote occasioned by C. I. 12 leaving the window wide open for ineligible voters to get on the register of voters prepared in 2012 through the use of cards obtained under C. I. 12 for registration under C. I. 72.
- Further, quite reprehensibly, the Electoral Commission set out to undertake the registration of voters by developing a Training Manual for the compilation of the new register of voters, which effectively relaxed the rules for registration and in fact, unlawfully operated as an unconstitutional amendment to C. I. 72. The following could be found at the said page 16:
…presenting a proof of eligibility is however not mandatory even though will help speed up the process.
- In effect, whereas I. 72 mandated a proof of eligibility, the 2nd defendant in instructions to its officers, authorised them not to demand a proof of eligibility in order to “speed up the process”. The sanctity of the registration process theoretically assured by Regulation 1 of C. I. 72 was therefore practically eroded “on the ground” by instructions given to officers of the 1st defendant.
- The fundamentally defective voter ID cards procured in 2012 were also utilised for limited registration exercises in 2014 and 2016. This is deplorable. Respectfully, we cannot continue like this, as a country. The 1st Defendant has expressed the resolve to make a clean departure from the past. We respectfully pray the Court to permit to do so in accordance with the procedures and regulations set out in C. I. 126.
REGULATION 1(3) OF C. I. 126 IS NOT INCONSISTENT WITH ARTICLES 42 AND 45(E) OF THE CONSTITUTION
- It is imperative to address the issue whether the enactment of C. I. 126 or any provision therein is constitutional. This, we find to be the most relevant, critical and crucial issue arising in this Consolidated Suit. In our submission, the power of the 1st Defendant to compile a register of voters using an instrument or instruments considered necessary by it, is unquestionable. In the submissions to be presented below, we will be guided by these three (3) hallowed principles:
i. The 1st Defendant in the discharge of its functions under the Constitution has one core principle – the protection of the right to vote embedded in which is the duty to ensure the sanctity of the electoral process in Ghana.
ii. The power of the 2nd Defendant to compile and revise the register of voters at such periods of time under article 45(a), may not be controlled by any person or authority, save in plain cases of unconstitutionality or a clear demonstration that the right to vote will be undermined.
iii. Any means of proving identity as a Ghanaian determined by the 1st Defendant in a constitutional instrument enacted by the 1st Defendant, to the extent that it ensures that only Ghanaians qualified to vote under article 42, will be perfectly constitutional, and same cannot be struck down by this Court as unconstitutional.
- We respectfully submit that underlying the above principle is the fundamental point that the Constitution does not determine or particularise which instrument of identification the 1st Defendant ought to utilise in registering voters. The Constitution does not specify which document(s) should be used by the 1st Defendant in the Second Suit in the discharge of its duties under article 45(a) to compile and revise the register of voters at such periods as may be determined by law. We observed in Legal Submissions filed on 8th June, 2020 that this Court in Abu Ramadan & Nimako (No.1) v. Electoral Commission & Attorney-General (No.1); Danso-Acheampong v. Electoral Commission & Attorney-General (Consolidated) [2013-2014] 2 SCGLR 1654 (simply referred to herein as Abu Ramadan No.1) and Abu Ramadan & Nimako (No.2) v. Electoral Commission & Attorney-General [2015-2016] 1 SCGLR 1 (simply referred to herein as Abu Ramadan No.2), which was the closest opportunity the Court had to spell rules for the 2nd Defendant’s article 45(a) function, in keeping with constitutional wisdom, stopped short at rightly failed to specifying the document(s) that may be used as an instrument of identification in a voter registration exercise. The Court left it to the independent discretion of the 1st Defendant, and in fact admonished the 1st Defendant to devise “mechanisms, structures, systems, processes and procedures must be such, as on balance, would guard, protect and preserve the sanctity and credibility of the rights guaranteed” under article 42, whilst underscoring the need to “safeguard the entire registration process” and protect it “…from underage persons, non-citizens and voter fraudsters alike, in order to avoid the process being perceived as flawed.”
- It is further submitted that in “Abu Ramadan No.2”, the Court in the judgments of Gbadegbe JSC and the concurring opinion of Benin JSC took full opportunity to clearly delineate the extent of judicial review powers it may exercise over the Electoral Commission and indeed, other constitutionally independent bodies, as well as the scope of independence of the Electoral Commission in respect of its various functions. At pages 30 – 31 of the report, also reproduced as holding (5), the Court per Gbadegbe JSC, stated thus
“…The court’s original jurisdiction thus enables it to determine the limits of the exercise of the repository’s powers. It is observed that in the exercise of the Supreme Court’s original jurisdiction, it was not permissible for the court to substitute its own decision for that of the body or persons exercising a discretion conferred on it by the Constitution. This is necessary to keep the court itself within its proper limits in order to give effect to the supremacy of the law, which appeared to be the foundation of the original jurisdiction. The court’s function is to set the limits on the exercise of the discretion, which by the decision made within these boundaries cannot be impugned”.
- At pages 36-39 (also reproduced as holding 10), Gbadegbe JSC, again had this very important and instructive statement to make:
“… By article 46, the first defendant Electoral Commission is endowed with independence in the performance of its functions ….
“In our opinion, and as part of the function to declare what the law is, the above words which are unambiguous insulate the Electoral Commission form any external direction and/or control in the performance of the functions conferred under article 45 …
A fair consideration of the functions of the first defendant Electoral Commission reveals that the demand which was made on its by the plaintiffs regarding the presence of ineligible and deceased persons and the latter’s refusal to acquiesce in the said demands, which provoked the action herein, relates to its mandate under article 45(a) of the Constitution… A careful scrutiny of the 1992 Constitution reveals that its functions under article 45(a) is not subject to any other provision. Therefore, in performing the said function, we cannot make an order compelling the Electoral Commission to act in a particular manner ….
In further consideration, we would like to refer to some specific provisions of the Constitution that have placed a fetter on the exercise of the independence bestowed on the first defendant Electoral Commission by article 46. …
The effect of the specific provisions in articles 47(1) and (5) and 48(1) and (2) is that where the Constitution intended the exercise of any of the functions conferred on the Electoral Commission to be subject to any other person or law, it is so provided. Accordingly, where no such provisions have been specifically made, the effect is that the Constitution intended the Electoral Commission to exercise its discretion without the control or direction of any person or authority.”
- Respectfully, the meaning and effect of the decisions of the Court in the two “Abu Ramadan” cases (cited supra) is that, this Court’s jurisdiction to declare acts and omissions by constitutionally independent bodies like the 2nd Defendant herein, extend to only decisions in respect of which a clear and obvious unconstitutionality has been established. In so far as a matter lies within the 2nd Defendant’s discretion, the only basis on which the Court may declare a choice made by it, is where that choice infringes the Constitution. Benin JSC in his concurring opinion, held at page 51 that:
“… even if there is provision in the law and/or regulations for validation, the court cannot compel the first defendant to follow that method unless it is the only mode that is sanctioned by the law or regulations. If the law provides for alternative ways of performing the task, the discretion is vested in the actor in deciding within the limits imposed by article 296 of the Constitution as to which one of them would best suit the task on hand.”
- In the circumstances, we respectfully submit that the Electoral Commission’s discretion to determine which instrument to use or how it may use it, in the upcoming voter registration exercise is not subject to the direction or control of this Honourable Court. The plaintiffs herein cannot, with the greatest respect, enjoin, the use of either the birth certificate or a so-called “existing voter ID card”, unless those instruments are the only lawful means of ensuring compliance with the Constitution. This is because, as already held by this Court, where the Commission has a number of lawful options available to it, this Court cannot compel recourse to a particular mode. The birth certificate and so-called “existing voter ID card” fall within the class of “alternative ways of performing the task” contemplated by Benin JSC in Abu Ramadan No.2. The discretion is vested in the Commission. One, respectfully, cannot compel recourse to them.
- Thus, the Electoral Commission may determine in its regulations that a particular document produced under any statute (for instance, a passport, a driver’s licence, national identification card, etc.) may be produced as evidence of identification for purposes of article 42. The 2nd Defendant may exclude any of these instruments too, if considered necessary by it. It may include an old voter registration card, or it may exclude same. That decision will be constitutionally valid, when taken in context of the factors spelt out herein. The history of the voter registration process in this country has shown that the Electoral Commission has freely exercised the function to decide which instrument(s) of identification it utilizes in the proof of eligibility of a Ghanaian citizen to vote. We proceed to illustrate this point.
- To start with, the Court will note the birth certificate has not been used as means of identification in any of the constitutional instruments enacted since the inception of the Constitution, 1992.
- Further, the Court will note that in 1995, when C. I. 12 was enacted, there was no use of any “existing voter ID card”. Same was introduced for the first time in 2012 when C. I. 72 was enacted. It however cannot be reasonably contended, and it has not been so ever suggested, that, the failure to specify an “existing voter ID card as an instrument of identification in C. I. 12, rendered that registration process unconstitutional.
- It is our further observation that the requirements for proof of eligibility set out in C. I. 72, bar the National Health Insurance Card, was adopted wholesale by C. I. 91. We however submit, respectfully, that the adoption of the various means of proving eligibility in C. I. 72 by C. I. 91 does not cast those requirements in stone. Neither do they become an unassailable yardstick or benchmark for a voter registration process in Ghana. The 1st Defendant’s quest to adopt means which can safely, and more credibly, ensure the sanctity of the register of voters must, with all respect, be upheld by this Honourable Court.
- In direct resolution of the issue whether or not Regulation 1(3) of I. 126 is inconsistent with articles 42 and 45((e) of the Constitution, we respectfully submit that C. I. 126 and all its parts fully satisfy the standard of constitutionality. In our humble view and in the spirit of intellectual honesty, we lay down 3 standards for the determination of constitutionality of a constitutional instrument enacted in pursuance of the constitutional duties of the 1st Defendant under article 45(a):
(a) Firstly, in accordance with article 51, the constitutional instrument must have been achieved compliance with article 11(7) of the Constitution.
(b) Secondly, at the pain of sounding repetitive, there is an implied duty to ensure a reasonably accurate and credible register of voters.
(c) Thirdly, the Commission ought to ensure that any document it settles on as proof of identity will reasonably guarantee that only Ghanaians of eighteen (18) years of age, and of sound mind, are registered to vote in consonance with article 42. In submissions below, we will demonstrate with facts and figures, that the impugned constitutional instrument, C. I. 126, reasonably provide an opportunity for all eligible voters to get on the electoral roll.
- The Court is respectfully urged to hold that C. I. 126 having satisfied the threshold spelt out above, is consistent with articles 42 and 45 (e) of the Constitution.
THE THREE (3) MEANS OF IDENTIFICATION IN C. I. 126 ARE REASONABLY CAPABLE OF PROTECTING THE RIGHT TO VOTE UNDER ARTICLE 42 OF THE CONSTITUTION AND THEREFORE, THERE WILL BE NO DISENFRANCHISEMENT
- Respectfully, we submit that, on the evidence, the 3 means of identification of an applicant for registration provided for by C. I. 126 are reasonably capable of protecting the right of a qualified Ghanaian to vote under article 42. The right to vote is thus not undermined or defeated at all by Regulation 1(3) of C. I. 126, which provides thus:
“(3) A person who applies for registration as a voter shall provide as evidence of identification one of the following;
(a) a passport
(b) a national identification card or
(c) one voter registration identification guarantee form as
set out in Form One of the Schedule, that has been completed and signed by two registered voters;”
- Out of a duty to this Honourable Court, by a letter dated 22nd June, 2020, the Office of the Attorney-General enquired from the National Identification Authority (NIA) the following:
i. The total number of Ghanaians who have enrolled for registration by the National Identification Authority (NIA).
ii. The total number of printed cards as of 22nd June, 2020.
iii. The total number of Ghanaians to whom national ID cards have been issued as of 22nd June, 2020.
iv. The total number of Ghanaians aged 18 and above to whom national ID cards have been issued by the NIA as of 22nd June, 2020.
- The letter is attached to the affidavit in verification as “Exhibit AG 3”. Having regard to the fact that the National Identity Register Act, 2008 (Act 750) as amended by the National Identity Register (Amendment) Act, 2017 (Act 950) permits the NIA to register Ghanaians aged 15 years, we specifically made an enquiry in relation to Ghanaians aged 18 and above.
- By a reply dated 23rd June, 2020, attached to the affidavit in verification as “Exhibit AG 4”, the NIA provided the following figures:
i. The total number of Ghanaians who have enrolled for registration by the National Identification Authority (NIA) is 11,228,137.
ii. The total number of printed cards as of 21st June, 2020 is 11,063,672.
iii. The total number of Ghanaians to whom national ID cards have been issued as of 21st June, 2020 is 10,644,735.
iv. The total number of Ghanaians aged 18 and above to whom national ID cards have been issued by the NIA as of 21st June, 2020 is 10,576,120.
- Respectfully, we have already indicated that it is not every eligible voter who actually registers to vote. About 20% of eligible voters actually do not turn up to register. Thus, out of Ghana’s “registerable population” of 16,650,476, it can reasonably be inferred that a figure of about 13,320,381, to err on the side of caution, about 14 million people will be expected to be on the register of voters. It can thus be safely be assumed that about 10,576,120 people on the register of voters will be catered for with the “Ghana cards”.
- This leaves a figure of about 3.3 million people, if we want to go by the reasonable projection of 13,320,381 likely registered voters, or 4 million, if we want to be very liberal or err on the side of caution. The official number of passports issued to Ghanaians aged 18 and above, per records from the Director of Passports, is 2,352,892. We readily concede that not all of these passport holders may be available to register to vote and some of them may also hold the NIA cards and thus will utilise only one of the instruments. Respectfully, we are prepared to be very conservative and submit that, if even only about 1,000,000 people out of the number of Ghanaian passport holders aged 18 and above utilise same to register, this will give a total figure of about 11,520,000 out of the projected voter population without an ID to be registered.
- C.I. 126 provides a means for all such potential voters to be registered. Respectfully, we submit, that on account of current official statistics from the Electoral Commission relating to the utilisation of the third means of identification, i.e. the “one voter registration identification guarantee form” prescribed by Regulation 1(3)(c), all potential voters will be registered. No one will be disenfranchised. Neither will there be a suppression of the right to vote.
- Recent statistics from the Electoral Commission obtained from voter registration exercises in 2014, 2016, 2018 and 2019 show irrefutably that, the “guarantor” system as we describe the process set out in Regulation 1(3)(c), is capable of registering a huge number of voters. The Court is invited to take judicial notice of the fact that the exercises in 2014, 2016, 2018 and 2019 were all limited registration exercises, and in these limited voter registration exercises, most applicants actually do not have any so-called “existing voter ID card” at all. The record, attached to the affidavit in verification as Exhibit AG 5, shows that:
i. In 2014, out of a total number of 928,540 registrants, 763,159 people registered using guarantors.
ii. In 2016, out of a total number of 1,046,067 registrants, 967,668 people registered using guarantors.
iii. In 2018, out of a total number of 37,929 registrants, 35,296 people registered using guarantors.
iv. In 2019, generally, out of a total number of 1,211,395 registrants, 1,151,912 people registered using guarantors.
v. In 2019 (for the referendum), out of a total number of 47,852 registrants, 47,634 people registered using guarantors.
- The foregoing record shows that in the various limited registration exercises, the rate of utilisation of the “guarantor” system was over 90%. In fact, as Exhibit AG 5 shows, there was minimal recourse to the use of an “existing ID card”. We thus submit, on the strength of unquestionable and incontrovertible documentary evidence that no potential voter will be disenfranchised in the contemplated voter registration exercise. On the contrary, C. I. 126 has made ample provision for all to register, including all those who do not have any of the two (2) national identity instruments specified therein.
- It goes without saying that official documentary evidence trumps bare assertions of fact, as plaintiffs herein have sought to make. The law recognises the supremacy of documentary evidence and considers same as the yardstick by which the veracity evidence will be tested. Whenever there was in existence a written document and conflicting oral evidence, the practice of the court was to lean favourably towards the documentary evidence, especially if it was authentic and the oral evidence conflicting.Please see the decisions of this Honourable Court in Agyei Osae & Others v. Adjeifio & Others [2007-2008] 1 SCGLR 499, Yorkwa v. Duah [1992-93] GBR 278 and Fosua & Anor v. Dufie (Decd) 2009 SCGLR 310
- It has been held that when documents are looked at by a judge and he pays due attention to the evidence adduced, the judge ought not to substitute his own independent judgment to any other form of evidence, even if coming form witness, be he an expert.Please see: the dictum of Lord Mcnaughten in the English case of Henessey v. Keating (1908) 421 L. T. R. 169. Also: the English case of Payton & Co. v. Snelling Lampard & Co (1901) AC 308.
- In the Nigerian case of Aiki v. Idowu  FWLR (Part 293) 361 per Alagoa JCA, who described the status of documentary evidence thus:“Documents when tendered and admitted in court are like words uttered and do speak for themselves. They are even more reliable and authentic than words from the vocal chords of man, because they are neither transient nor subject to distortion and misrepresentation but remain and indelible through the ages. They bear eloquent testimony to what happened.”
- We entreat the Court to disregard the submissions of both plaintiffs in the Consolidated Suits that the right to vote of the Ghanaian will be impaired or undermined as baseless, unsubstantiated and at best, speculative or conjectural. The plaintiff owed a duty to buttress their contentions with facts and figures from official sources in Ghana. This, they woefully neglected or refused to do. A court of law is bound to assess the veracity of allegations of fact made in suits on account of evidence presented. It is for this reason that we keep emphasising that any litigant invoking the original jurisdiction of this Honourable Court carries the burden of adducing cogent evidence in support of any allegation made by him/her.
UTILISATION OF OLD VOTER ID CARD AND BIRTH CERTIFICATES WILL UNDERMINE THE CREDIBILITY OF THE REGISTER OF VOTERS AND IMPERIL THE RIGHT TO VOTE, AND SHOULD THUS BE DISREGARDED BY THIS HONOURABLE COURT
- Respectfully, at pages 20 – 28 of the Legal Submissions filed by us on 8th June, 2020, and at some parts of this Statement of Case, we have demonstrated that the old voter ID cards procured from the flawed voter registration exercises in 1995, 2012, 2014 and 2018 will rather imperil and undermine the right to vote. For press of time, especially as we have had to file these submissions 24 hours since plaintiff herein filed his Statement of Case, we rely entirely on those submissions.
- We will further reiterate that the arguments for a rejection of the old voter ID card as a means of identification in the upcoming exercise are even more imperative in the case of the birth certificate. The Court ought to, respectfully, be remined of the constitutional principle that the Constitution does not enjoin the 1st Defendant to use a particular instrument of identification.
- The plaintiffs in the 2 Consolidated Suits have woefully failed to make out a case warranting a declaration of unconstitutionality of Regulation 1(3) of C. I. 126. The lawfully exercised discretion of the 1st defendant in specifying the manner in which it seeks to embark on its constitutional mandate enshrined in article 45(a) of the Constitution should be upheld.
LIST OF AUTHORITIES 1ST DEFENDANT INTENDS TO RELY ON
1st Defendant shall at the hearing, rely on the following reported cases:
- Opremreh v. Electoral Commission of Ghana & Attorney-General  2 SCGLR 1159;
- Abu Ramadan & Nimako (No.1) v. Electoral Commission & Attorney-General (No.1); Danso-Acheampong v. Electoral Commission & Attorney-General (Consolidated) [2013-2014] 2 SCGLR 1654
- Abu Ramadan & Nimako(No.2) v. Electoral Commission & Attorney-General [2015-2016] 1 SCGLR 1
- Ayine v. Attorney-General (unreported) 8th May, 2020.
- Asare-Baah III & Others v. Attorney-General & Electoral Commission  SCGLR 463;
- Writ No J1/28/2018 Mayor Agbleze & 2 Ors v The Attorney General & the Electoral Commission, (Unreported) 28th November, 2018
- Writ No J1/14/2017 James Bomfeh v Attorney General (Unreported) 23rd January, 2019
- Ransford France (No.1) v Electoral Commission and Attorney-General  1 SCGLR 689
- J.H. Mensah v. Attorney-General [1996-1997] SCGLR 320.
- Apaloo v. Electoral Commission [2001-2002] SCGLR 1
- Danso v. Daaduam II & Another [2013-2014] 2 SCGLR 1570
- Tuffour v Attorney General  GLR 637
- National Media Commission v. Attorney-General  SCGLR 1
- New Patriotic Party v. New Democratic Congress [1999-2000] 2 GLR 506
- Osei-Boateng v. National Media Commission and Appenteng  2 SCGLR 1038
- Bimpong-Buta v. General Legal Council and Others [2003-2004] 2 SCGLR 1200
- Republic v. Special Tribunal; Ex Parte Akosah  GLR 592
- Kuenyehia v. Archer [1993-94] 2 GLR 525
- Agyei Osae & Others v. Adjeifio & Others [2007-2008] 1 SCGLR 499,
- Yorkwa v. Duah [1992-93] GBR 278
- Fosua & Anor v. Dufie (Decd) 2009 SCGLR 310
- Henessey v. Keating (1908) 421 L. T. R. 169
- Payton & Co. v. Snelling Lampard & Co (1901) AC 308
- William Crawford v. Marion County Election Board 553 US (2008)
DATED AT ATTORNEY-GENERAL’S CHAMBERS, ACCRA THIS 23RD DAY OF JUNE, 2020
Godfred Yeboah Dame
For: THE ATTORNEY-GENERAL
- The above-named Plaintiff or his lawyer, COSMAS MWEYANG ANPENGNUO, Bayong Law Consult, Flat No. 23, Oroko Avenue, Kokomlemle, Accra;
- 1st defendant or its lawyer, JUSTIN A. AMENUVOR, ESQ., Amenuvor & Associates, Accra.
AND ALSO TO: Counsel for plaintiff in Writ No. J1/9/2020, GODWIN KUDZO TAMEKLO, Ayine and Felli Law Offices, East Legon, Accra.
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