Preserving an unchecked immunity clause in our constitutional democracy is like building a wooden house in the midst of the wild jungle and expecting to keep snakes out - Olufemi Franklin Olufemi, M.P.
This is definitely one of the most controversial subject for discuss in most jurisdictions around the world where Immunity reigns supreme or use to reign. It is yet an issue that should be continuously debated till lasting solutions are provided to the several nudging questions confronting us on the continued usefulness and viability of the subject matter: Immunity. Coming on the heels of recent developments in Nigeria where the Nigerian President, President Mohammadu Buhari recently signed into law, a Bill seeking Legislative Immunity for all lawmakers cited as Legislative Powers and Privileges Act 2018 amongst others, there is no better time to re-examine this principle than now.
This law effectively grants the National Assembly and State House of Assembly enormous and as it seems unqualified protection from all sorts of litigation in their line of duty not taking cognizance of certain wrongful and criminal acts that may arise from their actions or omissions which though done in their line of duty may nonetheless be ultra vires, that is beyond their scope of authority which may result in a culture of impunity all over again. There continues to be a need to check persons conferred with power to ensure such powers are not abused. This protection is uncharacteristically enormous and some have given it certain political coloration with other motives. This assumption this writer does not intend to pay undue attention to.
A comprehensive appraisal of the Law as it relates to the Subject matter of our discussion has reflected above, that is, Immunity, requires a clinical dissection of the various facets of the discussion for a complete understanding of it. This writer seeks to address this matter from seven (7) different perspectives thereby getting to the complete picture. These are:
· The Historical Antecedent
· The Rule of Law notwithstanding....
· The Constitutional perspective
· Immunity as a Shield and not a Sword
· The present day trend on the subject matter
According to the Blacks' Law Dictionary, Immunity is defined as "Exemption, as from serving in an office, or performing duties which the law generally requires other citizens to perform e.g. exemption from paying taxes. Freedom or exemption from penalty, burden or duty.
Under the 1999 Constitution, however, the immunity conferred on persons as construed in the immunity clause under section 308 may be characterizing as an executive form of immunity. This writer will not belabor the definition has it is a fact that definitions in the legal parlance varies with schools of thoughts and legal jurisprudence. I will just go straight to the subject of discussion.
The concept of immunity is deeply rooted in the historical fiber of our Legal system both the received laws and our traditional and indigenous laws as well. It is an ancient norm and acceptable practice applicable to the English Monarchical System and validated by common Law as well as in Kingdoms that today make up the Federal Republic of Nigeria.
It is a Principle of Law at common Law that the Queen cannot be brought before her own Court. This is because the Courts were ultimately under the full supervision of the Queen and so asking her to appear before her own Court is tantamount to making her a Judge in her own course. Thus, she naturally had immunity by reason of her royalty.
The United States of America's Constitution states that the "executive Power shall be vested in a President." Art. II, § 1. [The Founders] sought to encourage energetic, vigorous, decisive, and speedy execution of the laws by placing in the hands of a single, constitutionally indispensable, individual the ultimate authority that, in respect to the other branches, the Constitution divides among many. 520 U.S. at 711-12. The burdens imposed on a sitting President by the initiation of criminal proceedings (whether for official or unofficial wrongdoing) therefore must be assessed in light of the Court's "long recogni[tion of] the 'unique position in the constitutional scheme' that this office occupies." Id. at 698 (quoting Nixon v. Fitzgerald, 457 U.S. at 749)."
In the regions that now make up the Federal Republic of Nigeria before the advent of the colonialist; this was also mostly the case. A good example can be found in the Yoruba Kingdom where the Kings are regarded as "KABIYESI" a Yoruba word that means literally "The One that cannot be questioned". It is believed traditionally that the Kings are the mouthpiece of the gods and therefore occupies a very exulted position above all the people of the Land. This makes them the Judge and the last hope of the people and their Palaces usually double as a Courtroom with the King presiding where the need arises.
THE RULE OF LAW NOTWITHSTANDING.....
Despite these historical facts that are very responsible for the present constitutional provisions as can be gathered from section 308 of the 1999 Constitution of the Federal Republic of Nigeria (As amended), it must yet be observed that these privileges conferred upon Kings and Queens by reason of their enormous powers making them seem like demi gods because of their unquestionable tendencies was not absolute in application. The legal principle of rex non potest peccare (the king can commit no wrong). As the king enjoyed absolute immunity, he could neither be impeded in his own courts nor subject to any foreign jurisdiction. Maneleus of Sparta confirmed that the king was above the law of the Realm, when he said "when a king takes spoils, he robs no one; when a king kills, he commits no murder, he only fulfills justice."
According to Bracton, the King ought not to be subject to any man except to God and the Law because it was the Law that made him King. What this means is that in both jurisdictions discussed above, there is always a way to bring the King to comply with the Laws or sanction any radical departure from what is allowable or permitted by law or tradition. In these cases, drastic measures are taken by persons so empowered to either keep the King in check or punish his excesses. Hence, even the King is in the end subject to the Law.
The English Example
In medieval England, we know of what became of King John. King John was haughty and proud and reduced all his subjects to slaves and treated them like lesser men. The Lords, Knights, Barons and Chiefs were not spared the Kings wrath as he treated them all with disdain.
As a result of the harshness and abuse, the people with the cooperation of the Lords and particularly Barons ambushed him along the path of the Runnymede, a stream by which the King usually rides. There the King was accosted and compelled against his will to sign the first Human Right Document of all times, the "Magna Carta" or the "Great Charter of the Liberties". This first English Bill of Rights though did not tamper with the Crown Immunity, it succeeded in creating parallel rights for the people thereby limiting and curtailing the excesses of the King which he obviously cannot be held answerable for still. According to The History Learning Site,"Magna Carta was an attempt by the Barons to stop a King - in this case John - abusing his power with the people of England suffering". The effect was to prevent the Crown from excesses that cannot be cured once committed. This timeless piece has become a significant symbol of individual rights and protection of personal liberties heralding other laws both municipal and international that came after it. It also enjoys a place of reference both in the English and American jurisprudence till date. It was a viable method and it performed its office for as long as it possible.
Ever since this Great Charter of the liberties of England otherwise known as the Magna Carta of 1215 there has been constant Conflicts between the Monarch and the English subjects. Originally it was the Barons who fought the Monarch against taxation, and later the Parliamentarians who fought for the privilege not to be prosecuted by the Monarch for anything they say in the course of performing their legislative duties especially while on the floor of Parliament.
Legal principles were established by acts of parliament taking the forms of privileges and other guises of protection such as the Paliamentary immunity in the cause of their duties emerged as well intended to be in public interest. However, the laws keep changing in England today and proper measures have been put in place to check the excesses of public officers whilst also protecting them from a flood of cases or litigations thereby disturbing the performance of their public duties. There's been a deliberate act of striking the balance and achieving some level of sanctity in public offices.
The Old Oyo Empire
According to the Old Oyo empire, notoriously regarded as the Political Capital of Yoruba Land and having a well structured Political system comprising of the Alaafin who is the King (the Kabiesi - the One that cannot be questioned and answers to none), His Chiefs-in-Council and Baales-Land owning Chiefs and Sovereign within their Lands, the Oyomesi (The Kingmakers) the Aree Ona Kankafo (the Field Marshal of all Generals and Armies of Yorubaland), the Basorun, the Balogun - usually a High Ranking General amongst others.
The King by virtue of his position can do so many things and get away with it including forcibly marrying any maiden in the kingdom as he could marry as many wives as he wishes.
Whenever the King wielding this great power of the unquestionable ruler commits a major blunder that is abhorred customarily and traditionally even for a king, a chain of events is set in motion and the law eventually takes its course. The seemingly "Almighty" Alaafin upon committing a blunder will be confronted by the Oyomesi and told his offence upon which he will also be sanctioned accordingly either by sending him off on exile or asking him to commit suicide as custom demands in order not to face the shame of punishment depending on the degree of his calamity or offence. The throne must not be subjected to shame or ridicule by the misdeeds of one King even if it would cost him his life defending the honour of the throne, then he must give it up.
In view of the above, it can be safely deduced that though these Kings were Lords of their time and immune from doing any wrong "The King can do no wrong" both from the English and the African Oyo Examples above, it can be observed that the Rule of Law still had a supervening effect on them and brought them to submission when the need arises. This brings to mind the popular Dictum of Lord Justice Denning M.R when he declared thus: "Be ye ever so high, yet the Law is above you!"
THE CONSTITUTIONAL PERSPECTIVE
Upon the creation of the Nation - State, Nigeria, it became necessary that a peoples' constitution ( the Grundnorm) and other bodies of laws be made for the ordering and proper governing of the region. Most of the English laws were carried over and received into the Nigerian Legal system even after independence and codified into the pages of our statutes as Laws of the Federation of Nigeria. Although the absolutist powers of the king were swept away by the Glorious Revolution in England discussed partly above (i.e, the Magna Carta), the immunity of the Crown was left intact. Thus, by virtue of the Crown Proceedings Act, the king was totally absolved of vicarious liability with respect to the tortious acts of his agents or servants. This was affirmed in the decision before the King's Bench in the case of Roper V. Public Works Commissioner (1905) I.K.B. 45. The Crown Proceedings Ordinance, the Petition of Rights Ordinance, the Public Officers Protection Ordinance amongst others form a body of legislation which embodied the essentials of state immunity and which were subsequently imposed on Nigeria by the British colonial regime, hence the origin of the Immunity law in Nigeria.
The Country's turbulent political History is responsible for the coming and going of different constitutions over the years applicable to different dispensations. The most recent of these is the 1999 Constitution of the Federal Republic of Nigeria, amended in 2011. These constitutions are largely repetitious in nature though with certain clear differences or amendments. However, one provision that has always been part of the Nigerian Constitutional Law is the Law pertaining to Executive Immunity. It is provided for in Section 308 of the 1999 Constitution.
Section 308 states that:
RESTRICTION ON LEGAL PROCEEDINGS
 Notwithstanding anything to the contrary in this constitution, but subject to subsection  of this section -
[a] No civil or criminal proceedings shall be instituted or continued against a person to whom this section applies during his period of office;
(b) a person to whom this section applies shall not be arrested or imprisoned during that period either in pursuance of the process of any court or otherwise; and
(c) no process of any court requiring or compelling the appearance of a person to whom this section applies, shall be applied for or issued:
Provided that in ascertaining whether any period of limitation has expired for the purposes of any proceedings against a person to whom this section applies, no account shall be taken of his period of office.
(2) The provisions of subsection (1) of this section shall not apply to civil proceedings against a person to whom this section applies in his official capacity or to civil or criminal proceedings in which such a person is only a nominal party.
(3) This section applies to a person holding the office of President or Vice-President, Governor or Deputy Governor; and the reference in this section to "period of office" is a reference to the period during which the person holding such office is required to perform the functions of the office.
Constitutionally immunity exists in a tripartite form, that is, Executive Immunity, Legislative Immunity and Judicial Immunity. These types of immunity are not only different on the basis of their nomenclature but they also take different forms and extents.
The executive immunity under section 308 of the 1999 Nigerian Constitution (as amended) and its effect in perpetuating executive corruption in Nigeria. This immunity clause protects the President, the Vice-President, State governors and their deputies from civil and criminal prosecutions while they hold the above public offices. This is to enable them to do their Job properly without fear or let
Legislative immunity is a system in which members of the Parliament or the legislature are granted partial immunity from prosecution from civil or criminal acts particularly action for slander or libel whilst performing their duties in parliament. Today, nowhere in the world are members of legislative Houses not given some level of protections or immunity from legal proceedings. Most protections are against arrest or being sued for defamation for anything said or done in the course of performing legislative duties on the floor of the house.
The Legislative Powers and Privileges Act has conferred limited immunity, powers and privileges on the members of the National Assembly in the performance of their legislative duties. Specifically, they are immune from civil or criminal proceedings in respect of deliberations and comments made by them in the course of proceedings in the parliament.
Judicial immunity also like the Legislative Immunity protects the Judicial officer of any annoyance or legal action that may arise against him in the process of carrying out his judicial assignment as an independent arbiter and an epitome of justice. This is intended to reinforce the strength of an independent judiciary thereby protecting the sacred seat of justice from any form of threat or distraction.
Section 6 of the 1999 Constitution (as amended) vests the judicial powers of the State are in judges. Judges must not be respecters of persons, hence, the law establishing each of courts provides that judges shall not be held liable for any act done in the discharge of their judicial duties. Thus, judges are absolved of all civil or criminal liability whether by reason of negligence or errors made in the course of discharging their functions. Dissatisfied parties can exercise their rights of appeal to higher courts for redress. It is however noteworthy that despite this reality, the National Judicial Council is saddled with the responsibility to investigate allegations of misconduct against judges and recommend appropriate sanctions to the appointing authorities where such allegations are proven as true.these sanctions are usually effective depending on the misconduct committed.
It is also worthy of note that by virtue of the Diplomatic Immunities And Privileges Act, every foreign envoy and every foreign consular officer, the members of the families of those persons, the members of their official or domestic staff, and the members of the families of their official staff, are accorded immunity from suit and legal process in Nigeria. This is to give credence to the fact that though they be located within Nigeria, they are technically deemed to be standing on their home country's soil thus answerable to the laws governing their home country.
IMMUNITY AS A SHIELD AND NOT A SWORD.
In the Nigerian Political arena, it has become evident that the concept of immunity is being abused by corrupt political leaders who perpetuate corruption with impunity and thereafter hide under the cloak of immunity. This has become a worrisome development for Lawyers, Human Right Activists, Social Crusaders and all other stakeholders in the Nigerian Dream project as Immunity has suddenly become an un-noble shell militating against just and good governance.
Since Nigeria attained independence in 1960, the country has suffered greatly as a result of the overwhelming corruption of both military and civilian political leaders who often hide under the beguiling mask of Nationalist to perpetuate their evil. A renowned Nigerian author, Professor Chinua Achebe of Blessed memory, squarely located the source of corruption in the country in the political class. Accordingly, he stated that:
"the trouble with Nigeria is simply and squarely a failure of leadership...... The Nigerian problem is the unwillingness or inability of its leaders to rise to the responsibility, to the challenge of personal example which is the hallmarks of true leadership".
The framers of our Constitution must have deliberately planted immunity in our Constitution to avoid distracting our leaders from the very serious business of providing dividends of democracy to their people. There is no reason to fault the nobility of this idea which serious-minded leaders in naturally would use to better the lot of their people. After all, the whole idea of government is to be for the good of the governed and not for the "Governor".
Unfortunately in Nigerians, it has become evident over the past decades till date that the restriction on legal proceedings on our elected public servants cum 'big men' have become a licence for some of them and regrettably most of them to behave like unaccountable men. Bare-faced looting of our common patrimony is done under the protection of the 'immunity clause' as we all now popularly known it to be called. Even when it is very obvious to the governed that their collective resources are being mindlessly squandered by the very people that are sworn to be custodians of these resources, yet there is very little or nothing left for them to do that to cry out like the Ghanaian Writer, Ayi Kwei Armah that the Beautiful Ones Are Not Yet Born But Rather, We Are Beseiged By A Team Of Chichidodos Day After Day.
Obviously, an increasing number of our elected leaders have found a perfect weapon in section 308 of the constitution to commit all manner of atrocities against their people and still walk freely. Few years ago, the Legendary Chief Gani Fawehinmi of blessed memories fought the battle against this impediment called immunity from the High Court to the Supreme Court where he insisted that though the then Governor of Lagos State was immune from prosecution, he is not immune against investigation. This argument was put forward in the case of Fawehinmi V. Inspector General of Police. It marked the turning point in the Law on this subject matter as the Supreme Court held that the Constitutional provision though protects a public officer from prosecution does not necessarily shield him from investigation. The court held succinctly below:
Chief Gani Fawehinmi vs. Inspector General of Police per Honourable Justice Uwaifo JSC (Rtd) - (2002) 7 NWLR (Pt. 767) 606, (2002) 5 S.C (Pt. 1) 63, (2002) All NLR 357, (2002) 23 WRN 1:
"That a person protected under section 308 of the 1999 Constitution, going by its provisions, can be investigated by the police for an alleged crime or offence is, in my view, beyond dispute. To hold otherwise is to create a monstrous situation whose manifestation may not be fully appreciated until illustrated......The evidence may be useful for impeachment purposes if the House of Assembly may have need of it. It may no doubt be used for prosecution of the said incumbent Governor after he has left office. But to do nothing under the pretext that a Governor cannot be investigated is a disservice to the society."
However, it is noteworthy from the above that the Supreme Court was equally very careful and clinical in reaching this decision. The Apex Court tried not to negate the spirit of Section 308 of the constitution but by some judicial activism created an ample opportunity for an investigation to be conducted successfully even into the Bank Account of a sitting Governor to determine if proceeds of corruption have been lodged in. The Law Lords also suggested that discoveries from these investigations can be used as evidence to lawfully proceed against such Governors or persons concerned either by way of impeachment or by waiting patiently to prefer charges upon the expiration of their tenure. An example of this can be seen in the impeachment of former Bayelsa State Governor D.S.P. Alamayeseigha in 2006 after he was indicted for money laundering by the London Metropolitan Police in the United Kingdom.
Shortly after this decision was delivered in 2002, the Olusegun Obasanjo administration established the Economic and Financial Crimes Commission ( E.F.C.C ) a watchdog institution for corrupt public officers and financial crimes). It goes without saying that the decision in the above case created the opportunity of the establishment of this commission which turned out to be a step in the right direction.
Unseating this idea of immunity has proven to be a herculean task because of the constitutional safeguard given to this anomaly which Judges often are careful not to offend and really ought not to offend. To successfully wrestle against this necessary vice, we must also resort to some level of judicial activism whilst securing the institution of government at the same time from all levels of vulnerabilities. Hence, the valid dictum by Lord Oliver Wendel Holmes that the law is indeed the prophesy of what the Court would say in fact and nothing more pretentious.
PRESENT DAY TREND ON THE SUBJECT MATTER
The issue of immunity is now generating a lot of controversy and argument than ever. It is gladdening to hear Nigerians openly calling for the expurgation of the shielding clause in our constitution. It was in fact one of the items the Senate committee on the review of the 1999 Constitution was considering recommending for removal from our Constitution. Though, this has not been achieved till date.
Some noble Nigerians (myself inclusive) still nurse the valid fear that leaving our leaders without the protection of the invisibility cloak of the immunity clause will expose them to all manner of litigations. Even though this fear is legitimate and valid, this writer is of the opinion that this eventuality can be curtailed by other means rather than preserving this same "Immunity" in its present form which has obvious become almost impotent in its true spirit and lost its substance.
It is believed in some quarters that the presence of immunity is what makes corruption in public offices an alluring expedition. We must remove the attraction that makes the attainment of public office a 'do-or-die' bid. Some even contest for public offices in order to becoming invisible from already looming prosecution, criminal and civil alike. The possibility of probing and prosecuting over suspected criminal acts of embezzlement and others, while still in office, will definitely reduce the impunity by which corrupt leaders operate, especially some state governors who are mostly guilty of oppressing their people and unconscionably looting their states' treasury, without any restraint.
Coming on the heels of the last National Conference, the National Conference Committee on Politics and Good Governance recommended that the Immunity Clause be removed from the 1999 Constitution. Professor Jerry Gana, the Chairman of the Committee made it clear that the decision was reach as a result of concerns on the level of abuse of power by public officers and they wanted to send a message to all Nigerians that nobody is above the Law. He reported that this was a unanimous decision of the committee but it is yet to be presented to the Plenary for approval which will then make it the decision of the Conference.
According to Premium Times Publication of 18th April 2013, tagged "Nigerian demand Immunity Clause Amendment" it was gathered that the House of Representatives gathering the votes of Nigerians on the subject of the Immunity clause with the intentment to limit its cover only to civil proceedings and exclude criminal liability thereby exposing the President and Governors to immunity criminal prosecution where necessary.
Voters who participated in weeks of public sessions held across the federation last November, voted to limit that protection; proposing that protection for the chief executives be only for civil cases. Nigerians voting on whether section 308 should be "amended to make the immunity provision for the president" and the rest cover only civil cases voted in favour of the amendment. The response was 225 for the amendment while 132 voted against it. Only three constituencies abstained from taking a clear position.
The Speaker of the House of Representatives at the material time (2013), Aminu Tambuwal, said all opinions raised in the voting will be "fairly considered". He stated further as follows:
"To all Nigerians, let me seize this opportunity to assure, on behalf of the House of Representatives that all views and opinions offered at these public Sessions as well as those forwarded through written memoranda, which constitute the substance of this report, will be carefully and fairly considered in fashioning the proposed amendments to the Constitution,"
The effect of this amendment was that if it was approved, incumbents will be open to prosecution on criminal cases only. But till date, this proposal the requisite approvals.
In the Second Volume of this article, this writer will carefully examine the workable approaches and adaptable measures to radically change the face of the immunity law in Nigeria or if possible removing it entirely form our legal system but not without viable safety measures to re-balance the spirit of the law and also avoid a beehive of vexatious and frivolous cases getting in the way of governance. Briefly, I will suggest some workable measures which will be discussed more extensively in the next volume of this article. They are:
The law should be given strict interpretations to prevent unscrupulous persons take advantage of the privileges thereof thereby using the law as a machinery to perpetuate fraud or any other type of crime. This writer further suggests respectfully that a process for modifying the Immunity clause may be set in motion thereby setting circumstances wherein it may not apply or creating exceptions and avenues to guard against its misuse. Thirdly, the concept of Surrender may be adapted domestically whereby, where a person covered by Immunity has been properly investigated and sufficiently indicted, a procedure would be put in place to surrender such persons to a superior court of records for trial either upon conclusion of a referendum by the people of the State or the Country and finally such person is provided with two options of either waiving his immunity by proceeding to clear his name in court while his Deputy holds sway or simply resign from his position.
These realities amongst others already discussed above will no doubt bring back some level of deference and fear into the system. These however are suggestions by this writer put forward hypothetically to serve as precautions and safeguards from an immunity cover that has gone rogue. These suggestions will be more robustly discussed in the Second Volume (Vol. II) of this Article.
Using the words of Edmund Burke, he made it clear that evil will only persist as long as good men do nothing. The question now arises, what if good men are legally prevented by law from acting and stopping the reign of evil.
It has been said that the Journey of a Thousand Miles begins with just one step. We must take decisive steps to save our democracy from the flagrant abuse of the Immunity clause so as to draw closer to our desired destination as a Nation.
The fact that the Nigerian Constitutions have consistently provided for absolute executive immunity and there is a 2018 Act of the National Assembly now pronouncing clearly Legislative Immunity both in the wordings and the spirit of the law, a position the Supreme Court is required at law to abide with consistently and absolutely should not deter us from progressively canvassing for improvements. Lord Justice Denning encouraged us to keep trying when he stated as follows:
"If we never do anything that has been done before (because it is forbidden), we shall never get anywhere. The law will stand whilst the rest of the world goes on: and that will be bad for both."
Some schools of thought hold the position that the President is the symbolic head of the Nation and the Governors the chief executives of their states. To wound them by a criminal proceeding is to hamstring the operation of the whole governmental apparatus. It would impair a government function and cause unnecessary political distraction. They affirm that a criminal trial of a sitting President or Governor, however, would confer upon a single judge, the power, in effect, to overturn a national or state election.
In "A Delicate Balancing Act, Arguing Both Sides of Immunity" I humbly posit that common good or public good of the majority of our citizens, requires freedom of action on the part of public office holders, and a protection against fear of and from prosecutions for actions taken for the benefit of the generality of the citizenry. Such freedom of action should not have an impinging cloud, or danger of deterring public spirited actions. As I argued above that immunity has immense value and benefits, if and when it is not abused.
But now? Now, in the prevailing circumstance, this writer has most humbly, painfully, and agonizingly come to agree with the conclusion that the immunity clause have become abused, cursed, misused and bastardized so much, the only way out, is to excise the immunity clause from the constitution of Nigeria 1999 or at the very least, amend it to serve its proper purpose while combating its weaknesses and filling up all pitfalls and lacuna by legislation. Just then shall we tackle the culture of impunity which has become so blatant in the brazen criminal misconduct of some Nigerian public office holders. The Judiciary and Legislature may fashion out other ways of shutting the floodgate of unnecessary litigation against the Government. This will not be a first. There are many ways to achieve the necessary protection without preserving unnecessary immunity.
The following materials aided in writing this Article:
The BLACKS' LAW DICTIONARY
The 1999 CONSTITUTION of the Federal Republic of Nigeria (as amended) 2011
The Nigerian Weekly Law Report: CHIEF GANI FAWEHINMI V. INSPECTOR GENERAL OF POLICE: (2002) 7 NWLR (Pt. 767) 606 (Other Citations (2002) 5 S.C (Pt. 1) 63, (2002) All NLR 357, (2002) 23 WRN 1)
OFFICIAL CORRUPTION AND IMMUNITY IN NIGERIA, By Mr. FEMI FALANA SAN. Article Published in Premuim Times on the 7th day of July 2016
Nigerian Institute of Advanced Legal Studies: THE IMMUNITY CLAUSE UNDER THE 1999 CONSTITUTION AND THE ANTI-CORRUPTION CRUSADE - A CASE OF STRANGE BED-FELLOWS? An Article By Dr. S. Gozie Ogbodo
EXPUNGE; EXCISE & REPEAL IMMUNITY CLAUSE NOW! By Paul I. AdujieLawcareer@msn.comNew York, United States
REMOVING IMMUNITY CLAUSE FROM THE CONSTITUTION WILL UNDERMINE EXECUTIVE CAPACITY By Kayode Oladele.
DUNMADE ONIBOKUN - SCOPE OF IMMUNITY CLAUSE ON NIGERIAN PUBLIC OFFICERS Dunmade Onibokun Esq. Principal Partner, Adedunmade Onibokun & Co.
CONFERENCE COMMITTEE DENOUNCES IMMUNITY CLAUSE FOR PRESIDENT, GOVERNORS, OTHERS, published in The Nation on the 30th day of April 2014 https://thenationonlineng.net/conference-committee-denounces-immunity-clause-president-governors-others/
IMMUNITY CLAUSE: TO GO OR NOT TO GO by Mark Amaza, December 4, 2012 https://www.gamji.com/article6000/news7818.htm
NIGERIANS DEMAND IMMUNITY CLAUSE AMENDMENT, April 18th 2013 https://www.premiumtimesng.com/news/130272-nigerians-demand-immunity-clause-amendment.html
THE PUNCH NEWSPAPER, Wednesday, April 30, 2014 Vol. 38, No. 20, 651 www.punchng.com.