Matawalle: ADC Judgement Vindicates Tinubu on Judiciary, One-Party State Claims

A recent Federal High Court judgment in Nigeria, specifically the case of *Leke Abejide v. African Democratic Congress (ADC) & Ors.*, delivered on July 2, 2026, has affirmed the leadership of the African Democratic Congress (ADC) under former Senate President David Mark. The court, presided over by Justice Musa Liman, dismissed the suit challenging the party's leadership primarily on the grounds of lack of jurisdiction, holding that the matter constituted an internal affair of a political party and was therefore non-justiciable. The court also found that the plaintiff lacked *locus standi* and failed to exhaust internal dispute resolution mechanisms. This decision has been highlighted by political figures, such as Minister of State for Defence Mohammed Bello Matawalle, as a vindication of judicial independence and a counter-narrative against claims of Nigeria drifting towards a one-party state, underscoring the judiciary's role in upholding internal party democracy and the rule of law.

The landscape of Nigerian political party dynamics recently witnessed a significant judicial pronouncement with the Federal High Court's judgment in *Leke Abejide v. African Democratic Congress (ADC) & Ors.* on July 2, 2026. This decision, which affirmed the leadership of the African Democratic Congress (ADC) led by former Senate President David Mark, has reverberated beyond the confines of intra-party disputes, drawing commentary from prominent political figures. Notably, the Minister of State for Defence, Mohammed Bello Matawalle, swiftly interpreted the judgment as a vindication of the Nigerian judiciary's independence and a rebuttal to assertions regarding the nation's potential slide into a one-party state.

This article delves into the legal underpinnings and broader implications of the Federal High Court's ruling. It aims to dissect the court's reasoning, particularly its emphasis on judicial non-interference in the internal affairs of political parties and the principles of *locus standi* and exhaustion of internal remedies. By examining this judgment within the context of Nigeria's constitutional and electoral framework, we explore its significance for fostering internal party democracy, reinforcing judicial autonomy, and shaping the trajectory of multi-party politics in the country.

The operation and internal governance of political parties in Nigeria are primarily regulated by the Constitution of the Federal Republic of Nigeria, 1999 (as amended), and the Electoral Act, 2022. The Constitution, particularly Sections 221 to 229, outlines fundamental requirements for political parties, including provisions for their democratic operation and internal structures. Section 223(1)(a) mandates that the constitution and rules of a political party must provide for periodical elections on a democratic basis for its principal officers. The Independent National Electoral Commission (INEC) is vested with the constitutional and statutory responsibility to monitor the organisation and operation of political parties, including their finances and conventions, congresses, and meetings.

The Electoral Act, 2022, further elaborates on these principles, with provisions aimed at strengthening internal party democracy and regulating the conduct of party primaries and leadership selection processes. Sections 82 and 84, for instance, detail the procedures for holding conventions, congresses, and meetings for the nomination of candidates and election of party officials, emphasizing INEC's monitoring role. Historically, disputes over party leadership and candidate selection have been a recurring feature of Nigeria's political landscape, often leading to protracted litigation. Courts have frequently been called upon to adjudicate these matters, leading to a developing jurisprudence on the extent of judicial intervention in what are often considered the domestic affairs of political associations.

The Federal High Court's judgment in *Leke Abejide v. African Democratic Congress (ADC) & Ors.*, delivered by Justice Musa Liman, represents a significant reinforcement of the principle of judicial non-interference in the internal affairs of political parties. The court dismissed the suit challenging the leadership of the ADC, led by David Mark and Rauf Aregbesola, on multiple grounds. Primarily, Justice Liman held that the court lacked jurisdiction to entertain the matter, characterizing it as an internal affair of a political party and thus non-justiciable. This stance aligns with a long line of judicial precedents that advocate for courts to exercise restraint in meddling with the internal workings of voluntary associations, including political parties, as long as their actions conform to their own constitutions and extant laws.

Beyond the jurisdictional issue, the court also found that the plaintiff, Leke Abejide, lacked the requisite *locus standi* to institute the action. Justice Liman determined that Abejide failed to demonstrate how his personal rights had been violated by the emergence of the current ADC leadership. Furthermore, the court noted that the plaintiff had not exhausted the internal dispute resolution mechanisms provided within the ADC's constitution before resorting to litigation. These findings collectively underscore the judiciary's expectation that party members must first seek redress through established internal channels and demonstrate a direct and personal grievance before invoking the court's jurisdiction.

Crucially, the judgment affirmed that the process through which David Mark and Rauf Aregbesola emerged as the ADC's National Chairman and National Secretary, respectively, complied with the party's constitution and the Electoral Act, 2022. The court specifically noted that the handover of leadership by the former National Chairman, Ralph Nwosu, and the subsequent National Executive Committee meeting of July 29, 2025, where the new leaders were formally produced under INEC's supervision, were valid. This aspect of the ruling validates adherence to due process within party structures as a critical factor in judicial review. The imposition of substantial costs against both the plaintiff (N2 million to each defendant) and his counsel (N10 million) under the Electoral Act, 2022, further signals the judiciary's growing intolerance for frivolous or vexatious litigation aimed at destabilizing political parties.

The political commentary by Minister Matawalle, framing the judgment as a vindication of judicial independence and a counter to "one-party state" claims, highlights the broader societal perception of such rulings. By upholding internal party autonomy and refusing to be drawn into partisan squabbles without proper legal grounds, the judiciary demonstrates its commitment to its constitutional role as an impartial arbiter. This judicial posture is vital for maintaining public confidence in the rule of law and ensuring a level playing field for all political actors, thereby strengthening the foundations of Nigeria's multi-party democracy against any perceived threats of political dominance.

The Federal High Court's judgment in *Leke Abejide v. African Democratic Congress (ADC) & Ors.* serves as a potent reminder of the judiciary's commitment to upholding the principles of internal party democracy and judicial restraint in Nigeria. By emphasizing the non-justiciability of internal party affairs where due process is followed, and by strictly applying the doctrines of *locus standi* and exhaustion of internal remedies, the court has sent a clear message to political actors. This decision reinforces the imperative for political parties to adhere diligently to their own constitutions and the provisions of the Electoral Act, 2022, in managing their leadership transitions and resolving internal disputes.

For legal practitioners, the judgment underscores the critical importance of advising clients on the necessity of exhausting all available internal party mechanisms before contemplating litigation. Furthermore, it highlights the judiciary's increasing willingness to impose significant costs for frivolous or ill-conceived suits, serving as a deterrent against the abuse of court processes for political ends. As Nigeria's democratic journey continues, judgments such as this are crucial in fostering a robust multi-party system, ensuring that the judiciary remains an independent arbiter, and ultimately strengthening the rule of law and democratic governance.