THE IMPARTIALITY AS A SUPREME JUDICIAL VIRTUE



Indeed, the confidence which the entire public has in the judiciary for its high level of impartiality in the discharge of its functions by the judicial office holders is perhaps the greatest bulwark to the resilience of the institution. Though, many condemn and impugn the integrity of judges, there are some who extol their virtues and dependability. The complete confidence which successive Governments have reposed in the integrity of the judiciary is demonstrated by the many commissions and tribunals into which judges are appointed. In 1982, Fatayi-Williams C.J.N., (as he then was) observed:

Except, perhaps, in Australia up to the first quarter of this century, it is doubtful whether any other country in the English speaking world  has had as many tribunals of inquiring presided over by judges of the superior court as Nigeria has had during the last 15years. The military administration started the practice and the new civilian administration is perpetuating it.
The attitude is still much the same. In his address in the all Nigeria conference of judges in 1982, president Shehu Shagari said:
My confidence, indeed my faith, in the independence of our judiciary and the impartiality of our judges has been demonstrated beyond question. They have been appointed to head various commissions of inquiry which have made far-reaching recommendations on matters of national interest and importance. In this way they have played a very significant role in helping this nation to resolve issues which would otherwise have been intractable. He continued, on previous occasions I told the world that our judiciary is comparable to the best. I believe this is a view that all Nigerians share with me….
The general theme that the judiciary is the last hope for the common man is expected to be a reality. The Constitution of this country has held out the judiciary as the priceless asset by the individual for the protection of his property and defense of his liberty. It is only by total public support can it discharge these functions, free from political interference to prejudice of the victims of wanton oppression.
        The right of parties to a fair hearing before a judge is a subject of fundamental right under the 1999 Constitution of the Federal Republic of Nigeria. Section 36(1) of the Constitution provides:
(1) In the determination of his civil rights and obligations, including any question or determination by or against any government or authority, a person shall be entitled to a fair hearing within a reasonable time by a court or other tribunal established by law and constituted in such manner as to secure its independence and impartiality.
Whilst these provisions apply to civil proceedings, similar directive in respect of criminal proceedings is contained in subsection (4) of section 36 of the constitution. It reads:
“(4) Whenever any person is charged with a criminal offence, he shall, unless the charge is withdrawn, be entitled to a fair hearing in public within a reasonable time by a court or tribunal.”
As part of the function of deciding disputes, the Judges or courts provide a public service at almost no charge, or next to nothing, to their customers- the litigants, some of whom are meddlesome, vexatious, exhibitionist, aspiring to be famous or make a name thereby .Judges are expected to resolve such disputes wisely, according to the law, so that the parties before them can conclude that they have had a fair hearing. Undoubtedly, a wide variety of disputes which have otherwise been insoluble come before the judges. Some times the Judges are invariably unable to display omniscience on the legal and non-legal issues raised in their courts. Indeed, Judges are found from research that they are necessarily influenced in the decisions they make by their upbringing and experience. According to a distinguished English Judge, Lord Devlin, in his book “The Judges1, the Judge said:
The social service which the Judge renders to the community is the removal of a sense of injustice. To perform this service, the essential quality which he needs is impartiality and next after that the appearance of impartiality. I put impartiality before he appearance of it simply because without the reality the appearance would not endure.
In truth, within the context of service to the community, the appearance is the more important by the two. The Judge who gives the right judgment while appearing not to do so may be thrice blessed in heaven, but on earth he is of no use at all… impartiality and the appearance of it are supreme judicial virtues.
In some of the examples given by Hon. Justice M. L. Uwais, CJN, CON, in his paper presentation on “The Court an instrument of Justice and Democracy” under the aspect of Impartiality and Bias. In 1781, Lord George Gordon provoked riots in which the house of Chief Justice Mansfield of England got burnt. He was accused of treason and put up for trial before Chief Justice Mansfield who presided fairly. The trial resulted in the acquittal of Lord Gordon. According to Hon. Justice Uwais, he said – a judge who has a financial interest in the outcome of a case is not to sit in judgment on it. He also said – that any judge who considers himself unable to decide a case impartially for some reasons is obliged not to sit in judgment of the case.
2. 343 us 451 at pp. 406-7
 
In the case of Public Utilities Commission V. Pollak2, where the U.S. Supreme Court was asked, in 1952, to decide whether it was unconstitutional for a street railway company to install loudspeakers in its passenger vehicles for the transmission of music and advertisements. Mr. Justice Frankfurter declined to take part in the case because his “feelings were so strongly engaged as a victim of the practice in controversy that I had better not participate in judicial judgment upon it.”
        In the case of Federal Republic of Nigeria V. M. K. O. Abiola3,  an application was made by counsel for the respondent objecting to seven Justices of the Supreme Court sitting on the case because they had earlier brought actions individually for libel against the Concord Newspapers Limited in which the respondent had a controlling share of 90%. The application was granted and two out of the five Justices that constituted the panel disqualified themselves on the ground that justice is based on public confidence and that there was the likelihood that reasonable persons in Nigeria would feel that by reason of the libel action, the Justices disqualified would be biased against the applicant.
The partiality, that invariably affects Judges has been noted in cases with a political flavour. When Sir Winston Churchill was Home Secretary in 1911, he made the following statement in the House of Commons:
Where class issues are involved… it is impossible to pretend that the courts command the same degree of general confidence (as in other case). On the contrary, they do not, and a very large number of our populations have been led to the opinion that they are unconsciously no doubt biased4.
Similarly, Lord Scrutton made the same point in 1920 when he noted that judicial impartiality is difficult to attain. He was not speaking conscious impartiality, but the habits Judges are trained in, the people with whom they mix, lead to their having a certain class of ideas, they do not give as sound and accurate judgments as they would wish5.
4.20hc 1022 (30th may, 1911)
5. The work of the commercial courts iclj6 at p.8 (1923).
6. Justice in the Judicial Process (essays in.. Honour of Honourable Justice Eugene Ubaezonu. (JCA) edited by:C.C.Nweze. pg.201.
 
      In addition, in the paper presented by HON. JUSTICE CHUKWUDIFU OPUTA (J.S.C) (RTD), on “Judicial Ethics and Canons of Judicial Conduct,6” He cited impartiality as one of the judicial ethics, that: justice has no two weights and measures . In order, therefore, to inspire public confidence in the judicial process, Judges should be transparently impartial but also should be seen to be accentuated only by the principles of justice and fair play. The Judges should, therefore, scrupulously eschew bias in any shape or form. It is not merely by some importance, but is of fundamental importance, that justice should not only be done but should manifestly and undoubtedly be seen to be done. Justice must be rooted in confidence and confidence is destroyed when right minded people go away thinking – “the judge was biased”.
        Also Judges have to know that every case has some deep relevance and serious consequence or concern for the parties involved. Like the soldiers rightly say, there is nothing like an unimportant war. To prevent undermining the essence and very existence of the court, the trial judge should show seriousness and concern in every case that comes before him.
        Judges must not let ennui overcome them. The work of Judges is very important, and the results of their action, very far reaching. As Piero Calamanderi, the Italian lawyer and scholar once observed:
     The Judge who becomes accustomed to rendering justice is like the priest who becomes accustomed to saying mass. Fortunate is that country priest who, approaching the altar with senile step, feels the same sacred tabulation in his breast which he felt as a young priest at his first mass. And happy is that Judge who even unto the day of his retirement experiences the same religious exaltation in rendering judgment which made him tremble 50 years before, when as a young magistrate he handed down his first decision.
However, biblically, the first recorded institutionalized appointment of Judges was that made by Moses. Moses had led his people, the Israelites, from Egyptian bondage. As they wandered, thousands of them in the wilderness of Sinai, restive and guarre-some, Moses was the absolute ruler, answerable only to the God of Israelites. He only needed a spokesman to reduce the difficulties of his stammering and stuttering. There was nothing like separation of power. Moses was the executive, the judiciary and the legislature.
        He was religious, political, legislative and judicial leader. And the burden of his absolutism began to tell on him.
        Moses’ father-in-law, Jethro, took, one careful look at him, and was convinced that there had to be a change if he was not to prematurely bury a son-in-law. And this was his advice to him:

The thing that you do is not good. Both you and these people who are with you will surely wear yourselves out. For this thing is too much for you, you are not able to perform it by yourself. Stand before God for the people, so that you may bring the difficulties to God. And you shall teach them the statutes and the laws, and show them the way in which they must walk and the work they must do. Moreover, you shall select from all the people able men, such as fear God, men of truth, hating covetousness: and place such over them to be rules of thousands, rulers of hundreds, rulers of fifties and rulers of tens. And let them judge the people at all times. Then it will be that every great matter they shall bring to you, but every small matter they themselves shall judge7.
And also, in the book of Deuteronomy the virtues of Judges are again stated as follows:
You shall appoint Judges and Officers in all your gates, which the lord your God gives you, according to your tribes, and they shall judge the people with just judgment. You shall not pervert justice. You shall not show partiality nor take a bribe, for a bribe blinds the eyes of the wise and twists the words of the righteous. You shall follow what is altogether just that you may live and inherit the land which the lord your God is giving you.
Indeed, the holy bible has therefore, ordained the moral foundation of a Judge of the people. As Blackstone once declared:
7.1 Exodus 18; 17-22 (New (King James Version).
8. Deut. 16:18-20
 
“The bible has always been regarded as part of the Common Law of England “this indicates that judges’ decision should always be seen to be human and Godly.
        A Judge must be able, God-fearing and a man of truth and integrity. A judge should hate or avoid covetousness, that is to say a judge should not be avaricious, greedy or very desirous of acquiring material wealth. A judge identified with these virtues will administer justice fearlessly, courageously; without ill-will or favour, without distinction of race, tribe, greed, religion or sex. He will be upright and devoid of corruption. Such a Judge will not take bribes to assist litigants in cases before him. His errors of law are in good faith, not contrived subterfuges, because no matter how he tries, he must make mistakes for no man is infallible.
As Oputa, JSC, stated in A. T. Bakare V. T. S Apena & Ors9. “Perfection is a laudable aspiration. But for a trial Judge, it is not necessarily a virtue. For one thing strive as you can, you may never attain perfection. No Judge however brilliant, however hard-working can claim immunity from error. The very existence of appellate courts assumes that the courts of first instance may sometime be in error. Then it becomes the duty of these appellate courts to correct that error”.
9. (1984) 4 NWLR (pl33,) 1 at pages 25-26.
 
        Therefore, to still uphold this virtue of impartiality, Judges should always have it at the back of their minds that litigants come to court to have their particular complaints resolved.  Whatever rules of evidence, practice or procedure the courts adopt in dealing with suits before them must be aimed at achieving the best resolution in the particular circumstance, of the particular disputes or complains which the parties have brought to the court. Only then can such rules be properly referred to as handmaidens of justice. Litigants do not come to court to entertain Judges or the gallery. They are not actors on a stage that must perform in accordance with laid down rules designed to guarantee a particular type of performance that would give maximum entertainment to the target audience, so that a failure to comply with those rules means failure of the play or performance. Litigants pay to come to court; they are not paid to come there and perform. This decision seems rather like that of a movie producer who rejects the movie turned in by this employee actors and directors on the grounds that they have not strictly followed written script or screenplay. That certainly cannot be the role of a court of justice”. By Chidi Nworka- DE NOVO.10
This judicial virtue, the “impartiality”, was also given credit by the eminent Jurist, Hon. Justice. C. A. Oputa, in his book “the Law and the Twin Pillars of Justice”, when he observed:
10. See Pp. 56-57 of the”The Law And The Twin Pillars Of Justice”
 
“A court must be apparently and transparently impartial. A judge should therefore team to be less talkative, to be more restrained in his remarks during the proceedings in order to maintain judicial dignity, and what is more, give the appearance of impartiality. Sir Francis Bacon did once observe that a talkative judge is like an ill-turned cymbal. A Judge should always remember that the aspect of his duty most fitting to, and characteristic of his office is to listen patiently and carefully to both parties before him; never unduly disturbing them or their counsel or interrupting their witnesses, nor in any way taking any step or doing anything which tends to give the impression that he is, as it were, taking sides. Counsel is entitled to expect that the Bench will give him full and ample opportunity to put across his case and to do fairly and freely.
        Questioning by the Bench should therefore be done sparingly and only when it is absolutely necessary. The normal thing is that the Judge does not and should not examine witnesses. This is a task better reserved for counsel. The Judge should realize that he is an umpire and that his job is to hold the scales evenly. It is true that when an umpire enters the arena and participates in the conflict he ceases to be an umpire, he then becomes a contestant, and in such a case his vision is definitely bound to be clouded by the dust of the contest.” These therefore indicate that the esteemed diligence of the judiciary in its adjudication remains the utmost expectation of the litigants from the Judges.
As was humorously put by Lord Hewart: 11
The business of a Judge is to hold his tongue until the possible moment and try to be as wise as he is paid to look.
Also, Lord Birkett had observed thus:12
People unaccustomed to the procedure of the court are likely to be overruled or frightened, or confused or distressed when under the ordeal of prolonged questioning from the presiding Judge. Moreover, when the questioning takes on a sarcastic or ironic tone, as is sometimes almost inevitable, the danger is not only that witness will be unable to present, but to be begin to think, quite wrongly it may be, that the Judge is not holding the scales of justice evenly.
11: Ibid,
12: Ibid,
13: Ibid,
 
        Finally, according to Hon. Justice Oputa13, once more, he said that- “the essential thing is not only that justice is done but also that it should appear to all, including the parties that it is being done in their case. This show of aloofness and impartiality assumes even greater importance in our country, where there is always the belief and the fear that the Bench may be or has been influenced by one or the other of the parties. Our people have jaundiced vision when they come to court and they see in every act of the Judge supporting evidence of undue and improper influence. Judges and Magistrates too should be very careful to do nothing and say nothing (during the hearing of a case) which will give the impression of the Bench siding one of the parties. The apparent impartiality of the presiding Judge is the hall-mark and the plenitude of judicial independence viewed subjectively from the Judge’s angle as a dispenser of justice.”
REFFRENCE
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The Judiciary in the Government of Nigeria – by T. Akinola Aguda.

Modern Constitutional Law in Nigeria by Ben. O.Igwenyi (MON).
Constitutional Law in Nigeria –First Edition By –P.A.O Ouyede

The Law and the Twin Pillars of Justice by – Hon. Justice C.A.Oputa, JSC.

The 1999 Constitution of the Federal Republic of Nigeria.

Human Rights in Nigeria- Millennium Perspective – by Obiaraeri, Nnamdi Onyeka.
Human Rights Law and Practice in Nigeria. Vol 1-by Okpara Okpara.

It’s your Duty to know your Rights- by Agbo Ikechukwu. O (esq).

The Court and Administration of Law in Nigeria. Dr. Chief Fidelis Ejike Ume.

The Black’s Law Dictionary, Ninth edition.

The Relevance of the Judiciary in the Polity in Historical Perspective- Hon. Justice A.G. Karibi- White, JSCN Journal of Human Rights Law and Practice vol.2. Number 3, November, 1992.

All Nigeria Judges Conference Papers 1995-Kano.

Ife Juris Review- A journal of Contemporary Legal and Allied Issues. 2004 vol. 1 part 2.

Journal of Human Rights Law and Practice, vol. 3, number 1, 2,3, December 1993

Nigerian Bar Journal vol.5 no. 1 February, 2007.

News Watch- Nigeria weekly news magazine February 23, 2009.

The Nigerian Bar Journal- vol. 1. No. 1, 2001.

News Watch- Nigeria weekly news magazine-September 21, 2009.
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