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Comparatives of Western Legislative Experience in Electing Parliamentary Leaders

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The imbroglio in the Nigeria upper legislative assembly, the Senate, resulting from the defection of the Senate President, Dr. Bukola Saraki, from the ruling All Progressives Congress (APC) to the main opposition, the Peoples Democratic Party (PDP), has reached fever pitch as calls for his resignation or impeachment from a section of the APC rings the air.

Championing the calls are the national chairman of the party, Comrade Adams Oshiomhole, and Senate majority leader, Ahmed Lawan, who have threatened fire and brimstone should he fail to resign his position as the president.

On the other hand, Saraki has turned down the call to resign citing constitutional provisions and precedence obtainable world over, which permits the minority group to produce parliamentary leaders through elections.

According to Andrew Kennon, a former Clerk of Committees in the British House of Commons “The House’s freedom to make its own choice among an array of volunteers probably means that any sense of it being the ‘turn’ of a particular party is out of date.

Kennon’s over 40 years in the British House of Commons made him an authority capable of speaking authoritatively on areas of legislative elections.

Below are samples of parliamentary procedures requisite for elections in developed democracies and the precedence set for others to follow:

UNITED KINGDOM

MPs elect the Speaker from amongst their own ranks. The House must elect a Speaker at the beginning of each new parliamentary term after a general election, or after the death or resignation of the incumbent. Once elected, a Speaker continues in office until the dissolution of Parliament, unless he or she resigns prior to this. Customarily, the House re-elects Speakers who desire to continue in office for more than one term. Theoretically, the House could vote against re-electing a Speaker, but such an event is extremely unlikely. Until 2001, the election of a Speaker was conducted as a routine matter of House of Commons business, as it used motions and amendments to elect. There was, however, a considerable amount of behind-the-scenes lobbying before suitable candidates were agreed upon, and so it was very rare for a new Speaker to be opposed. However, this system broke down in 2000 when 12 rival candidates declared for the job and the debate occupied an entire Parliamentary day.  Under the new system, candidates must be nominated by at least twelve members, of whom at least three must be of a different party from the candidate. The House votes by secret ballot; as in Nigeria, an absolute majority is required for victory.

In recent times, from the 19th century onwards, the Speaker has even been a member of the Opposition and not all Speakers have been the candidates proposed by the ruling Party even if they are from that Party. For example, in 1895, the Conservatives and Liberal Unionists put forward Sir Matthew White Ridley, a well-respected MP who had many years of experience, and hoped for a unanimous election as the previous Speaker had been a Liberal. However, the Liberals decided to oppose him and eventually nominated William Court Gully who had been an MP for only nine years and had been a relatively quiet presence. Gully won on a party-line vote. In 1951 there was a great demand from the Labour Party for Major James Milner to become the first Labour Speaker after he had served as Deputy Speaker for eight years. However, the Conservatives (who had just regained power) nominated William Shepherd Morrison, Conservative MP, against him. This was at the time an unusual step. The vote again went down party lines, and Morrison was elected. In 1992, Betty Boothroyd, a Labour MP who had been Deputy Speaker, contested against the Conservative former Cabinet member Peter Brooke. About 70 Conservative MPs supported Boothroyd ensuring her election. She was the only Speaker elected in the 20th century not to be a member of the governing party at the time of her first election. In 2000, most Labour MPs supported Michael Martin. However, most Conservatives felt that a Conservative Speaker should be chosen. They supported two prominent Conservatives, Sir George Young and Deputy Speaker Sir Alan Haselhurst. After a lengthy sitting of the House, Michael Martin was elected Speaker. Following the debacle of this election the rules were changed as stated above. In 2009, John Bercow, a Conservative MP was elected Speaker following an election by secret ballot in which the frontline Labour MP, Margaret Beckett, and another Labour MP, Parmjit Dhanda, participated.  Labour was in Government at this time. Bercow thus became the first Speaker to be elected in the 21st century not to be a member of the governing party at the time of his first election.

IRELAND

The Ceann Comhairle (“head of the council”) is the chairperson (or speaker) of Dáil Éireann, the lower house of the Oireachtas (parliament) of Ireland. The person who holds the position is elected by members of the Dáil from among their number in the first session after each general election. Despite this, a government usually tries to select a member of its own political party for the position, if it has enough deputies to allow that choice. The Leas-Cheann Comhairle holds office as the Deputy Chairman of Dáil Éireann under Article 15.9.1 of the Constitution. In the absence of the Ceann Comhairle, the Leas-Cheann Comhairle deputises and performs the duties and exercises the authority of the Ceann Comhairle in Dáil proceedings. By tradition, the position is reserved for the Opposition, but the appointment is made by the Taoiseach (Prime Minister) of the day.

AUSTRALIA

The President of the Senate is elected by the Senate in a secret ballot. The Clerk conducts the election. The Presidency has always been a partisan office and the nominee of the government party has nearly always been elected, although this cannot be guaranteed since the government of the day does not necessarily have a majority in the Senate. The President is assisted by an elected Deputy President.

The traditional practice has been that the government nominates a Senator to be elected as President, and the Opposition nominates a Senator to be Deputy President. If there are no other nominations, no election is required, however the Australian Greens in 2005 and again in 2007 put forward Senator Kerry Nettle as a rival candidate when the position of President was vacant. Neither Government nor Opposition Senators supported that candidacy. After the 1996 election, the Labor Party refused to nominate Colston to become Deputy President of the Senate. In a bid to win him over, the Howard Coalition government offered to support him. Colston resigned from the Labor Party by fax message at 11:30 a.m. on 20 August, and he took his seat as an independent that afternoon. In the evening, he was elected Deputy President, on the nomination of the Coalition.

UNITED STATES

The Constitution designates the Vice President of the United States as President of the Senate. The Constitution also calls for a President pro tempore to serve as the leader of the body when the President of the Senate (the Vice President) is absent. In practice, neither the Vice President nor the President pro tempore customarily the most senior (longest-serving) Senator in the majority party actually presides over the Senate on a daily basis; that task is given to junior Senators of the majority party.

The Senate Majority and Minority Leaders are two United States Senators who are elected by the party caucuses that hold the majority and the minority respectively. These leaders serve as the chief Senate spokesperson for their parties and manage and schedule the legislative and executive business of the Senate.

Party leaders and whips of the United States House of Representatives are elected by their respective parties in a closed-door caucus by secret ballot and are also known as floor leaders. The U.S. House of Representatives does not officially use the term “Minority Leader” although the media frequently does. The House instead uses the terms “Republican Leader” or “Democratic Leader” depending on which party holds a minority of seats.

In common U.S. Congressional Republican caucus legislative usage, the caucus chair is styled conference chairman and is outranked by the Speaker or Senate President pro-tempore, and the leader or whip of his or her party.

 

CANADA

In Canada, the elected members of each party in Parliament, including senators, or a provincial legislature, elect among themselves a caucus chair who presides over their meetings. The exception to this norm is the Conservative Party of Canada, whose caucus chair is appointed by the party leader. This person is an important figure when the party is in opposition and an important link between cabinet and the backbench when the party is in government.

 

FRANCE

The Senate is the upper house of the Parliament of France, presided over by a president. The senators elect a President from among their members. The current incumbent is Gérard Larcher. The President of the Senate is, under the constitution of the Fifth Republic, first in the line of succession in case of death, resignation or removal from office (only for health reasons) to the Presidency of the Republic, becoming Acting President of the Republic until a new election can be held.

Elected by secret ballot at the beginning of the legislative session by members, the President of the National Assembly represents the Assembly and directs discussion and debates.

The President normally comes from the largest party represented, assisted by Vice Presidents from across the represented political spectrum.

The above is a testimony that the President of the Senate has not fallen short of any constitutional provision, and should not be in any form of pressure to relinquish his position, or be threatened with impeachment before his party might be in the minority.

The case of John Pam West of the Senate and Edwin Ume-Ezeoke of the Nigerian Second Republic are clear evidences of the what must be.

 

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Atiku Rejects Senate’s Approval of Mixed Transmission of Election Results

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Former Vice President Atiku Abubakar has opposed the use of a combination of electronic and manual transmission of election results, warning that such an approach could create confusion within the electoral system.

Atiku, who spoke to journalists in Minna after a closed-door meeting with former Military Ruler, General Ibrahim Badamasi Babangida (retd.), at his residence, said he favours full electronic transmission of election results.

According to him, electronic transmission remains the most credible option for ensuring fairness and transparency in the electoral process. He added that the current approach falls short of the expectations of Nigerians, many of whom anticipated real-time electronic transmission of results across all levels of elections.

The former Vice President urged opposition political parties to unite and pursue the matter collectively, insisting that the issue should not be allowed to rest where those in power want it to be.

“The mixture of electronic and manual transmission undermines the integrity of the electoral process and does not align with the reforms Nigerians had hoped for,” he said.

On the 2027 presidential election, the former Vice President said discussions about his candidacy are premature.

He explained that his party, the African Democratic Congress (ADC), is currently focused on strengthening its structures across wards, local governments, states, and at the national level, while mobilising and registering members.

Regarding zoning, Atiku noted that the ADC does not have a zoning arrangement in its constitution, adding that the Peoples Democratic Party (PDP) remains the only political party in Nigeria with an explicit zoning provision.

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Nenadi Usman-led Exco Resumes at LP National Secretariat

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The National Caretaker Committee of the Labour Party (LP) led by Senator Nenadi Usman, on Tuesday, resumed at the party’s national secretariat in Abuja, following a court ruling which affirmed its leadership.

Usman and members of her team arrived at the party office, previously occupied by the Bar Julius Abure-led National Working Committee, at 11am.

The Usman-led faction had had a lengthy legal battle with the Abure-led camp, which got to the Supreme Court but was revived at the federal high which recognized her leadership of the party.

The Independent National Electoral Commission (INEC) also affirmed her leadership recently via invitation for party meetings.

The Abure camp has, however, kicked against her recognition by the electoral commission and vowed to challenge the high court verdict.

As the first female national chairman of a major political party in Nigeria, Usman’s ascension is considered a milestone for women’s representation in politics.

Details of her plans and agenda are expected to be announced in due course.

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Who’s Afraid of New Electoral Act?

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By Eric Elezuo

The furore generated with the passing of the Electoral Bill 2026 by the Nigerian Senate, is yet to die down as various groups, sections and institutions, have continued to lend their voices in condemnation of the tactical removal of the proposed real-time electronic transmission of results.

The Civil Society Organisations and Action Aid have declared a protest to kickoff on Monday, February 9, 2026, titled Occupy NASS Protest, until the Senate find reason to listen to Nigerians, and do what is right, and that aligned with the aspirations of Nigerians, according Samson Itodo, the Executive Director of YIAGA Africa.

In the same vein, the African Democratic Congress has pledged to begin a protest in Abuja on Monday over the removal of real-time clause in the new electoral bill.

The Senate, on Wednesday, passed the Electoral Bill 2026 following hours of debate, but ended up rejecting a proposal to mandate real-time electronic transmission of election results while however, approving significant reforms to election timelines, penalties for electoral offences and voting technology.

The Boss learnt that at the centre of the controversy was Section 60, which governs the transmission of polling unit results, where the Senators voted down a recommendation by the Senate Committee on Electoral Matters that would have compelled presiding officers to upload results to the INEC Result Viewing (IReV) portal in real time. The rejection has drawn the irk of majority of Nigerians, who have have wondered if anyone is actually afraid of the new electoral law? If yes, who? And what could be the reason behind such fears as the need to regulate a hitchfree and smooth and fair electoral process have remained the goal and aspirations of politically savvy Nigerian.

But the lawmakers, contrary to the yearnings of most Nigerians, have retained the approach in the 2022 Electoral Act, which allows electronic transmission after votes are counted and publicly announced at the polling unit. In other words, giving approval to transfer of results instead of transmit in real-time of results.

In their defence however, Senators opposing the real-time upload argued that inconsistent network coverage and logistical challenges could trigger legal disputes and undermine electoral credibility.

The rejected proposal was contained in the new Clause 60(5) of the draft bill, which aimed to mandate presiding officers to electronically transmit polling unit results in real time after completing and signing Form EC8A.

The clause was designed to strengthen transparency and reduce electoral malpractice through technology-driven result management.

The motion to reject the electronic transmission clause was swiftly seconded by the Deputy President of the Senate, Barau Jibrin.

Similarly, the Senate also rejected a proposed amendment under Clause 47 that would have allowed voters to present electronically-generated voter identification, including a downloadable voter card with a unique Quick Response (QR) code, as a valid means of accreditation.

In his defensive remarks, the Chairman of the Senate Committee on Media and Public Affairs, Adeyemi Adaramodu, described the debate as a process subjected to an invisible world of semantics.

“Electronic transmission remains part of the law,” he said, “and results will continue to be available to the public both electronically and through physical forms, ensuring verifiable records for disputes,” Adaramodu said.

In his own defence, President of the Senate, Godswill Akpabio, though admitted that the Senate deliberately deleted the provision for “real-time” transmission of election results from the Electoral Bill, 2026, noted however, that the Senate took the decision because it believed that “technology must save and not endanger democracy.”

Speaking at the launch of a book, “The Burden of Legislators in Nigeria”, authored by Senator Effiong Bob, in Abuja, Akpabio likened the issues raised in the book to the challenges faced by lawmakers in the course of their duties, including the controversy and alleged “abuses” directed at the Senate following the passage of the electoral bill.

The Senate President argued that the entire country could be thrown into chaos if, for instance, network or power failure affected the uploading of results.

He insisted that Form EC8A and other official election records should remain the most reliable means of declaring results.

“All we said was to remove the word ‘real-time’ to allow INEC decide the mode of transmission. If you make it mandatory and there is a system failure, there will be a serious problem,” Akpabio told the gathering, further confirming that the bill, as passed, excluded real-time electronic transmission of results.

Continuing, he said, “Real-time means that if there are nine states where there is no network, does it mean elections will not take place there?

“Or in any part of the country where there is a grid breakdown, does it mean there will be no election?”

The Senate President sounded a note of warning to Nigerians amid outrage, saying the legislature would not be “intimidated” into passing a faulty law simply to please opposition political parties, civil society groups and non-governmental organisations (NGOs).

He criticised NGOs for insisting that because they organised retreats for lawmakers, where ideas were exchanged on the electoral bill, the Senate must adopt their positions, even if such positions did not align with the interests of all segments of the country.

“Why are people setting up panels on television stations and abusing senators? I leave them to God.

“We will not be intimidated but will do what is right for Nigeria, not what one NGO says. A retreat is not law-making.

“Why do you think that the paper you agreed to in Lagos must be what we must approve?” he asked.

Akpabio frowned at the public attacks on the Senate, saying they were uncalled for, and stressing that any provision rejected by the Senate could be reinstated by the Conference Committee of the Senate and the House of Representatives. He said there was therefore no need to hastily criticise senators.

“We have not even completed it until we look at the votes and proceedings. When we bring out the votes and proceedings, any senator has the right to rise and amend it.

“We can amend anything before we approve the votes and proceedings. Why abuse the Senate when what we have is incomplete?

“I can’t talk until they tell me to drop the gavel. In this case, we are yet to complete the process,” he said.

Besides Akpabio’s defences, many groups and individuals have risen stoutly against the removal of the real-time electronic transmission clause, describing the act as irresponsible and detrimental to the feeling of Nigerians.

In his reaction, the National Chairman of the main opposition party, African Democratic Congress (ADC) Senator David Mark, who himself, was a Senate President, and was also present at the book launch, cautioned Akpabio against speaking for the Independent National Electoral Commission (INEC).

“What the ADC is saying is: pass the law and let INEC decide whether it can implement real-time electronic transmission or not. Don’t speak for INEC.

“The position of the ADC is clear: pass the bill and let INEC decide what it will do with it,” Mark harped.

Reacting also, a former governor of Anambra State and presidential candidate of the Labour Party in the 2023 presidential election, Mr. Peter Obi, delivered knocks to the Senate for the rejection, noting that the Senate decision to stick to the 2022 Electoral Act, which concedes the discretion to apply electronic transmission of results to the Independent National Electoral Commission ( INEC), is an assault on democracy.

In a lengthy post in X titled, “We Continue to Confirm our ‘Now Disgraced Status’ as a Nation?” the now ADC chieftain expressed concern that while other nations have embraced the practise of electronic transmission of results, “the supposed giant of Africa, shamelessly lags behind, dragging the continent backwards.”

He wrote: “Let us all pause and pray for the souls of over 150 innocent lives lost in Kwara yesterday. This tragedy is precisely why I delayed commenting on the outrageous and shameful news surrounding our electoral system.

“The Senate’s blatant rejection of mandatory electronic transmission of election results is an unforgivable act of electoral manipulation ahead of 2027.

“This failure to pass a clear safeguard is nothing short of a deliberate assault on Nigeria’s democracy. By rejecting these essential transparency measures, they are eroding the very foundation of credible elections. “One must ask: Does the government exist to ensure order and justice, or to institutionalise chaos? Is its purpose to serve the people, or to fulfil the sinister ambitions of a select few?

“The turmoil, disputes, and manipulations that plagued past elections, especially the 2023 general election, stemmed directly from the refusal to fully implement electronic transmission.

“Nigerians were fed excuses of a fabricated “glitch” that never existed. While numerous African nations adopt electronic transmission to bolster democracy, Nigeria, the supposed giant of Africa, shamelessly lags behind, dragging the continent backwards.

“We are wasting time hosting conferences and drafting papers on Nigeria’s problems while we, the leaders and elite, are the real issue. Our deliberate resistance to reform is pulling the country backwards, dragging us toward a primitive state of governance.

“By rejecting mandatory electronic transmission—a critical safeguard for electoral integrity—we are entrenching disorder aimed at perpetuating confusion according to the whims of a small clique. Have we not reached a point where we must think seriously about the future of our country and our children? Should leadership not focus on building a credible, orderly, and livable nation for the next generation, rather than one permanently ensnared in chaos?

“When the former Prime Minister of the UK, aware of our history, labelled us “fantastically corrupt,” we reacted defensively. When President Donald Trump declared us a “now disgraced nation,” we were incensed. Yet, with every act of resistance against transparency and reform, we continue to affirm their claims. Those responsible will later point fingers at others for harming the country while they quietly suffocate its potential.

“Let there be no illusion, the criminality witnessed in 2023 will not be tolerated in 2027. Nigerians everywhere must start getting ready to rise up, resist, and reject the backward trajectory, legitimately and decisively reclaim our country from the clutches of deliberate malevolence.

“The International community must take heed of this groundwork for continued future electoral manipulation, endangering our democracy and development.”

Another respondent, Akin Osuntokun, who was the Labour Party campaign DG in 2023, noted that the removal is an affront to democracy.

“It (Rejection of e-transmission of election results) does not portend good omen, it does not portend good for the growth of democracy in Nigeria.

“The growth of democracy is rooted in accountability and the integrity of elections.

“So anything that makes elections less accountable makes the election less credible. Automatically, it is a drag and an obstruction of the growth of democracy in Nigeria.

“It does not serve the purpose of democratic consolidation, so far as the elections that are conducted on that basis will not meet the bar or threshold of credible election,” Osuntokun said while fielding questions from NAN.

Also, opposition senators have stepped out as a group, insisting that the Senate passed the Act with provision of real-time in it, stressing that anything other than that, is not a document from the Senate.

In the midst of the public outrage, Akpabio has insisted that senate did not remove or reject electronic transmission, clarifying that it cannot guarantee the transmission of results in real time hence the omission of the status of ‘real-time’.

While presiding over the debate session, Akpabio also dismissed claims that electronic transmission had been removed, emphasising that “Retaining that provision means electronic transmission remains part of our law.”

WHAT THE SENATORS CONSIDERED APPROPRIATE FOR THE ELECTORAL BILL

But beyond the brouhaha of real-time electronic transmission, other major amendments to Nigeria’s electoral calendar were approved by the Senate.

The election notice period was reduced from 360 days to 180 days, the deadline for submission of party candidate lists was shortened from 120 to 90 days, and the nomination period was cut from 180 to 90 days.

To deter electoral malpractice, the fine for unlawful possession of voters’ cards was increased from N500,000 to N5 million, though the Senate rejected a proposal for a 10-year ban on vote-buyers, opting for stiffer financial penalties instead. The smart card reader was officially removed from the electoral framework and replaced with the Bimodal Voter Accreditation System (BVAS).

Under the retained provisions, presiding officers are required to count votes at the polling unit, record results on prescribed forms, announce them publicly and transmit them electronically to the appropriate collation centre.

The e-transmission of results, if approved, would have required INEC presiding officers to upload results from each polling unit to the IReV portal in real time, immediately after completing Form EC&A, which must be signed and stamped by the presiding officer and countersigned by party agents.
Instead, the senators chose to retain the present Electoral Act provision, which mandates that “the presiding officer shall transfer the results, including the total number of accredited voters and the results of the ballot, in a manner as prescribed by the Commission.”

Lawmakers voted to retain the existing 2022 provisions requiring voters to present their Permanent Voter’s Card (PVC) for accreditation at polling units.

The Senate further upheld the provision mandating the use of the Bimodal Voter Accreditation System (BVAS) or any other technological device prescribed by INEC for voter verification and authentication, rather than allowing alternative digital identification methods as proposed in the new bill.

With these decisions, the Senate reaffirmed the use of PVC and BVAS-based accreditation while rejecting efforts to expand digital voter identification and make electronic transmission of results compulsory.

Meanwhile, while Nigerians are planning to occupy NASS beginning from Monday, the Senate has called an emergency plenary for which the agenda is hitherto unknown, but related to votes and proceedings. It is interesting time in the Nigerian political circle now.

The bone of contention has remained ‘real-time’, and Nigerians continue to ask, ‘who is afraid of new electoral act’?

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