Ombudsman Is a Laudable Institution Although It Has Failed Woefully in Nigeria- Discuss.

SCHOOL OF POST GRADUATE STUDIES

UNIVERSITY OF LAGOS, AKOKA

FACULTY OF LAW

COURSE: ADMINISTRATIVE LAW II

TOPIC: OMBUDSMAN IS A LAUDABLE INSTITUTION ALTHOUGH IT HAS FAILED WOEFULLY IN NIGERIA- DISCUSS.

PROGRAMME: LL.M

NAME: THELMA IFEYINWA MAFUA

MATRIC NO. 099061003

LECTURER: DR. AMUSA

CONTENTS

1. INTRODUCTION

2. HISTORY OF THE OMBUDSMAN

3. FEATURES, MANDATE AND LIMITATIONS OF THE OMBUDSMAN 4. THE OMBUDSMAN INSTITUTION IN NIGERIA

5. THE IMPACT AND FAILURE OF OMBUDSMAN IN NIGERIA

6. CONCLUSION AND RECOMMENDATIONS

INTRODUCTION

With the existence of a great bureaucracy in twentieth century Nigeria, there are inevitable occasions when through deliberate exercise of power, error or sheer indifference, injustice is done. A man of substance can deal, if he chooses to, with such situations. He can afford to pursue legal remedies as may be available. But too often the little man, the ordinary humble citizen, is incapable of asserting himself whether under a Civilian Government or a Military regime, but more so under a Military Government whether benevolent or dictatorial. Therefore, in order to protect the ordinary citizen from undue influence, negligence, error or maladministration by government officials and staff of parastatal organizations, the Federal Military Government rightly promulgated the Public Complaints Commission Decree (Now Act) 31, 1975.

The office of the ombudsman in the public service of African States, have over the years been wobbling in its performance. The reasons being largely as a result of over-centralization of government, bureaucratization and the unwillingness of government to become truly democratic. The resultant effect has been that many citizens in African States cannot meaningfully seek redress against maladministration nor can they complain about poor governance and services delivery.

Public servants in African States should be perceived as existing to help citizens and not to make their lives difficult. That the office of the ombudsman needs to be strengthened so that all the tenets of a credible public service would be seen to be present and working to the advantage of all. This will help to put a check on government activities in the interest of the citizens, and thus help to address the problems of human rights abuses, lack of accountability and the absence of good governance.

A continental resurgence of interest has taken grip on the need to establish the office of the ombudsman as an instrument of Public Defender that would thus prevent unethical practices in Africa’s public services. The office of the ombudsman it is hoped would help the African public service to enthrone a self-check that would enforce accountability, prevent corruption and guide against maladministration.

Apart from a history of individual case studies of countries on their own instituting the portfolio of the ombudsman into their public sector practice in Africa, a wholesome approach to building an alternative mechanism for protecting the ordinary citizens against powerful state bureaucracies have not become popular.

However, national governments as well as some international organizations have started creating anti-corruption agencies and ethical bodies with large sums of money committed into the projects to bring about good governance and good ethical practices in Africa’s public institutions. Examples of these bodies are the United Nations Development Programme (UNDP), World Bank, the Commonwealth, the African Association for Public Administration and Management, amongst others. What comes from these sharing of opinions between state organs and international agencies is the fact that there is the need for the institution of the ombudsman to be strengthened throughout Africa.

The situation before now has been very pitiable. This is because; the institution of the ombudsman has been non-existent in many countries in Africa. Adamolekun (2002) summarized this whole essence when he said;

‘The number of S.S.A. (Sub –Sahara Africa) countries with ombudsman institutions increased from six (Tanzania, Ghana, Zambia, Sudan, Nigeria and Zimbabwe) in the late 1980’s to about a dozen in 1995 with Malawi, Namibia, Senegal, and South Africa among the newcomers’.

According to him, the performance of the ombudsman varies significantly amongst the countries that have caught the bug in Africa. But in each of the cases, the existence of the office of the ombudsman reflects an affirmation of a commitment to assisting citizens who seek redress against maladministration to get some reasonable amount of solution. This sends a message to public officials in Africa on the need to treat citizens with fairness and impartiality. A critical look at the situation shows that several countries in Africa have now realized the need to adopt the ombudsman plans and anticorruption institutions in their bureaucracies. One fact however remains very fundamental, and that is that these erected institutions for redress seeking have not succeeded in raising the level of accountability and good governance in Africa (Olowu: 2002).

The system whether in governance or through the operations of the public service, still shows signs of defects. This is because, not only is there a wide gap between the government and the people, leadership itself indulges in flagrant disregard for the rule of law and the abuse of power. This alienation of state from society and the perception of the state as a hostile force, reasonably leads to loss of faith in the system. This paper examines what the institution of the ombudsman means. It also went ahead to examine the history of the ombudsman and the tasks/mandate of the Ombudsman. Finally, the paper examines the impact and failure of the ombudsman in Nigeria.

CHAPTER TWO
HISTORY OF THE OMBUDSMAN

MEANING OF THE OMBUDSMAN
The ombudsman is an official, usually (but not always) appointed by the government or by parliament, who is charged with representing the interests of the public by investigating and addressing complaints reported by individual citizens (Wikipedia: 2007).

The office of the ombudsman serves as an appropriate institution for dealing with complaints from the citizens. It has the mandate to conduct inquiries concerning instances of maladministration in the activities of government. Hill (2000) argued that the major work of the ombudsman is to serve as an agent for redress against arbitrary governments or administrative actions.

Government need not appoint an ombudsman. They may work for private corporations like newspapers, Universities, schools, N.G.O.’s etc. They serve internal employees or other constituencies. These roles performed by the ombudsman are structured to function independently, by reporting to the board of directors, and do not serve any other role in the organization. As the case presently is, the ombudsman is important in the African Public Service. This is because the ombudsman plays a major role in curbing corruption, safeguarding human rights and assisting citizens to get redress in cases of maladministration by government officials.

In the twentieth century, however, with the wide spread of the Ombudsman all over the world, the stage seems set for the reassessment of its actual role. In the search for the proper role of this august body, no matter the name it may be called in different countries, it would appear that its role its clear. In the words of Sir Guy Powles:

‘A number of cases have established principles of general importance or of interest to particular departments. A greater number has concerned matters which, while of no great public moment, were nevertheless of very real importance to the individuals concerned. In its concern for the latter, the office of the Ombudsman is fulfilling one of its important and basic functions’.

In short, whether under a military regime or under ‘one party’ as in Tanzania, an Ombudsman has an effective role to play in administration. Put in a nutshell the main purport of the office of Ombudsman is to protect citizens against arbitrary authority in any shape or form. Having identified the role this ‘watch-dog’ is expected to play in an administration, it becomes incumbent on the particular country concerned to ensure that the law establishing and governing such an institution and the methods and procedure adopted by the institution should depend on the political, social and economic factors in the relevant country. The national character must find expression in the institution; a Swedish, Danish or British Ombudsman would not of necessity be of practical use in Nigeria. In Nigeria, there are certain basic factors which establish our national identity and which ought to have been taken into consideration when the law creating the Ombudsman was promulgated. Methods and procedure of investigation have to be such that will meet local conditions and environment.

For the purpose of this paper, the ombudsman is considered to be a special official in the government appointed to hear complaints from citizens concerning their grievances with the public service. The work of the ombudsman in this respect is to mediate, persuade, cajole, and otherwise seek to bring about a reasonable solution to an administrative problem.

HISTORY AND ETYMOLOGY
The word ombudsman or ‘public watch-dog’ originated from Sweden in 1809 and it has been adopted into English as well as other languages. Akindele (1992) has it that the first ombudsman system was established in Sweden in 1809, Finland in 1919, Norway in 1952, and Denmark between 1953 and 1954. The word ombudsman in Swedish means representative. The modern use of the term began in Sweden, with the Swedish parliamentary ombudsman instituted in 1809, to safeguard the rights of citizens by establishing a supervisory agency independent of the executive branch. An account by Wikipedia encyclopaedia (2007) has it that a prototype of modern ombudsman flourished in China during Qin Dynasty (221 BC), and in Korea during the Choseon Dynasty. The Romans also grappled with the problem, but it was the example of the second Muslim Caliph, Umar (634 – 644) and the concept of Qadial – Qadat which influenced the Swedish king, Charles XII. The account has it that in 1713, fresh from self-exile in Turkey, Charles XII created the office of Highest Ombudsman. The Scandinavians subsequently moulded the office into its contemporary form. It was no more than the ‘citizen’s defender’ or ‘complaints-man’.

In the Soviet Union there is the Ombudsman called the Procurator-General who exercises a very powerful supervision over most government agencies to protect the interest of the common man. As a matter of fact, many countries in recent years have in one way or another provided for an Ombudsman or similar ‘watch-dog’ over administration.

In the continent of Africa, the factors largely responsible for giving the concept a wide currency are the British Commonwealth and the influence of the French. According to Oosting (1996), the permanent commission of Enquiry in Tanzania, established in 1965 “was the first ombudsman’s institution in Africa”, and thus was in the vanguard of the dissemination of the idea especially amongst the Anglophone countries in Africa.

CHAPTER THREE
FEATURES AND MANDATE OF THE OMBUDSMAN
FEATURES OF THE OMBUDSMAN
Professor Rowat has named three important features which the ombudsman man must possess, they are: 1. He must be independent and non-partisan, whose office is usually provided in the constitution. 2. He must deal with specific complaints from the public against administrative injustice and mal-administration. 3. He has the power to investigate, criticize and publicize, but not reverse administrative action.
Imlanhimhin has also identified some salient features of the ombudsman, they include: a. Professional pre-occupation with complaints handling:- His main function is the handling of peoples complaints, thus it is necessary for him to possess technical knowledge of how to function well. b. Freedom of action:- He is generally free to act and is allowed to carry out his functions within the purview of his authority. c. Independence: The office of ombudsman is usually regarded as independent because his appointment is usually guarded against arbitrary abuse, and termination. Also his emolument is guaranteed from executive control. d. Speedy Action: The ombudsman is expected to carry out his duties speedily and without delay. e. Publicity: He needs publicity for the people to know about its existence, functions and services. f. Informality: The ombudsman is not bound by the technicalities of the courts, and thus he is allowed to be informal in his dealings. g. Persuasiveness: The ombudsman approach is usually persuasive as opposed to sanctions. h. Accessibility: The services of the ombudsman should be free, or should cost very little, in order for it to be accessible to the general public.
FUNCTIONS OF THE OMBUDSMAN
The task of the ombudsman generally is to conduct investigations and then give judgments. These investigations arise from complaints made by the public about the activities of government agencies. Akindele (1992) while quoting Van Leen and Whittington gave the functions of the ombudsman to be universally the same. That is;
(a) To protect the rights of the citizens;
(b) To act as an indirect check on the misuse of powers by the administrators or any government officials;
(c) To investigate, publicize abuses of bureaucratic power and in some cases to initiate legal action much as a private citizen would.
From the context of the performance of government, the ombudsman can be regarded as an official appointed to provide a check on government activities in the interest of the citizens, and to oversee the investigation of complaint of improper government activity against the citizens. If the ombudsman finds a complaint to be substantiated, he publishes a report to that effect. However, the laws of each individual country determines to a large extent how far the ombudsman can go if cases becomes too unwieldy for him to handle.
In many countries around the world, where the institution of the ombudsman exists, the office of the ombudsman is made to function in all ministries and departments of the central government, as well as in many states, provincial or local government. Examples of some of these countries from the western world are countries in the Scandinavian enclave, Canada, Australia, the United Kingdom etc. As for the continent of Africa, few examples like South-Africa, Ghana, Senegal, Nigeria, Tanzania, Algeria, etc., easily comes to mind.

The continent of Australia provides a classical case for the task performed by the ombudsman. Reference is being made to Australia here because counties in the continent of Africa would have a lot of lessons to learn here. In this country, the ombudsman offices deal with rights problems in all areas of government. The work of the ombudsman has transformed government in terms of its accountability and sensitivity of individual rights. McMillan, who was a former ombudsman in Australia and is now a commonwealth ombudsman, said this much about Australia;

The office of ombudsman is one example of an independent overseeing agency that is beyond the judicial and legislative branches of government … this new system of overseeing and accountability has developed in response to the shortcomings of legislative and judicial methods in providing effective practical protection of people’s rights (McMillan: 2006).
The function of the ombudsman may be enshrined in the country's constitution and may also be provided by legislation, or formed by an act of the legislature.
The duties of the ombudsman is to protect the people against abuse of power, error, violation of their rights, negligence, unfair decisions, oppression and maladministration in order to enhance public administration and ensure that the government's actions more transparent and that government and its workers more accountable to its people.
In many nations all around the world there is usually the office of the ombudsman who deals with complaints from the public regarding, actions or omissions, and decisions of public administration. The holder of this office is sometimes elected by parliament or may be appointed by the government alone or after consultation with the legislature.
The ombudsman has powers to make a detailed investigation into complaints from the general public about the administration of government. The ombudsman also has the power to initiate an investigation even if a complaint has not been initiated. To ensure that people’s rights are the protected the ombudsman has the following powers: 1. Power to investigate whether the administration of government is being performed accordingly or contrary to law or unfairly; 2. Where a thorough investigation discovers improper decision or administration, make recommendations to amend the improper administrative conduct; and 3. Prepare a report of his activities in specific cases to the government and the complainant and, if the recommendations made in a specific case have not been accepted by the government, to the parliament. Most ombudsmen also make an annual report on their work to the parliament and to the general public.
The ombudsman generally does not have the power to make decisions that are binding on the government. Rather, the ombudsman makes recommendations for amendment, as provided by a detailed and thorough investigation into a matter that has been complained. An important matter in carrying out the duties of the ombudsman is that his office must be independent from the executive/administrative branch of government. In order that the ombudsman's investigations and recommendations is credible to both the general public and the government, the office of the | ombudsman must remain and protect the impartiality and integrity of his office.
Generally, an ombudsman is a government official appointed to provide a check on government activities on behalf of its people, and to monitor the investigation of complaints of improper government activities against the general public. Where the ombudsman finds a complaint to be in order or substantiated, the complaint may get rectified, or an ombudsman report is published making recommendations for amendments. Further redress depends on the laws of the country concerned, but it usually involves financial compensation. The office of the ombudsman in most countries does not have the power to initiate legal proceedings or prosecution on the grounds of a complaint, this function is usually referred to as a "tribunitian" role, and has been traditionally fulfilled by elected representatives – the word refers to the famous ancient Roman "tribunes of the plebian" (tribuni plebis), whose duty was to intercede in the political process on behalf of the common people.
The major function of the ombudsman is that he or she investigates complaints from administrative institution, thus preventing the conflicts of interest inherent in self-policing. However, the ombudsman system relies heavily on the appointment of an appropriate person for the office, and on the cooperation of at least some effective officials from within the state. Perhaps for this reason, outside Scandinavia, the introduction of ombudsmen has tended to yield mixed reaction.
In general, the public sector ombudsman has a general jurisdiction over a variety of governmental organizations. For some, it may include the executive, legislature, judiciary, police and military, while in several other countries, one or more of these may be specifically excluded. Several countries have also created ombudsmen who deal only with specific areas of government functions such as corruption allegations, police brutality, and violence in particular locations, access to information, health issues, or ethical conduct of officials. In other situations, the ombudsmen have specific mandates to protect the territory, deal with racial, cultural or linguistic rights, or to investigate corruption in government. In recent years, many countries around the world have been making the transition to democratic forms of government. As part of the democratization of government, they have often created ombudsman offices to improve government administration. Some of these new offices have been given the explicit duty to investigate complaints from members of the public whose human rights have been infringed upon by the government. These offices are sometimes given additional powers, such as the right and power to initiate actions to protect human rights guarantee or the mission to promote human rights education.
Several countries have established human rights council or commission which uses the ombudsman concept as the means of enhancing the protection of human rights. In these countries, the human rights commissions act as ombudsmen in investigating complaints from the general public, they also carry out active educational programs to create a human rights orientation.
The concept of the ombudsman has also been adapted for use by the private sector as a form of internal dispute resolution and also to handle complaints made against the private entity by its customers. Thus, there may be "ombudsman" schemes for banks, schools, private health care facilities, corporations etc.
FUNCTIONS OF THE PUBLIC COMPLIANTS COMMISSION: 1. Initiating investigations into matters of general interest. 2. Receiving complaints from people and investigating them if it is within its purview. 3. Recommending the result of its investigation to the right authority for it to take action. 4. Making recommendation to the appropriate authority on the need to modify any existing law which may be unjust.
To protect citizens and residents in Nigeria against any act of administrative injustice, every public complaints commissioner is to investigate the following acts according to Adamolekun,1981 pg 307-326: 1. Contrary to any known or existing law or regulation. 2. Mistaken in law or arbitrary in ascertainment of fact 3. Unreasonable, unfair, oppressive, or inconsistent with the general functions of administrative organs. 4. Improper in motivation or based on irrelevant consideration 5. Unclear or inadequately explained or otherwise objectionable.
The following strengthens the powers of the Commission: a. Any commissioner shall be able to access all information necessary for the efficient performance of his duties....... and may visit any premises belonging to any person involved. b. A commissioner has the powers to summon in writing any person who is in the opinion of the commissioner is in the position to testify on any matter before him to give evidence in the matter and any person who fails to appear when required to do so shall be guilty of an offence.

LIMITATION OF POWERS OF THE COMMISSION:
The commissioner is prohibited from taking the following actions: 1. Actions that are clearly out of its terms of reference. 2. Matters that are before the Federal or state government. 3. Matters before any court of law in Nigeria. 4. Acts that have being carried out or purported to be carried out by any member of the armed forces or police force. 5. Where the complainant has not exhausted all possible avenues of redress. 6. Relating to the any act that has being done before24thJuly, 1975 or where the complaint is lodged later than 12months after the act from which the complaint arose. 7. Where the complainant has no personal interest.
The main business of the Public Complaints Commission is the resolution of complaints. The types of complaints that the Commission entertains include administration acts which are or appear to be: a) Contrary to any law or regulation in Nigeria; b) Mistaken in law or regulation in Nigeria; c) Unreasonable, unfair, oppressive or inconsistent with general functions of administrative organs; d) Unclear or inadequately explained; e) Improper in motivation or based on irrelevant considerations or otherwise objectionable; f) Administrative procedures of courts of law in Nigeria.
Arising from the above, examples of cases that the Commission can handle include: * Wrongful dismissal from service; * Wrongful termination of appointment; * Wrongful computation of benefits/contributions; * Difficulty in getting Insurance Companies to pay claims; * Failure to get refund of amount over paid to tax authorities; * Loss of postal or money order/lost of luggage – e.g. by NIPOST, etc. * Complaints against NITEL, PHCN, etc. * With-holding of superannuation benefits; * Non-release of examination results by WAEC, NECO, etc. * Police, Military/Armed Forces brutality or misuse of power; * Delay in getting: i. Any department or Ministry of Federal or State Government or Local Government Authorities to pay compensation for land acquired for public use for economic trees or property destroyed during the acquisition ii. Payment of retirement benefits; iii. Payment of death gratuity to the family of the deceased; iv. Payment of workmen’s compensation, etc.

CHAPTER FOUR
THE OMBUDSMAN INSTITUTION IN NIGERIA

HISTORICAL BACKGROUND
The body that is known as the Public Complaints Commission in Nigeria is better known as the Ombudsman all over the world. The Public Complaints Commission (Nigerian Ombudsman) is an independent organization established by the Federal Government of Nigeria in 1975 through Decree No. 31 of 1975, amended by Decree 21 of 1979, now Cap 377 Laws of the Federation of Nigeria 1990 and revalidated in Section 315(5) of 1999 Constitution.

AIMS AND OBJECTIVES
The main aim of the Public Complaints Commission is to promote social justice for the individual citizen without which there can hardly be genuine peace and stability in Nigeria. It was established to provide viable options for Nigerians or anyone resident in Nigeria, seeking redress against administrative injustice arising from bureaucratic errors, omissions or abuse by official of governments or limited liability companies in Nigeria. It is also to improve public administration in general by pointing out weaknesses observed in the laws, procedures, practices, rules, regulations and standards of behaviours of officials.

THE ESTABLISHMENT OF THE OMBUDSMAN IN NIGERIA UNDER A MILITARY ADMINISTRATION
The report of the Public Service Review Panel, which was set up by the Federal Government to look into the conditions of service of all public workers in the federation, better known as the Udoji Report, had in paragraph 181-187, in 1974 recommended the setting up of the institution of an ombudsman fir better administration in the country.
The Government noted the recommendation. However, as soon as General Murtala Mohammed came to power in July 1975 it was arranged that a team should study the role and activities of the Ombudsman in Africa and elsewhere. The team submitted its report and the Government decided immediately on the establishment of the Public Com-plaints Commission. The Federal Military Government of Nigeria promulgated on the 16th October 1975, the Public Complaints Commission consisting of a chief Commissioner and twelve other Commissioners appointed by and has power to investigate either on its own initiative or on complaints any administrative action by Federal or State agencies, statutory corporations, local government authorities and public institutions, and companies whether in public or private sector, and officials thereof. It has some limitations. For example, it cannot investigate anything done before 29th July, 1975. Suffice it to say that in 1979, Public Commission (Amendment) Decree 21 was promulgated. It made sundry amendments to the Public Complaints Commission Decree 31 of 1975 and among other things; it conferred immunity from legal process on the public complaints commissioners in the performance of their official duties.

WHY ESTABLISH THE PUBLIC COMPLAINTS COMMISSION IN NIGERIA UNDER THE PRESIDENTIAL SYSTREM OF GOVERNMENT?
It now becomes necessary at this juncture to examine the adequacy or otherwise of the provisions of the Act setting up the Public Complaints Commission in the light of our political, social and economic conditions in Nigeria of the eighties under the Presidential system of Government. But before starting to analyse the provisions of the Act setting up the Public Complaints Commission, it becomes very pertinent to answer the questions whether under our system of presidential government there was need for this type of commission. It has been argued that under the Military regime the role of the Ombudsman was understandable. But under an elected presidential system with an independent judiciary coupled with easy access to courts and legal representation of one’s choice it became unnecessary to have the Public Complaints Commission. Some even said, erroneously, that in the United States of America whose model of constitution Nigeria seemed to have adopted, there was no public complaints commission.

It is however, submitted that the commission which plays a similar role to the judiciary, as little or no cost to the aggrieved brings a ray of hope to the common man or the less privileged citizens of Nigeria whose rights are daily trampled upon with impunity by well-placed functionaries of various governments, parastatals, private or even individual persons who derive pleasure from riding roughshod over the rights of the weak and the helpless in our society. The public Complaints Commission is meant to be a poor man’s court if properly constituted, organised and operated. It has even served a university professor and other highly placed members of our society at almost no cost. As to the existence of this type of institution in the United States of America, there are at least seventeen states with Ombudsmen and in every state of America the institution exists under one name or the other. The point, of course, is not that because the Ombudsman institution in exist in America and therefore it should be imported into Nigeria regardless of its usefulness. The truth indeed is that Nigeria as an independent and developing country should have as one of its principal objectives good administration. But the historical snobbery inherited from our erstwhile colonial civil servants still remains in certain quarters of our public service and it has a most alienating effect on the ordinary man. Moreover, it is not every wrong that is justiceable in our law courts. The consequential effect is that no matter what checks and balances you may have under our constitution, the Public Complaints Commission still has its own useful role to play, depending of course, on the provisions of the Act and methods of operating it by the different commissioners who have a duty so to do.
Attention will be focused on some omissions such as power to deal with continuing injustice, annual report, issue of ‘locus standi’ and power to deal with an individual in authority but not under any of the bodies covered by the Act.

DEFECTS IN THE PROVISIONS AND MODE OF OPERATION
Section 4(1) of the Act says, interalia, that all Commissioners shall be responsible to the Supreme Military Council at the head of which is the Head of State and Commander-in-chief of the Armed Forces. During the first military regime this provision might have worked well. By virtue of Section 18(4) of the Interpretation Act of 1964, that Act shall apply for purposes of interpreting the provisions of the Public Complaints Act as laid down by section 277 (4) of the constitution. Section 18(4) Interpretation Act, 1964 provides:
‘A reference in an enactment in relation to any functions to an official described by a designation which under the system of government in a particular part of Nigeria is no longer appropriate in relation to the functions shall be construed in relation to those functions and that part, as a reference to the person on whom the functions have devolved under the system of government for the time being in force in that part’.

Even if the above section 18(4) of the Interpretation Act is applied to section 4(1) of the so Public Complaints Act so that the president as the commander-in-chief of the Armed Forces with his Council of Ministers can be substituted for the supreme military council, or in the alternative the National Assembly for the Supreme Military Council because of the dual role the Supreme Military Council plays under military regimes, the fact remains that the Act still needs an amendment in this connection. This section should be amended in such a way that the Chief Commissioner is responsible to the President and the other Commissioners should be responsible to the Chief Commissioner. This course of action is advocated because of the submission of annual report. At the moment, there is no provision for the submission of annual report. It is suggested that the Act should make it mandatory for an annual report by each commissioner to be submitted through the Chief Commissioner who will have a duty of collating all the reports from all the sates to be placed before the president for onward transmission to each state assembly and the National Assembly for the necessary and meaningful debate. However, it will be argued later that the commission should be merged into the judiciary to which it should properly belong.

Section 4(2) (a) sets out a list of persons or bodies over which the commission has power of investigation. Unfortunately, this list omits individuals acting in their individual capacities and oppressing fellow Nigerians. The reports of the Commission show that such cases exist and the Commission has been handling them. For example Mr. A approached Mr. B a licensed land (estate) surveyor at X town to survey 2 plots of land for him in December 1978. The surveyor charged Y naira which was paid. But the surveyor did not undertake the job until; ‘he was summoned before this Commission’. He has since released the survey plans to Mr. A the complainant.
It is submitted that any amendment in this area should cover individuals especially professionals, like the lawyers, doctors, surveyors etc who are self-employed so that the Act may meet the practical needs of the common man. It may be argued that his is a matter of private and not public administration or a matter of contract and a breach of which can easily be redressed in our courts. A poor man will readily forgo his rights in our society today rather than to go to court for many reasons. Another point that has to be made here is that the surveyor in question did not show up at the commission or prepare the survey plan until he was threatened with the application of section 8 of the Act by the Commission. Section 8 provides: (1) In the discharge of his functions under this Act a commissioner shall have power to summon in writing any person who in his opinion of the commissioner is in the position to testify on any matter before him, to give evidence in the matter and any person who fails to appear when required to do so shall be guilty of an offence under this Act. (2) Any person guilty of an offence under this section shall on conviction be liable to a fine of N500 or imprisonment for six months or to both such fine and imprisonment.
It may well be that if the surveyor was aware that the Act does not cover individual situations like his own, he would have protested against the jurisdiction of the commission and the obvious wrong would have remained unremedied.

DEVELOPMENT OF OUR LAWS THROUGH THE PUBLIC COMPLAINTS COMMISSION
Section 4 (3) (d) (i) (iv) provides thus: (3) For the purposes of this Act……………………………..
(d) Every commissioner shall ensure that administrative action by any person or body mentioned in subsection (2) will not result in the commitment of any act of injustice against any citizen of Nigeria or any other person resident in Nigeria and for that purpose he shall investigate with special care administrative acts which are or appear to be * contrary to any law or regulation * mistake in law or arbitrary in the ascertainment of fact * unreasonable, unfair, oppressive or inconsistent with the general functions of administrative organs * improper in motivation or based on irrelevant considerations * Otherwise objectionable
The above-quoted provisions offer not a wonderful opportunity for the commission to make an everlasting contribution to the jurisprudence of this country, but also a golden chance to detect most of the weaknesses in our Rules, Orders, Regulations especially in the civil service ‘Bible’ called the General Order (G.O) handed down to us by our erstwhile colonial masters and the laws that affect the liberty and happiness as well as the social, economic and political life of the common man in this country.
Going through the reports of the commission one is left in no doubt that the commission has made a few recommendations. For example, in May 1978 two national newspapers, the weekly star and the Nigerian Herald published a shocking discovery by the police of a school in plateau state where children between ages of nine and thirteen were being trained as ‘thieves and robbers’. Those of the students who were arrested by the police confessed that they had successfully taken part in thefts of cars and raids on public places. The Commissioner like every reasonable Nigerian was no doubt shocked and made some recommendations in that regard. This is a fertile ground for a surgical operation to be carried out on our criminal laws and particularly out-dated Criminal Procedure Act. Because of the secrecy with which its work is done and the fact that the reports are never debated, whatever recommendation that was made by the Commission may never be carried out by the authorities who should do so. Another example is to be found as a result of a petition dated 17 June 1977 from a gentleman from X state. The petitioner complained of academic victimisation by the principal and the Bursar of his institution which resulted in the non-release of his examination result. On receipt of the petition the Commission advised the authorities to set up a Board of Inquiry which found the bursar culpable and disciplined him accordingly. The Commission then made the following recommendations about rules and regulations of higher institutions generally:
............one can safely conclude that students indiscipline and revolt is a matter of cause and effect and that any genuine efforts at eliminating revolts and indiscipline in our institutions should primarily be directed to removing the causes of such unrest and indiscipline. In this regard it is worthwhile to involve students as much as possible in taking policy decisions that affected them directly or indirectly. They need to be actively involved in the government and administration of their institutions. This will remove the impression in the students that the administration of their schools and colleges is secretive, bureaucratic and antagonistic to their interests. There should also be a lubricated channel of communication between the authorities of the institutions and their students. Apart from this being one way by which the authorities could show respect for their students as human beings, it provides a method of probing the mind of the students on any issue, correcting their misconceptions and forestalling any suspected revolt.

The institutions of higher learning in this country may know about the above recommendations but it does not appear that those in authority have made any effort to amend the laws, rules and regulations establishing the institutions to take account of the suggestion.

In fairness to the Military Government, it has been said that it was a result of the series of the petitions received by the Commission, for example a technician at the State hospital alleged that a medical doctor indulged in a gross abuse of office and professional indiscipline by making use of hospital facilities for his private patients, that the then Federal Military Government promulgated the Regulated and Other Professional (Miscellaneous Provisions) Act of 1978. It is to be hoped that the various Governments all over the country will emulate this and modernise our archaic rules, regulations and even statutes whenever meaning suggestions are made by the Public Complaints Commission. Such suggestions, however, must be sent to the various Law Reform Commissions in this country for further consideration and early necessary action to effect the desired change.

JURISDICTIONAL PROBLEMS OF THE COMMISSION
Section 5 of the Public Complaints Act states that a commissioner shall not investigate any matter: (a) That is clearly outside his terms of reference (b) That is pending before the Armed Forces Ruling Council, the National Council of States or the Federal Executive Council. (c) That is pending before any Court of law in Nigeria (d) Relating to anything done or purported to be done in respect of any member of the Armed Forces in Nigeria or the Police Force under the Nigerian Army Act 1960, the NAVY Act 1964, the Air force Act 1964 or the Police Act, as the case may be (e) In which the complainant has not, in the opinion of the Commissioner exhausted all available legal or administrative procedures (f) Relating to any act or thing done before the 29 July 1975, in respect of which the complaint is lodged later than twelve month after the date of the act or thing done which the complaint arose (g) In which the Complainant has no personal interest.
In the first place, it has been shown that the Commission has in fact been investigating cases that fall outside its jurisdiction and an amendment has been advocated in this connection. Secondly, the Armed Forces Council did not exist under the civilian regime and therefore section 5(1) (b) needs to be amended. Section 5(1) (d) which deals with the Armed Forces and the Police calls for urgent amendment for many reasons. In the first place the Commission has been dealing with matters affecting these bodies since its inception in Nigeria and there is reason to believe that this may continue.

For example on the 25 October, 1976, a woman from Queen’s School in X town called at the Commission to complain that the Police illegally towed away her car from where she parked it sometime in September that year. She explained that the spot on the right of the road where she parked the car was not a prohibited place. The Public Complaints Commission took the matter up with the Commissioner of Police in the State who immediately, after investigation, ordered his officers of the Motor Traffic Division to release the complainant’s car and tender an apology to her for the inconvenience and embarrassment caused her. Putting it mildly, the police action in this case is a combination of high handedness and sheer ignorance of the laws they are supposed to enforce. This is no doubt is an act purportedly done under the Police Act. One can then imagine how many millions of Nigerians and aliens have suffered similar or even worse fate in hands of our Commission Akure, Annual Report October 1978 to December 1979n affecting the Armed forces as well as the police.
Similarly page 12 of the 1980 Annual Report shows that the commission in that state alone handled 14 cases affecting the Nigerian Police, 8 Nigerian Army and 1 Airforce’. It goes without saying that despite the provisions of Section 5 (1) (d), the commission had been handling cases affecting these untouchable bodies. In a military regime that provision is perhaps understandable. But under a civilian system of government it should be amended. In America for instance, the Army Inspector General Tribunal is set up which is headed by the Inspector General of Army. Complaints or requests are sent from any citizen or through the members of the Congress. In respect of the Navy, the commander also functions as the Navy’s Ombudsman. If for security reasons there had not been cause to throw our Armed Forces open to civilians, the American system may be adopted. But most certainly they should not be made to feel that they are above the law as the present situation under the Public Complaints Act seems to portray.

POWER TO STOP CONTINUING WRONG
It is suggested that the Act should be amended in such a way that the Commission will have the power to stop a continuing wrong where it detects one. An example of continuing wrong is the case of an alleged murder of a baby by a man. The accused was tried, discharged and acquitted. But on getting back home he was mercilessly beaten by the parents of the baby. He was molested daily by them. He reported to the police who did nothing. He had to move out to another town. However, each time he came home he was either threatened or beaten by the parents of the deceased baby. It is agreed that in many countries, because Ombudsmen do not have executive but advisory powers, they have no power to stop or compel the administration to do one thing or the other. But at this stage of our development it will not be out of place if the commission is given power to grant an interlocutory injunction. This power will not change its nature as may be argued by some people, after all its work is quasi-judicial although it is part of the executive arm of government rather than the judiciary. If it is for this reason alone, it is strongly suggested that it may it be made part of the judiciary rather than the Executive. In fact the Judiciary is better equipped to manage the Public Complaints Commission that the Executive over which it keeps watch. But it must not charge fees for discharging its duties. It will certainly make for better administration if the public Complaints Commission is empowered to stop a continuing wrong pending a final decision by the appropriate authority. It may be argued that the commission has the power to recommend for prosecution under Section 6 (3) of the Act but power to recommend is certainly not the same thing as power to stop offending authority from further action.

INTRODUCTION OF LOCUS STANDI UNDER PUBLIC COMPLAINTS COMMISSION
Section 5(1) (g) provides thus-
A commissioner shall not investigate any matter…………..in which the complainant has no personal interest.

It is submitted that Section 5(1) (g) of the Public Complaints Commission Act has clearly introduced the doctrine of ‘locus standi’ which may be defined as the right of a party to appear and be heard on the question before any court or tribunal. The fundamental aspect of the locus standi or standing to sue is that it focuses on the party seeking to get his complaint before a tribunal and not on issues he wishes to have adjudicated or remedied. Put in another way it means (i) a man who seeks a remedy before the Public Complaints Commission in Nigeria against an administrative error or act must show that he is directly affected by that act before he can be heard., (ii)n a general interest common to all members of the public is not per se a complainable interest to accord standing before the Public Complaints Commission, (iii) there must be assertion of a right by such person personal to him and that right must have been infringed or that there is a threat of such infringement. The above three conditions imposed by the strict application of the doctrine of ‘locus standi’ are difficult to reconcile with the provisions of section 4 (3) (d) (i) (iv) of the Act.

It is submitted that in view of the provisions of section 4 (3) (d) (i) (iv) of the Act there will be a grave lacuna in our system of public law if a pressure group or even a single public spirited tax payer, were prevented by out-dated technical rules of ‘locus standi’ from bringing any matters in of section 4 (3) (d) (i) (iv) of the Act. To attention of the Public Complaints Commission to vindicate the rule of law and get the unlawful administrative conduct stopped. Although, we are not aware of any case rejected by the commission on the basis of locus standi, it is advisable that section 5(1) (g) be deleted to prevent this problem in future.

THE PUBLIC COMPLAINTS COMMISSION AND THE CONSTITUTION
When the Constituent Assembly rejected the provision in Section 81 (1) of the Draft Constitution that there should be a public complaints commission it became clear to the Federal Military Government that unless 5the Commission was entrenched in the constitution, the Public Complaints Commission might not last longer than October 1979. The Constituent Assembly felt that there should be no need for such a body in post-military Nigeria. In any case, if the need arose after the military regime, the institution could be established by an Act of parliament. Whatever the arguments had been, a look will now be taken at the provisions of the constitution and the public complaints commission Act.

Various aspects of the Public Complaints Act which ought to be amended in the foregoing paragraphs have been dealt with at length. It is timely at this juncture to say that the provision of section 274(5) of the constitution provides, 5. Nothing in this constitution shall invalidate the following enactments that is to say-
(b) The Public Complaints Act 1975
And the provisions of those enactments shall continue to apply and have full effect in accordance with their tenor and to the like extent as any other provisions forming part of this constitution and shall not be altered or repealed except in accordance with the provisions of Section 9 (2) of this constitution.

Although, it would appear that the Supreme Court has said in Chief R.O Nwocha v. Governor of Anambra State & ors (1981) suit no: E/167/81 (Unreported Enugu) H/CJ that the statutes enumerated in section 274(5) are, merely entrenched in, but not part of, the constitution, this is a moot point. However since this is an entrenched clause, section 9(2) applies. And section9 (2) makes it extremely difficult to amend the Act, it therefore means that no matter however absurd any part of the Act may look like, or no matter what hardship it works in actual practice, the proper and difficult procedure of amending the entrenched clause of the constitution must be adopted for valid amendment to be carried out. To say the least, this is most disturbing in view of the urgent need for obvious amendments as outlined above. If therefore the overdue amendments cannot easily be carried out, the situation calls for spirit of give and take on the part of all Nigerians who believe that the Public Complaints Commission has a lot to contribute to the welfare of and good administration in this country. In the words of Chief Michael Adekunle Ajasin, the then Governor of Ondo State the ‘establishment of the Public Complaints Commission is one of the achievements of the Federal Military Government to help poor people’. As a matter of fact the commission is to try to stop the tyrannies and official malpractices that are so common in developing countries and are perpetrated against the weak, poor and/or ‘the less privileged, so common in human establishments in our society that is more often than not devoid of justice and discipline’. As a matter of fact the fundamental objectives and directives principles of State Policy set out by the Federal Military Government and put in our constitution may be difficult to attain unless there is a special machinery to grant quick and cheap redress to the individual for administrative errors. This is not to say that the constitution and the general principles of law do not provide for the review by the courts and other tribunals of administrative action taken in pursuance of the exercise of discretionary powers vested in different authorities or arms of the government.

It was thought by the then Military Government, and rightly too, that the supervision by the Courts was limited in scope, sometimes rather expensive and technical for the common people to easily take advantage of it. It therefore established the Public Complaints Commission. It is fair, however, to state that before a national commission was established, Kwara and the then North-Central states established similar bodies respectively but which were later absorbed by the national one. The reason for establishing the Public Complaints Commission was vividly brought by what the Ondo State Public Complaints Commission said at page 54 of its 1978-1979 Annual Report thus:
‘From the list of selected cases treated on the foregoing pages, it is easy to see how many people do suffer in silence without any means, financial or otherwise, of seeking redress or even if there is the avenue for redress, due to ignorance, the affected may not know how to go about it and will resign himself to fate since what cannot be cured must be endured’.

In spite of the above quotation, it is still on record that many of the common people in this country do not know of the existence of the Complaints Commission. This is the view of the existence of the fact that the Annual Reports of the Commission are all devoid of complaints from our universities. One wonders whether the undergraduates in our universities in this country are aware of the existence of the Public Complaints Commission and its functions. This is doubtful otherwise they might have sent most of their complaints to the commission rather than resorting to violence in many cases.

CHAPTER FIVE
THE IMPACT AND FAILURE OF OMBUDSMAN IN NIGERIA
In Nigeria the concept of the ombudsman has failed woefully for several reasons, these reasons include: a. The inability of the public complaints commission to function independently. The commission’s activities are interfered by the government and its officials, thus preventing the ombudsman from carrying out his duties effectively. b. The Commission’s officials are often bereft of the technical expertise that is required of the job; this prevents them from carrying out their duties efficiently. c. The services of the commission which should be free are not, and thus are not affordable and accessible by the masses. d. There was no public awareness of the importance of the commission and its various functions. There were no vigorous publicity on the radio and television dealing with its powers and duties in both the national and state network services of our news media. Neither were there publications in the dailies. e. The failure of the local government in the states of the country to establish a local office of the commission led to the failure of this laudable commission. f. The public Complaints Commission Annual Reports were not made available for sale to the public. g. The commission themselves did not undertake frequent enlightenment tours and trainings to explain to both the officials and the people what the commission stands for in languages spoken in their areas of operation. h. The complaints of the public were not heard as there were postal difficulties in the country without the availability of special complaints boxes set up in local government headquarters into which complainants can drop written complainants which will be collected later by the commission. i. There was no provision for the children Ombudsman with the main object of furthering the interests of children in our society. The investigations may be self-initiated or on the request of others. Accesses to all private and public institutions for children were not guaranteed by the section of the Public Complaints Commission Act establishing it. j. There was no legal officer on the staff of the Commission in each state. In most countries, as a matter of fact, the Commissioners are themselves legal luminaries of the justices of the Supreme Court calibre or at least High Courts. k. The Commission was not made part of the judiciary to which it should properly belong to, rather than the executive.

RECOMMENDATIONS/SUGGESTIONS
The following suggestions are put forward for the consideration of the Federal Government and the Chief Commissioner for the improvement of the commission. (a) There should be frequent radio and television talks dealing with its powers and duties in both the national and state network services of our news media. This should be supported with occasional publications in the dailies. But in almost all publications local languages must be used or renditions in such languages or dialects immediately after the English version have been given. (b) Even local government in the states of the country must establish a local office of the commission. (c) The public Complaints Commission Annual Reports must not only be rendered in both English and local languages, they must be available for sale to the public. (d) The commission themselves must undertake frequent enlightenment tours to explain to both the officials and the people what the commission stands for in languages spoken in their areas of operation. (e) In view of the postal difficulties in this country as of now special complaints boxes should be set up in local government headquarters into which complainants can drop written complainants which will be collected later by the commission. (f) A children Ombudsman must be established with the main object of furthering the interests of children in our society. The investigations may be self-initiated or on the request of others. Access to all private and public institutions for children must be guaranteed by the section of the Public Complaints Commission Act establishing it. It will be the duty of the Ombudsman to safeguard children’s interest by making sure that all laws protecting children’s interest re obeyed. The Act should suggest measures to strengthen the legal protection of the children propose measures to solve or prevent conflicts between the children and society and also make sure that sufficient information is given to public and private authorities about children’s rights and the measures they require. (g) A legal officer should be on the staff of the Commission in each state. In most countries, as a matter of fact, the Commissioners are themselves legal luminaries of the justices of the Supreme Court calibre or at least High Courts. (h) The Commission should be made part of the judiciary to which it properly belongs, rather than the executive.
It is true that the first annual report of the commission issued in March 1977, covered the first 15 months of operation, during which the Commission received only 6, 777 complaints. The second Annual Report covering 1977 shows the receipt of 8, 357 complaints and there have been slight increases mainly in Ondo State since then from year to year. It is, however, submitted that if the Act is amended along the lines suggested above and the above suggestions on the working of the commission are taken care of by the commission itself, the number of complaints will run to millions every year resulting, of course, in better administration.

CONCLUSION
An attempt has been made to trace the history of the Ombudsman generally but with particular reference to the Public Complaints Commission under the military regime and the presidential system of government in Nigeria. The main objectives of any watch-dog like the commission in Nigeria can be summarised thus:
In the first place to keep a balance between the citizens especially the little man who is unable to assert himself and the government officials and staff or parastatals organizations. Secondly, to ensure justice between the ordinary humble citizen and a man of substance known as the ‘big shot’ in society. We have examined the provisions of the Public Complaints Act and find them to be grossly inadequate in some parts and in many areas defective for the purpose of the above stated objectives.
Suggestions for amendments have therefore been made. But the serious handicap in the way of amendment lies in the fact that the Public Complaints Act is an entrenched part of the suspended 1979 Constitution, consequently, it could not be easily amended. Although the Public Complaints Commission, like its counterparts the world over, is advisory and not executive, from the records it is doing very useful work in our society at this stage of our development. If properly organized it can perform better. It will make citizens grow conscious of their rights and will be able to ask for them as citizens do in more developed countries. It may well be an easy way to awaken a ‘National Ethic’ which people talk so much about in Nigeria now., because indiscipline is the main cause of almost all the ills in Nigerian society. Indiscipline breeds inefficiency, corruption and maladministration, and the commission is out to cure indiscipline in the society.
If the Act is defective and it is rather difficult to get it amended, the question then will be: is the commission to fold up or stop operating until the obvious amendments are affected? The commission is certainly an expression for real democracy and the rule of law that Nigeria keeps a special institution with the task to control and ensure that almost all administrative organs of the society respect the rights of the citizens and that anybody in the society be he a Nigerian or not poor or without social position, has a right to get, without costs, his complaints against the society investigated and tried even if the highest official in the society in involved.
In the words of Chief S.F Adeniran ‘on the whole, it is safe to say that the commission had so far not done badly and that it is daily gaining the confidence of a wider circle of people who take it as their last hope, able to champion their cause to success’.
It is submitted that the development the development of a national ethic can come through the Public Complaints Commission by building up a tradition for protecting individual against the mighty hands of the administration. This is what Tanzania is doing through the Permanent Commission of Inquiry in that country; there is no reason why it cannot be done in Nigeria. In any case, the Act can now be easily amended during the present military regime.

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[ 1 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 393.
[ 2 ]. THE OMBUDSMAN PHENOMENON IN AFRICAN STATES PUBLIC SERVICES BY Dr. MUKORO Akpomuvire.[Male] Department of Local Government Studies Obafemi Awolowo University Ile-Ife, Osun State, Nigeria, E-mail = [e-mail], page 3.
[ 3 ]. See footnote 2 page 4
[ 4 ]. See footnote 2 page 4
[ 5 ]. See footnote 2 page 4
[ 6 ]. See footnote 2 page 4
[ 7 ]. Adamolekun, Ladipo (2002): Public Administration in Africa. Ibadan, Spectrum Books Limited referred to by Dr. MUKORO Akpomuvire Department of Local Government Studies Obafemi Awolowo University Ile-Ife, Osun State, Nigeria, E-mail = [e-mail] in THE OMBUDSMAN PHENOMENON IN AFRICAN STATES PUBLIC SERVICES
[ 8 ]. THE OMBUDSMAN PHENOMENON IN AFRICAN STATES PUBLIC SERVICES BY Dr. MUKORO Akpomuvire.[Male] Department of Local Government Studies Obafemi Awolowo University Ile-Ife, Osun State, Nigeria, E-mail = [e-mail]
[ 9 ]. THE OMBUDSMAN PHENOMENON IN AFRICAN STATES PUBLIC SERVICES BY Dr. MUKORO Akpomuvire.[Male] Department of Local Government Studies Obafemi Awolowo University Ile-Ife, Osun State, Nigeria, E-mail = [e-mail]
[ 10 ]. Hill, L.B. (2002): “The Ombudsman Revisited: Thirty years of Hawaiian Experience” in Public Administration Review Vol. 24. referred to by BY Dr. MUKORO Akpomuvire Department of Local Government Studies Obafemi Awolowo University Ile-Ife, Osun State, Nigeria, E-mail = [e-mail] in THE OMBUDSMAN PHENOMENON IN AFRICAN STATES PUBLIC SERVICES
[ 11 ]. THE OMBUDSMAN PHENOMENON IN AFRICAN STATES PUBLIC SERVICES BY Dr. MUKORO Akpomuvire.[Male] Department of Local Government Studies Obafemi Awolowo University Ile-Ife, Osun State, Nigeria, E-mail = [e-mail]
[ 12 ]. New Zealand Ombudsman Report 1964 p.g 5 referred to in Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 394
[ 13 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 394-395
[ 14 ]. THE OMBUDSMAN PHENOMENON IN AFRICAN STATES PUBLIC SERVICES BY Dr. MUKORO Akpomuvire.[Male] Department of Local Government Studies Obafemi Awolowo University Ile-Ife, Osun State, Nigeria, E-mail = [e-mail]
[ 15 ]. See footnote 14
[ 16 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 394
[ 17 ]. See footnote 14
[ 18 ]. Donald C.Rowat (1965) The Ombudsman: Citizens Defender
[ 19 ]. Imlanhimhin (1998) 1-21 The Ombudsman Institution, a conceptual analysis. University of Benin
[ 20 ]. Akindele, S.T. (1992): “Judicial Review and Ombudsman System: Examination of their Efficacy as means of Citizens Redress” in Journal of Nigerian Public Administration and Management Vol. 1, No. 2.
[ 21 ]. McMillan, John (2006): “The Role of the Ombudsman in Protecting Human Rights” in an address to a Conference on Legislatures and the Protection of Human Rights. University of Melbourne, Faculty of Law, 21st July.
[ 22 ]. public complaints commission servicom charter
[ 23 ]. See footnote 22
[ 24 ]. See fonote 23
[ 25 ]. See footnote 24
[ 26 ]. public complaints commission servicom charter
[ 27 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 394
[ 28 ]. Each state of the federation now has a resident commissioner
[ 29 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 396
[ 30 ]. Ombudsman and other complaint-handling system survey published by international ombudsman institute vol. viii of July 1978-June 1979
[ 31 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 397
[ 32 ]. By virtue of section 274 (5) of the constitution the public complaints act 1975 is part of the constitution.
[ 33 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 399
[ 34 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 401
[ 35 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 403
[ 36 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 405
[ 37 ]. Sam O.Akpekpe ans E.S.I Ejere “(A paper on Public Perception of the Public Complaints Commission, the Nigeria System-a survey on Benin residents)
[ 38 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 407-409
[ 39 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 407-409
[ 40 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 407-409
[ 41 ]. Nigerian Administrative Law P.A Oluyede University Press Plc Ibadan 2002, page 409-410