When Legal Advice Undermines The Rule of Law (Part II) - AFRICAN PARLIAMENTARY NEWS

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Wednesday, January 14, 2026

When Legal Advice Undermines The Rule of Law (Part II)

Why Scope of Mandate Is Central to Assessing Institutional Bad Faith

By Olu Ibekwe

In institutional law, good faith is inseparable from fidelity to mandate. An advisory organ acts in good faith only where it adheres strictly to the scope defined by the policy organ that conferred authority. When an organ knowingly exceeds a narrow and explicit mandate, bad faith may be inferred objectively, without proof of motive. It is against this standard that the conduct of the Office of the Legal Counsel (OLC) following Executive Council Decision EX.CL/Dec.1242(XLIV) must be assessed.

The Limited and Corrective Nature of EX.CL/Dec.1242(XLIV)

Executive Council Decision EX.CL/Dec.1242(XLIV) directed that the suspended Rules of Procedure of the Pan-African Parliament “should be reconsidered by the PAP Plenary, taking into consideration the inconsistencies outlined in the Legal Opinion issued by the Office of the Legal Counsel.” The mandate was explicit, corrective, and narrowly framed. It did not authorize a wholesale review of the Rules, reliance on extraneous materials, or any unilateral redefinition of scope by the OLC. The Executive Council neither mandated nor implied a comprehensive redrafting exercise.

Election Timing and the Limits of Advisory Authority

It must be emphasized that the determination of when elections to the Bureau of the Pan-African Parliament shall be held does not fall within the mandate of the OLC. The PAP Protocol provides a complete and self-contained legal framework governing Bureau tenure, rotation, vacancies, and the conduct of elections. Article 12(3) ties the tenure of the President and Vice-Presidents to the duration of their mandate in their respective national parliaments; Article 12(4) recognizes the rotation of the offices among the five regions of Africa; Article 12(8) stipulates the conditions under which the offices of the President and Vice-Presidents become vacant; and Article 12(10) expressly requires that any vacancy “shall be filled at the sitting of the Parliament immediately following the occurrence of the vacancy.” Read together, these provisions vest the Pan-African Parliament with the authority and corresponding responsibility to manage its own electoral processes in accordance with the Protocol.

In June 2022 and March 2024, the Executive Council directed the Office of the Legal Counsel to issue modalities solely for the conduct of those specific elections, and only because no Bureau was in place at the time to manage the electoral process. That instruction was exceptional, situational, and time-bound; it did not confer a standing or general mandate on the OLC to determine election calendars, prescribe the timing of elections, or dictate the modalities through which future elections are to be conducted once a Bureau has been duly constituted. The PAP Protocol establishes a complete and self-contained framework in this regard. Article 12(3) ties the tenure of Bureau officers to the mandate of their respective national parliaments; Article 12(4) provides for the rotation of offices among the Regions; Article 12(8) governs the circumstances under which the offices of the President or Vice-Presidents become vacant; and Article 12(10) expressly provides that “any vacancy shall be filled at the sitting of the Parliament immediately following the occurrence of the vacancy.” Read together with Article 12(5), which vests responsibility for the management and administration of the Parliament and its organs in the officers under the control and direction of the President, these provisions confirm that the authority to declare vacancies and to schedule and conduct elections rests with the Plenary of the Pan-African Parliament, acting in accordance with the Protocol, and not with any administrative or advisory organ.

Accordingly, attempt by the OLC to assert continuing authority over the scheduling, timing, or mode of PAP Bureau elections outside the narrow circumstances expressly authorized by the Executive Council constitutes a clear overreach of its advisory mandate and an encroachment upon the institutional autonomy of a treaty-established organ of the Union.

Reliance on Extraneous Materials

Instead of confining the process to the specific inconsistencies it had identified, the OLC asserted that a so-called “Technical Team” agreed to conduct a comprehensive review of all provisions of the suspended Rules and to rely on a prior internal gap-analysis report prepared during an earlier revision exercise. This reliance is probative of institutional bad faith. The Executive Council did not authorize recourse to internal documents previously considered and rejected by the PAP Plenary, nor did it empower the OLC to revive rejected positions through administrative means. By expanding the scope of review beyond the inconsistencies identified in its own Legal Opinion, the OLC effectively rewrote the Executive Council’s mandate, a power it does not possess.

Post-Compliance Insistence: The Most Damaging Factor

Even after PAP complied with the Executive Council’s directive through its November 2024 Plenary resolution addressing all inconsistencies identified in the October 2023 Legal Opinion, and after that compliance was acknowledged by the PRC and taken note of by the Executive Council, the OLC continued to insist that PAP’s compliance was inadequate because it did not adopt the full range of amendments proposed by the OLC. At this point, the issue ceased to be interpretive. Persisting after compliance has been formally acknowledged by the competent policy organs is one of the clearest indicators of institutional bad faith or abuse of advisory function.

An Institutional Posture That Is Condescending in Effect

This pattern of conduct also reveals an institutional posture that is condescending in effect toward the Pan-African Parliament. PAP is the third highest organ of the African Union, established by treaty, with its own constitutional mandate and deliberative authority. Yet the OLC’s approach of treating PAP’s Plenary decisions as provisional, subordinating them to continuing administrative discretion, and insisting on outcomes beyond those required by the Executive Council, implicitly positions PAP as administratively subordinate rather than constitutionally autonomous within its mandate. In institutional terms, such a posture diminishes the dignity and authority of a co-equal organ of the Union and is incompatible with a good-faith advisory relationship.

Why This Goes Beyond Procedural Error

Taken cumulatively, the conduct reflects disregard for the express limits of a policy-organ mandate, unilateral expansion of scope, reliance on extraneous and previously rejected materials, substitution of advisory preference for policy-organ instruction, and refusal to accept institutional closure even after acknowledged compliance. This combination goes beyond procedural error or interpretive zeal. It satisfies the objective threshold for institutional bad faith and undermines the balance of authority established by the Union’s legal framework.

The Constitutional Lens: Articles 3(g) and 4(m) of the Constitutive Act

Article 3(g) of the Constitutive Act of the African Union commits the Union to the promotion of democratic principles and institutions, popular participation, and good governance. These objectives presuppose that the Union’s organs, particularly its parliamentary organ operate within a framework of legality, predictability, and mutual institutional respect. Democratic institutions cannot function effectively where leadership tenure, electoral rules, and internal governance arrangements are repeatedly unsettled through administrative reinterpretation after policy organs have acted.

Article 4(m) further enshrines respect for democratic principles, the rule of law, and good governance as foundational principles of the Union. The rule of law, in this context, requires not only adherence to treaty provisions, but also respect for institutional hierarchy, finality of decisions, and the limits of mandate. Advisory organs are required to act within the authority conferred upon them and to give effect to the decisions of the Assembly and the Executive Council, not to dilute or re-litigate them through practice.

Institutional Dignity

Read together, Articles 3(g) and 4(m) also speak to institutional dignity as an implicit constitutional value. The Pan-African Parliament is a treaty-established organ of the Union, not an administrative appendage of the Commission. An approach that treats PAP’s Plenary decisions as provisional, subjects them to continuing administrative validation, or insists on outcomes beyond those mandated by the policy organs risks conveying a condescending institutional posture in effect. Such a posture undermines the dignity, autonomy, and democratic character of a co-equal organ of the Union.

Where advisory conduct subordinates a parliamentary organ’s lawful decisions to ongoing administrative discretion, it weakens popular participation, erodes confidence in continental democratic institutions, and blurs the separation between advisory and decision-making authority. This is incompatible with the good governance ethos envisaged by the Constitutive Act.

Ultimately, fidelity to Articles 3(g) and 4(m) requires more than formal compliance with legal texts. It requires that each organ of the Union respect the constitutional space of the others, that advisory authority remain advisory, and that once the competent policy organs have acted, their decisions be implemented with finality. Protecting the institutional dignity of PAP is therefore not a matter of sentiment, but a constitutional necessity for sustaining democratic governance and the rule of law within the African Union.

Conclusion

The issue presented is not whether fixed tenure is, in the abstract, a desirable institutional reform. It is whether the African Union governs itself through law, institutional hierarchy, and constitutional discipline, or through administrative oscillation that unsettles settled outcomes. By issuing a legal opinion that nullified a tenure regime, inducing binding action by the Executive Council on that basis, and subsequently seeking to revive the same regime without renewed authorization, the Office of the Legal Counsel moved beyond advisory interpretation into conduct incompatible with the good-faith exercise of institutional authority.

This conduct also implicates institutional dignity as a constitutional value of the Union. The Pan-African Parliament is a treaty-established organ, vested with democratic legitimacy and deliberative autonomy. Treating its Plenary decisions as provisional, subordinating them to continuing administrative discretion, or insisting on outcomes beyond those mandated by the policy organs diminishes the standing of a co-equal organ and erodes the balance carefully constructed by the Union’s legal framework.

It must further be underscored that the determination of the timing, calendar, or modalities of PAP Bureau elections does not fall within the standing mandate of the Office of the Legal Counsel. The PAP Protocol provides a complete legal framework governing tenure, rotation, vacancies, and the filling of such vacancies, and vests the Parliament itself with authority to manage its electoral processes in accordance with Articles 12(3), 12(4), 12(8), and 12(10). While the Executive Council exceptionally directed the OLC to issue modalities for the conduct of elections in June 2022 and March 2024, this was solely because no Bureau was in place at those moments to manage the process. Those instructions were situational and time-bound and cannot be construed as conferring any continuing or general authority on the OLC to determine future election timelines or modalities once a Bureau has been duly constituted.

Respect for Articles 3(g) and 4(m) of the Constitutive Act requires that democratic institutions be protected not only from overt illegality, but also from practices that weaken their authority through mandate overreach and condescension in effect. Good governance demands legality, predictability, finality of decisions, and mutual respect among the organs of the Union. Advisory authority must remain advisory; policy-organ decisions must remain determinative; and parliamentary autonomy must be preserved as an expression of popular participation at the continental level.

Ultimately, safeguarding the institutional dignity of the Pan-African Parliament is inseparable from safeguarding the rule of law within the African Union itself. Where advisory conduct respects mandate, accepts institutional closure, and defers to the supremacy of Assembly and Executive Council decisions, the Union’s constitutional order is strengthened. Where it does not, democratic governance is weakened. The choice between these paths will determine not only the resolution of the present dispute, but the credibility of the Union’s commitment to law-based governance going forward.


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