Death Penalty Database

Nigeria

Information current as of: June 19, 2014

General

Official Country Name

Federal Republic of Nigeria (Nigeria). [1]

Geographical Region

Africa (Western Africa). [2]

Death Penalty Law Status

Retentionist. Nigeria executed four individuals in 2013. [3]

Methods of Execution

Hanging.
Under secular law, hanging is the method of execution. [4] Under Shariah law (applied in some northern Nigerian states), executions can be carried out by hanging. [5] Under the Federal Robbery and Firearms Act, applicable in the Federal Capital Territory, death sentences can be carried out by hanging, if so decided by the governor. [6] The High Court of Lagos declared that execution by hanging is unconstitutional, however the ruling is only enforceable within Lagos State. [7]

Shooting.
Under Shariah law (applied in some northern Nigerian states), executions can be carried out by firing squad. [8] Under the Federal Robbery and Firearms Act, applicable in the Federal Capital Territory, death sentences can be carried out by firing squad, if so decided by the governor. [9] The High Court of Lagos declared that execution by firing squad is unconstitutional, however the ruling is only enforceable within Lagos State. [10]

Stoning.
Stoning (rajm) is a Shariah law punishment applied in some northern Nigerian states and reserved for Muslims. The punishment applies broadly for adultery, rape (if the offender is married), incest (if the offender is married) and homosexual sodomy. Evidentiary requirements for demonstrating these offenses, if enforced, are very demanding. [11]

Comments.
Crucifixion (salb) is a form of punishment under Shariah for hirabah (armed robbery) resulting in death when property is actually taken. Shariah law punishments are applied in some northern Nigerian states. Nigerian states differ on what is meant by “crucifixion.” [12]

References

[1] BBC, Country Profiles: Bangladesh Profile, http://www.bbc.com/news/world-africa-13949550, Nov. 27, 2013.
[2] U.N., Composition of macro geographical (continental) regions, geographical sub-regions, and selected economic and other groupings, http://unstats.un.org/unsd/methods/m49/m49regin.htm, Oct. 31, 2013.
[3] Amnesty Intl., Nigeria reportedly hangs four in first executions since 2006, http://www.amnesty.org/en/for-media/press-releases/nigeria-reportedly-hangs-four-first-executions-2006-2013-06-24, Jun. 24, 2013.
[4] Nigeria Criminal Procedure Act of 1945, art. 367(1), Laws of the Federation of Nigeria Ed. 2000 Ch. 80, Jun. 1, 1945, as updated to Dec. 31, 2000.
[5] Harmonised Shariah Penal Code Annotated, p. 52 fn. 67, Mar. 2002.
[6] Robbery and Firearms (Special Provisions) Act, sec. 1(3), Laws of the Federation of Nigeria Ed. 2000 Ch. 398, Mar. 29, 1984, as updated to Dec. 31, 2000.
[7] The Nation, Court Restrains Govt From Executing Five by Hanging, http://thenationonlineng.net/new/court-restrains-govt-from-executing-five-by-hanging/, Sep. 25, 2012.
[8] Harmonised Shariah Penal Code Annotated, p. 52 fn. 67, Mar. 2002.
[9] Robbery and Firearms (Special Provisions) Act, sec. 1(3), Laws of the Federation of Nigeria Ed. 2000 Ch. 398, Mar. 29, 1984, as updated to Dec. 31, 2000.
[10] The Nation, Court Restrains Govt From Executing Five by Hanging, http://thenationonlineng.net/new/court-restrains-govt-from-executing-five-by-hanging/, Sep. 25, 2012.
[11] Harmonised Shariah Penal Code Annotated, ch. III, 41, 44, 93 (1) (xviii), 126, 127, 129-130, 131-132, p. 68 fn. 162, p. 69 fn. 172, p. 69 fn. 174, p. 70, fn 181.
[12] Harmonised Shariah Penal Code Annotated, ch. VIII, art. 152 (d).

Country Details

Language(s)

English (official), Yoruba, Ibo, Hausa. [1]

Population

166.6 million (U.N., 2012). [2]

Number of Individuals Currently Under Sentence of Death

1,233.

As of September 2013, there were at least 1,233 individuals on death row across Nigeria. [3] At least 141 death sentences were imposed in 2013. [4]

Annual Number of Reported Executions

Executions in 2017 to date (last updated on December 6, 2017)

0. [5]

Executions in 2016

The Legal Defence & Assistance Project, a Nigerian rights group that provides legal representation to capital defendants, reported in late December that 3 executions were carried out secretly in Benin City. [6] Amnesty International also reported 3 executions in 2016. [7]

Per capita execution rate in 2016

Executions in 2015

0. [8]

Per capita execution rate in 2015

0 executions.

Executions in 2014

0. [9]

Per capita execution rate in 2014

0 executions

Executions in 2013

4. [10]

Per capita execution rate in 2013

1 execution per 41,650,000 persons.

Executions in 2012

0. [11]

Per capita execution rate in 2012

0 executions.

Executions in 2011

0. [12]

Per capita execution rate in 2011

0 executions.

Executions in 2010

0. [13]

Executions in 2009

0. [14]

Executions in 2008

0. [15]

Executions in 2007

0. [16]

Year of Last Known Execution

The Legal Defence & Assistance Project, a Nigerian rights group that provides legal representation to capital defendants, reported in late December that 3 executions were carried out secretly in Benin City. [17]

References

[1] BBC, Country Profiles: Bangladesh Profile, http://www.bbc.com/news/world-africa-13949550, Nov. 27, 2013.
[2] BBC, Country Profiles: Bangladesh Profile, http://www.bbc.com/news/world-africa-13949550, Nov. 27, 2013.
[3] Amnesty Intl., Annual Report 2013- Nigeria, https://www.amnesty.org/en/region/nigeria/report-2013#section-108-10, last accessed Mar. 21, 2014.
[4] Amnesty Intl., Death Sentences and Executions in 2013, p. 45, ACT 50/001/2014, Mar. 26, 2014
[5] DPW Executions and Death Sentences Monitor.
[6] Chanells Television, LEDAP condemns killing of death row prisoners in Benin City, https://www.channelstv.com/2016/12/28/ledap-condemns-killing-death-row-prisoners-benin-city/, Dec. 28, 2015.
[7] Amnesty International, Death sentences and executions in 2016, ACT 50/5740/2017, Apr. 11, 2017.
[8] DPW Executions and Death Sentences Monitor.
[9] Amnesty Intl., Death Sentences and Executions in 2014, ACT 50/001/2015, Mar. 31, 2015.
[10] Amnesty Intl., Death Sentences and Executions in 2013, p. 50, ACT 50/001/2014, Mar. 26, 2014. Amnesty Intl., Nigeria reportedly hangs four in first executions since 2006, http://www.amnesty.org/en/for-media/press-releases/nigeria-reportedly-hangs-four-first-executions-2006-2013-06-24, Jun. 24, 2013.
[11] Amnesty Intl., Death Sentences and Executions in 2012, ACT 50/001/2012, Apr. 9, 2013.
[12] Amnesty Intl., Death Sentences and Executions in 2011, ACT 50/001/2012, http://www.amnesty.org/en/library/info/ACT50/001/2012/en, Mar. 27, 2012.
[13] Amnesty Intl., Death Sentences and Executions in 2010, p. 5, ACT 50/001/2011, Mar. 28, 2011.
[14] Amnesty Intl., Death Sentences and Executions in 2009, p. 6, ACT 50/001/2010, Mar. 30, 2010.
[15] Amnesty Intl., Death Sentences and Executions in 2008, p. 8, ACT 50/003/2009, Mar. 24, 2009.
[16] Amnesty Intl., Death Sentences and Executions in 2007, p. 6, ACT 50/001/2008, Apr. 15, 2008.
[17] Chanells Television, LEDAP condemns killing of death row prisoners in Benin City, https://www.channelstv.com/2016/12/28/ledap-condemns-killing-death-row-prisoners-benin-city/, Dec. 28, 2015.

Crimes and Offenders Punishable By Death

Crimes Punishable by Death

Aggravated Murder.
In states applying Shariah law, intentional killing during robbery or after secluding a person to rob him carries the mandatory death penalty. [1] The secular law (of Southern states) does not distinguish between aggravated and simple murder. [2]

Murder.
In states applying Shariah law, murder carries the retributive sentence of death. Murder is intentional killing or killing as the result of an action likely to cause death. [3] A person who induces a person to commit a murder is liable for that agent’s offense under Shariah law. [4]

Under secular law (of Southern states), murder is punished by death [5] - for instance, under the Criminal Law of Lagos State. [6]

Under the Armed Forces Act of 1993, murder is punishable by death after conviction by court martial. [7]

Other Offenses Resulting in Death.
In states applying Shariah law, robbery resulting in death carries the mandatory death penalty. [8] Assisting the suicide of a person legally unable to consent is punished by death. [9] Perjury or fabrication resulting in the execution of an innocent defendant carries the retributive sentence of death. [10] Committing any act of witchcraft or juju that results in death carries the death penalty, and causing the death of an accused witch through trial by ordeal carries the retributive death penalty. [11]

Under the secular law (of Southern states) killing someone unintentionally while committing another unlawful act is deemed murder and carries the death penalty even in absence of a showing of intent or recklessness with regard to risk to life. [12] Presiding over a trial by ordeal which results in death carries the mandatory death penalty. [13]

Terrorism-Related Offenses Resulting in Death.
Support or solicitation for terrorist acts that result in death carries the death penalty. [14]

Roger Hood and Carolyn Hoyle report that the death penalty applies for use of firearms or explosives in undermining public order, offenses that could result in death. [15] We did not find the legislation establishing these offenses.

Terrorism-Related Offenses Not Resulting in Death.
Roger Hood and Carolyn Hoyle report that the death penalty applies for use of firearms or explosives in undermining public order, even when not resulting in death. [16] We did not find the legislation defining these offenses. The Terrorism Prevention Act requires that deaths result from a terrorist act in order for the death penalty to apply. [17]

Rape Not Resulting in Death.
In states applying Shariah law, rape committed by a married person carries the death penalty by stoning under demanding evidentiary showings. [18]

Robbery Not Resulting in Death.
Under the Criminal Code Act and the Robbery and Firearms (Special Provisions) Act, applicable in all southern states with the exception of Lagos and the Federal Captal Territory respectively, armed robbery or robbery resulting in harm to a victim carries the death penalty. [19] Armed robbery is also punishable by death under the Criminal Law of Lagos State if the offender uses violence on any person. [20]

Kidnapping Not Resulting in Death.
Kidnapping was made a capital offence in 2009 in six Nigerian states – Abia, Akwa, Ibom, Anambra, Ebonyi, Enugu, and Imo. [21] Kidnapping was made a capital offense in Edo in 2013. [22]

Adultery.
In states applying Shariah law, adultery carries the death sentence under demanding evidentiary showings, and adulterers are to be stoned to death. [23]

Apostasy.
In states applying Shariah law, blasphemy to the Prophet or Islam carries the death penalty. [24]

Experts state that apostasy (leaving the religion) is punishable by death in Nigeria, [25] but these reports are dated and we have found no recent references to apostasy being a capital offense. Conversion to Judaism or Christianity is explicitly permitted. [26]

Consensual Sexual Relations Between Adults of Same Sex.
In states applying Shariah law, under demanding evidentiary showings homosexual sodomy carries the death sentence by stoning if the defendant is married. [27]

Treason.
High treason, conspiring to wage war against Nigeria, and treachery (which applies to non-Nigerians as well as Nigerians) carry the death penalty. [28]

Military Offenses Not Resulting in Death.
Misconduct in action, mutiny and dereliction of duty are punishable by death. [29] Armed robbery and treason committed by members of the military subject to military law are punishable by death. [30]

Other Offenses Not Resulting in Death.
- Incest: In states applying Shariah law, under demanding evidentiary showings incest committed by a married offender carries the death sentence by stoning. [31]

- Practice of indigenous beliefs: In states applying Shariah law, the practice of some religions may be considered juju or witchcraft and punished by death, even when of little or no harm. [32] Cannibalism [33] and retaining human blood or remains for the purpose of trophy or witchcraft [34] are also punished by death.

Comments.
Nigeria operates under a federal system, and while there are some federal criminal laws which apply in southern states with the exception of Lagos, most criminal offenses fall under state jurisdiction. Criminal laws vary from state to state across Nigeria, thirty-six states in total. Each state has its own set of laws, which define individual crimes and punishments within the territory of the state. Twelve northern states have incorporated Shariah law into their penal laws. [35] Shariah courts operate alongside courts in the common law system. [36] According to an in-country expert, the death penalty is predominantly a state issue, and state-level amendments can greatly impact the scope of the death penalty. [37]

We did not have access to the complete criminal legislation for all thirty-six states. We consulted the Criminal Code Act (effective in southern states except Lagos), the Harmonised Shariah Penal Code Annotated (compiling the Shariah law of the Northern states with the Penal Code applicable in the Northern states), the Armed Forces Act of 1993, the Criminal Procedure Act, the Robbery and Firearms Act, and the Terrorism (Prevention Act). [38] A model Shariah criminal law has not been adopted, however, and states continue to apply divergent penal codes. [39] The Harmonised Shariah Penal Code we referred to is an informative secondary compilation of annotated Shariah offenses rather than a collection of the original statutes, which we could not obtain. For the purposes of this research, we included any offense which is death-eligible in at least one state.

Shariah rules of procedure establish that very high evidentiary requirements must be met before the death penalty can be applied to offenses against sexual mores. Circumstantial evidence is prohibited and the conviction must be based on the testimony of four (male) witnesses or a confession. According to some scholars, no court has ever properly issued a conviction on anything but a confession. [40] Whether the 12 states applying Shariah law enforce the strict evidentiary standards required by law is an open question. A 2006 reports notes that there were cases in which individuals were able to claim the evidentiary protections of Shariah law only upon appeal after lengthy incarceration under sentence of death. The lower Shariah courts had condemned them despite a complete failure by the state to even approximate Shariah evidentiary requirements. [41]

In 2014, President Goodluck Jonathan introduced a Cybercrime Bill. [42] A provision of the Bill includes the death penalty as punishment for individuals who hack into the Critical National Information Infrastructure, thus causing loss of life. [43] At the time of this report, the National Assembly was considering the Bill. [44]

Does the country have a mandatory death penalty?

Yes. The law we accessed prescribes the mandatory death penalty for a wide range of offenses. [45] Additionally, under Shariah law, the retributive (qisas) death penalty for killing applies in every case, precluding judicial discretion without the consent of the victim’s relatives. [46] Adamu A. Ja'afaru, a member of the Human Rights Law Society in Nigeria, confirmed that the mandatory death penalty is applied. [47]

In September 2012, the High Court of Lagos State declared that the mandatory death penalty was unconstitutional in James Ajulu & Others v. Attorney General of Lagos. [48] However, its holding is only enforceable in Lagos State.

For Which Offenses, If Any, Is a Mandatory Death Sentence Imposed?

Aggravated Murder.
In states applying Shariah law, intentional killing during robbery or after secluding a person to rob him carries the mandatory death penalty. [49]

The secular law (of Southern states) does not distinguish between aggravated and simple murder and applies the mandatory death penalty for both. [50]

Murder.
In states applying Shariah law, simple murder carries the retributive (qisas) sentence of death, which applies in every case unless the victim’s family grants the condemned a pardon. [51] A person who induces a person to commit a murder is liable for that agent’s offense. [52]

Under secular law (of Southern states), the death penalty is mandatory for murder. [53]

Under the Armed Forces Act of 1993, murder is punishable by death after conviction by court martial. [54]

Other Offenses Resulting in Death.
In states applying Shariah law, robbery resulting in death carries the mandatory death penalty. [55] Also, the distinction between murder and manslaughter is unclear or, in some states, non-existent, and manslaughter carries the retributive sentence of death. [56] Assisting the suicide of a person legally unable to consent is punished by death in some states. [57] Perjury or fabrication resulting in the execution of an innocent defendant carries the retributive sentence of death. [58] Committing any act of witchcraft or juju that results in death carries the mandatory death penalty, and causing the death of an accused witch through trial by ordeal carries the retributive (qisas) death penalty. [59]

Under the secular law of southern states, some offenses resulting in death are deemed murder and carry the mandatory death penalty even in absence of a showing of intent or recklessness with regard to risk to life. [60] Presiding over a trial by ordeal which results in death carries the mandatory death penalty. [61]

Terrorism-Related Offenses Resulting in Death.
Support or solicitation for terrorist acts that result in death carries the mandatory death penalty. [62] .

Rape Not Resulting in Death.
In states applying Shariah law, rape committed by a married person carries the mandatory death penalty by stoning under demanding evidentiary showings. [63]

Robbery Not Resulting in Death.
Under the secular federal law, armed robbery or robbery resulting in harm to a victim carries the mandatory death penalty. [64] Armed robbery carries the mandatory death penalty under the Robbery and Firearms (Special Provisions) Act, applicable in the Federal Capital Territory, if the offender uses violence on any person. [65]

Roger Hood and Carolyn Hoyle report that the death penalty is no longer mandatory in Nigeria for armed robbery; while our reading of the law and cases differs, there could be recent changes or factors of which we are unaware. [66]

Adultery.
In states applying Shariah law, under demanding evidentiary showings adultery carries the death sentence, and adulterers are to be stoned to death. [67]

Apostasy.
In states applying Shariah law, blasphemy to the Prophet or Islam carries the mandatory death penalty. [68]

Experts state that apostasy (leaving the religion) is punishable by mandatory death in Nigeria, [69] but these reports are dated and we have found no recent references to apostasy being a capital offense. Conversion to Judaism or Christianity is explicitly permitted. [70]

Consensual Sexual Relations Between Adults of Same Sex.
In states applying Shariah law, homosexual sodomy carries the mandatory death sentence by stoning under demanding evidentiary showings. [71]

Treason.
High treason, conspiring to wage war against Nigeria, and treachery (which applies against non-Nigerians as well as Nigerians) carry the mandatory death penalty. [72]

Other Offenses Not Resulting in Death.
- Incest: In states applying Shariah law, incest committed by a married offender carries the mandatory death sentence by stoning under demanding evidentiary showings. [73]

- Practice of indigenous beliefs: In states applying Shariah law, the practice of some religions may be considered juju or witchcraft and punished by a mandatory death sentence, even when of little or no harm. [74] Cannibalism [75] and retaining human blood or remains for the purpose of trophy or witchcraft [76] are also punished by death.

Comments.
The retributive (qisas) sentence of death is a penalty that excludes the possibility of judicial discretion unless a payment of blood money is made to a victim’s relatives (or forgiveness is gratuitously extended). [77] We consider this to be a mandatory death penalty because an extrajudicial determination controls whether discretion may be exercised.

Other offenses in Nigeria carry the mandatory death penalty because they either explicitly exclude discretion under any circumstances (as is the case for hadd punishments) or demand application of the death penalty without providing for alternative punishments. [78]

Roger Hood and Carolyn Hoyle report that the death penalty applies for use of firearms or explosives in undermining public order even when no death results, but we did not find the defining legislation and we do not know if the death penalty is mandatory in such cases. [79]

Crimes For Which Individuals Have Been Executed Since January 2008:

Murder.
The four prisoners executed in 2013 were convicted of either armed robbery or murder. [80]

Robbery Not Resulting in Death.
The four prisoners executed in 2013 were convicted of either armed robbery or murder. [81] We were unable to find information on whether the robbery offenses resulted in the death of a victim.

Categories of Offenders Excluded From the Death Penalty:

Individuals Below Age 18 At Time of Crime.
The federal Child Act defines juveniles as a child under the age of 18 and prohibits sentencing juveniles to capital punishment. [82] This Act, however, is only enforceable in the Federal Capital Territory of Abuja and in states which have explicitly enacted it. [83] As of March 2013, thirteen states out of thirty-six had yet to enact the Children’s Rights Act. [84] Furthermore, two northern states modified the definition of a child to individuals aged 16 or 17 and under. [85] In the states which did not adopt the Child Act, the governing law is the older Child and Young Persons Act which provides that children who are 17 years and older can be punished as adults. [86] Under the Criminal Code Act applicable in southern states with the exception of Lagos, and under the Criminal Procedure Act applicable in federal courts throughout Nigeria, juveniles over the age of 17 can be subject to the death penalty. [87] Furthermore, under Shariah law applicable in at least 12 states, [88] juveniles who committed offenses after reaching puberty or the “age of responsibility” can be executed. [89]

As a party to the ICCPR, [90] the Convention on the Rights of the Child, [91] and the African Charter on the Rights and Welfare of the Child, [92] Nigeria is under an international obligation to exclude juveniles from capital punishment.

As of 2010, 40 death row inmates were thought to be under the age of 18 at the time of their offenses. [93] We were not able to find more recent figures.

In June 2014, the ECOWAS Court of Justice issued a judgment holding that the death sentence of Maimuna Abdulmumini, who was convicted of murdering her husband at the age of 13, was a violation of the ICCPR’s prohibition on applying capital punishment to minors. The court awarded Abdulmumini trial costs and damages. [94] In March 2014, Justice Minister Bello Adoke had announced that the federal government would not carry out her execution in accordance with the ECOWAS court’s interim decisions. [95] The ECOWAS judgment thus has the potential to change Nigeria’s practice with regard to sentencing juveniles to death.

Pregnant Women.
According to article 368(2) of the Criminal Procedure Act, applicable in federal courts throughout Nigeria, pregnant women cannot be sentenced to death and their sentences should be commuted to life imprisonment instead. Section 300(3) of the Criminal Procedure Code, applicable in state courts in the northern states and the Federal Capital Territory, also includes a similar provision. [96] Reportedly, Shariah penal laws in some states in Nigeria authorize the imposition of death penalties on pregnant women. [97] The practices in these states seems to be out of line with observations of Shariah law outside of Nigeria, which generally does not condone the execution of pregnant women. [98]

As a party to the ICCPR, [99] and the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Women in Africa, [100] Nigeria is under an international obligation to exclude pregnant women from capital punishment.

Mentally Ill.
The Criminal Code Act, applicable in southern states with the exception of Lagos, stipulates that an individual is excluded from criminal liability if at the time of the crime he or she is in “such a state of mental disease … as to deprive him of capacity to understand what he is doing, or of capacity to control his actions, or of capacity to know not do the act.” [101] Those who are deluded can be criminally responsible as long as their delusions aren’t related to the crime for which they are convicted. [102]

Individuals may be found incompetent to stand trial. [103] An in-country expert corroborates that mental illness is, in practice, grounds for acquittal. [104]

We found no laws, however, prohibiting the execution of prisoners who are mentally ill at the time the death sentence is to be carried out.

Intellectually Disabled.
The Criminal Code Act, applicable in southern states with the exception of Lagos, stipulates that an individual is excluded from criminal liability if at the time of the crime he or she is in “such a state of … natural mental infirmity as to deprive him of capacity to understand what he is doing, or of capacity to control his actions, or of capacity to know not do the act.” [105] Those who are deluded can be criminally responsible as long as their delusions aren’t related to the crime for which they are convicted. [106]

We found no laws, however, expressly prohibiting the execution of prisoners who are intellectually disabled at the time of their sentencing or at the time the death sentence is to be carried out.

Comments.
Nigeria has ratified the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Women in Africa, [107] which excludes pregnant women and nursing women from the application of the death penalty.

References

[1] Harmonised Shariah Penal Code Annotated, arts. 50, 198-199, p. 85 fn. 271, Mar. 2002.
[2] Nigeria Criminal Code Act, arts. 316, 319, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[3] Harmonised Shariah Penal Code Annotated, arts. 198-199 (a), Mar. 2002.
[4] Harmonised Shariah Penal Code Annotated, art. 205, Mar. 2002.
[5] Nigeria Criminal Code Act, arts. 316, 319, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[6] Criminal Law of Lagos State, Sec. 319, Aug. 19, 2011.
[7] Nigeria Armed Forces Act, art. 106, Law No. 105 of 1993, 1993.
[8] Harmonised Shariah Penal Code Annotated, art. 152 (c), Mar. 2002.
[9] Harmonised Shariah Penal Code Annotated, art. 205, p. 87 fn. 282, Mar. 2002.
[10] Harmonised Shariah Penal Code Annotated, art. 330(2), Mar. 2002.
[11] Harmonised Shariah Penal Code Annotated, arts. 407, 411, Mar. 2002.
[12] Nigeria Criminal Code Act, arts. 316, 319, Laws of the Federation of Nigeria Ed. 2000, Jun. 1, 1916, as updated to Dec. 31, 2000.
[13] Nigeria Criminal Code Act, art. 207-208, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[14] Terrorism (Prevention) Act, sec. 4(2), Act. No. 10 of 2011, Jun. 2, 2011.
[15] Roger Hood & Carolyn Hoyle, The Death Penalty: A Worldwide Perspective, p. 136, Oxford University Press, 4th ed., 2008.
[16] Roger Hood & Carolyn Hoyle, The Death Penalty: A Worldwide Perspective, p. 136, Oxford University Press, 4th ed., 2008.
[17] Terrorism (Prevention) Act, sec. 4(2), Act. No. 10, Jun. 2, 2011.
[18] Zamfara State Shari’a Penal Code, sec. 129, Jan. 2000. Harmonised Shariah Penal Code Annotated, art. 128 (b), Mar. 2002.
[19] Nigeria Criminal Code Act, art. 402, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000. Robbery and Firearms (Special Provisions) Act, sec. 1(2)(b), Laws of the Federation of Nigeria Ed. 2000 Ch. 398, Mar. 29, 1984, as updated to Dec. 31, 2000.
[20] Criminal Law of Lagos State, Sec. 295(2), Aug. 19, 2011.
[21] Amnesty Intl., Death Sentences and Executions in 2009, p. 23, ACT 50/001/2010, Mar. 30, 2010.
[22] Leadership, Nigeria: Death Penalty for Kidnappers - Ex-Lawmaker Backs Oshiomhole, http://allafrica.com/stories/201310210111.html, Oct. 19, 2013.
[23] Zamfara State Shari’a Penal Code, sec. 126, Jan. 2000. Harmonised Shariah Penal Code Annotated, art. 126 (b), Mar. 2002.
[24] Harmonised Shariah Penal Code Annotated, p. 133 fn. 627, p. 134, fn. 637, arts. 406, 408-409, Mar. 2002.
[25] Cherif Bassiouni, Crimes and the Criminal Process, p. 277, Arab Law Quarterly, Vol. 12, No. 3, 1997. Cherif Bassiouni, Leaving Islam is Not a Capital Crime, Chicago Tribune, Apr. 2, 2006.
[26] Harmonised Shariah Penal Code Annotated, p. 133 fn. 627, p. 134, fn. 637, arts. 406, 408-409, Mar. 2002.
[27] Zamfara State Shari’a Penal Code, sec. 129, Jan. 2000. Harmonised Shariah Penal Code Annotated, art. 132 (b), Mar. 2002.
[28] Nigeria Criminal Code Act, arts. 37-38, 49, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[29] Nigeria Armed Forces Act, arts. 45, 46, 47, 52, 63, Law No. 105 of 1993, 1993.
[30] Nigeria Armed Forces Act, arts. 107, 114, Law No. 105 of 1993, 1993.
[31] Harmonised Shariah Penal Code Annotated, art. 130 (1), Mar. 2002.
[32] Harmonised Shariah Penal Code Annotated, arts. 408-409, Mar. 2002.
[33] Harmonised Shariah Penal Code Annotated, art. 413, Mar. 2002.
[34] Harmonised Shariah Penal Code Annotated, art. 414, Mar. 2002.
[35] Radio Netherlands Worldwide, Law and Disorder in Nigeria’s Sharia States, http://www.rnw.nl/africa/article/law-and-disorder-nigeria’s-sharia-states-0, Dec. 23, 2011.
[36] Human Rights Watch, “Political Shariah” Human Rights and Islamic Law in northern Nigeria, p. 13, Vol. 16, No.9, Sep. 2004.
[37] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[38] Nigeria Criminal Code Act, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000. Harmonised Shariah Penal Code Annotated, Mar. 2002. Nigeria Armed Forces Act, No. 105 of 1993, 1993. Criminal Procedure Act, art. 368(3), Laws of the Federation of Nigeria Ed. 2000 Ch. 80, Jun. 1, 1945, as updated to Dec. 31, 2000. Robbery and Firearms (Special Provisions) Act, sec. 1(2)(b), Laws of the Federation of Nigeria Ed. 2000 Ch. 398, Mar. 29, 1984, as updated to Dec. 31, 2000.
[39] U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Denial of Fair Public Trial, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[40] U.N. ESC, Report of the Special Rapporteur on Summary, Extrajudicial or Arbitrary Executions, Philip Alston, p. 3, E/CN.4/2006/53/Add.4, Jan. 7, 2006.
[41] For example, see: U.N. ESC, Report of the Special Rapporteur on Summary, Extrajudicial or Arbitrary Executions, Philip Alston, paras. 21-26, 32-28, E/CN.4/2006/53/Add.4, Jan. 7, 2006.
[42] Nigerian Monitor, President Goodluck Jonathan Seeks Death Penalty for Cyber Crime, Jan. 29, 2014.
[43] CybercrimeBill 2013, sec 5(3), Jan. 28, 2014.
[44] Eseohe Ebhota, Nigerians React to Cyber-Crime Bill, AllAfrica.com, http://allafrica.com/stories/201402031339.html, Feb. 2, 2014.
[45] Nigeria Criminal Code Act, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000 (effective in southern states); Harmonised Shariah Penal Code Annotated (compiling the Shariah law of northern states and the Penal Code applicable in northern states).
[46] Harmonised Shariah Penal Code Annotated, arts. 198-199 (a), Mar. 2002.
[47] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[48] The Nation, Court Restrains Govt From Executing Five by Hanging, http://thenationonlineng.net/new/court-restrains-govt-from-executing-five-by-hanging, Sep. 25, 2012.
[49] Harmonised Shariah Penal Code Annotated, arts. 50, 198-199, p. 85 fn. 171, Mar. 2002.
[50] Nigeria Criminal Code Act, arts. 316, 319, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[51] Harmonised Shariah Penal Code Annotated, arts. 198-199 (a), Mar. 2002.
[52] Harmonised Shariah Penal Code Annotated, art. 205, Mar. 2002.
[53] Nigeria Criminal Code Act, arts. 316, 319, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[54] Nigeria Armed Forces Act, art. 106, Act No. 105 of 1993, 1993.
[55] Harmonised Shariah Penal Code Annotated, ch. VIII, art. 152 (c), Mar. 2002.
[56] Harmonised Shariah Penal Code Annotated, arts. 198-199 (a), Mar. 2002.
[57] Harmonised Shariah Penal Code Annotated, art. 205, p. 87 fn. 282, Mar. 2002.
[58] Harmonised Shariah Penal Code Annotated, art. 330(2), Mar. 2002.
[59] Harmonised Shariah Penal Code Annotated, arts. 407, 411, Mar. 2002.
[60] Nigeria Criminal Code Act, arts. 316, 319, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[61] Nigeria Criminal Code Act, art. 207-208, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[62] Terrorism (Prevention) Act, sec. 4(2), Jun. 2, 2011.
[63] Harmonised Shariah Penal Code Annotated, ch. VIII, art. 128 (b), Mar. 2002.
[64] Nigeria Criminal Code Act, art. 402, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[65] Robbery and Firearms (Special Provisions) Act, sec. 1(2)(b), Laws of the Federation of Nigeria Ed. 2000 Ch. 398, Mar. 29, 1984, as updated to Dec. 31, 2000.
[66] Roger Hood & Carolyn Hoyle, The Death Penalty: A Worldwide Perspective, p. 140, Oxford University Press, 4th ed., 2008.
[67] Zamfara State Shari’a Penal Code, sec. 126, Jan. 2000. Harmonised Shariah Penal Code Annotated, ch. VIII, art. 126 (b), Mar. 2002.
[68] Harmonised Shariah Penal Code Annotated, p. 133 fn. 627, p. 134, fn. 637, arts. 406, 408-409, Mar. 2002.
[69] Cherif Bassiouni, Crimes and the Criminal Process, p. 277, Arab Law Quarterly, Vol. 12, No. 3, 1997. Cherif Bassiouni, Leaving Islam is Not a Capital Crime, Chicago Tribune, Apr. 2, 2006.
[70] Harmonised Shariah Penal Code Annotated, p. 133 fn. 627, p. 134, fn. 637, arts. 406, 408-409, Mar. 2002.
[71] Harmonised Shariah Penal Code Annotated, ch. VIII, art. 132 (b), Mar. 2002.
[72] Nigeria Criminal Code Act, arts. 37-38, 49, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[73] Harmonised Shariah Penal Code Annotated, ch. VIII, art. 130 (1), Mar. 2002.
[74] Harmonised Shariah Penal Code Annotated, arts. 408-409, Mar. 2002.
[75] Harmonised Shariah Penal Code Annotated, art. 413, Mar. 2002.
[76] Harmonised Shariah Penal Code Annotated, art. 414, Mar. 2002.
[77] Harmonised Shariah Penal Code Annotated, arts. 198-199 (a), Mar. 2002.
[78] Nigeria Criminal Code Act, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000 (effective in southern states). Harmonised Shariah Penal Code Annotated, Mar. 2002 (compiling the Shariah law of northern states and the Penal Code applicable in northern states).
[79] Roger Hood & Carolyn Hoyle, The Death Penalty: A Worldwide Perspective, p. 136, Oxford University Press, 4th ed., 2008.
[80] Amnesty Intl., Nigeria reportedly hangs four in first executions since 2006, http://www.amnesty.org/en/for-media/press-releases/nigeria-reportedly-hangs-four-first-executions-2006-2013-06-24, Jun. 24, 2013. Reuters, Nigeria Hangs Four Prisoners in First Executions since 2006, http://www.reuters.com/article/2013/06/25/us-nigeria-execution-idUSBRE95O0RA20130625, Jun. 25, 2014.
[81] Amnesty Intl., Nigeria reportedly hangs four in first executions since 2006, http://www.amnesty.org/en/for-media/press-releases/nigeria-reportedly-hangs-four-first-executions-2006-2013-06-24, Jun. 24, 2013. Reuters, Nigeria Hangs Four Prisoners in First Executions since 2006, http://www.reuters.com/article/2013/06/25/us-nigeria-execution-idUSBRE95O0RA20130625, Jun. 25, 2014.
[82] Child Act, sec. 221, 2003.
[83] Child Rights International Network, Inhuman Sentencing of Children In Nigeria, http://www.crin.org/docs/Nigeria_UPR_CRIN_FINAL.pdf, Mar. 2013.
[84] Child Rights International Network, Inhuman Sentencing of Children In Nigeria, http://www.crin.org/docs/Nigeria_UPR_CRIN_FINAL.pdf, Mar. 2013.
[85] Child Rights International Network, Inhuman Sentencing of Children In Nigeria, http://www.crin.org/docs/Nigeria_UPR_CRIN_FINAL.pdf, Mar. 2013.
[86] Child and Young Persons Act, art. 12, 1943.
[87] Nigeria Criminal Code Act, arts. 319, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000. Criminal Procedure Act, art. 368(3), Laws of the Federation of Nigeria Ed. 2000 Ch. 80, Jun. 1, 1945, as updated to Dec. 31, 2000.
[88] Child Rights International Network, Inhuman Sentencing of Children In Nigeria, http://www.crin.org/docs/Nigeria_UPR_CRIN_FINAL.pdf, Mar. 2013.
[89] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 43, AFR 44/020/2008, http://www.amnesty.org/en/news-and-updates/news/poverty-and-the-death-penalty-in-nigeria-20081021, Oct. 21, 2008. Nigeria Criminal Code Act, arts. 39, 319, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[90] Status, Declarations, and Reservations, ICCPR, 999 U.N.T.S. 171, Dec. 16, 1966, http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-4&chapter=4&lang=en, last accessed Mar. 14, 2014.
[91] Status, Declaration, and Reservations, Convention on the Rights of the Child, 1577 U.N.T.S. 3, Nov. 20, 1989, https://treaties.un.org/pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-11&chapter=4&lang=en, Jun. 16, 2014.
[92] African Commission on Human and Peoples’ Rights, Ratification Table: African Charter on the Rights and Welfare of the Child, http://www.achpr.org/instruments/child/ratification, last accessed Mar. 4, 2014.
[93] U.N. CRC, Committee on the Rights of the Child, Concluding Observations: Nigeria, paras. 7, 32-33, U.N. Doc. CRC/C/NGA/CO/3-4, Jun. 11, 2010.
[94] Bertram Nwannekanma, ECOWAS Court upholds rights of death row detainees, http://www.ngrguardiannews.com/news/national-news/166818-ecowas-court-upholds-rights-of-death-row-detainees, Jun. 18, 2014.
[95] Ikenna Emewu, ECOWAS Court Stops Death Penalty in Nigeria, The Sun, http://sunnewsonlinEd.com/new/?p=56385, Mar. 15, 2014.
[96] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 43, AFR 44/020/2008, Oct. 21, 2008. Nigeria Criminal Procedure Act, art. 368(2), Laws of the Federation of Nigeria Ed. 2000 Ch. 80, Jun. 1, 1945, as updated to Dec. 31, 2000.
[97] Lilian Chenwi, Towards the Abolition of the Death Penalty in Africa: A Human Rights Perspective, p.41, Pretoria University Law Press, 2007.
[98] Gerald E. Lampe, ed., Justice and Human Rights in Islamic Law, p. 56, Intl. Law Institute, 1997.
[99] Status, Declarations, and Reservations, ICCPR, 999 U.N.T.S. 171, Dec. 16, 1966, http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-4&chapter=4&lang=en, last accessed Mar. 14, 2014.
[100] African Commission on Human and Peoples’ Rights, Ratification Table: Protocol to the African Charter on Human and People’s Rights on the Rights of Women in Africa, http://www.achpr.org/instruments/women-protocol/ratification, last accessed Mar. 14, 2014.
[101] Nigeria Criminal Code Act, art. 28, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[102] Nigeria Criminal Code Act, art. 28, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[103] Nigeria Criminal Procedure Act, arts. 222-223, Laws of the Federation of Nigeria Ed. 2000 Ch. 80, Jun. 1, 1945, as updated to Dec. 31, 2000.
[104] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[105] Nigeria Criminal Code Act, art. 28, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[106] Nigeria Criminal Code Act, art. 28, Laws of the Federation of Nigeria Ed. 2000 Ch. 77, Jun. 1, 1916, as updated to Dec. 31, 2000.
[107] Status, African Convention on Human and Peoples’ Rights, Protocol on the Rights of Women in Africa, http://www.achpr.org/instruments/women-protocol/ratification/, last accessed Jun. 18, 2014.

International Commitments

ICCPR

Party?

Yes. [1]

Date of Accession

July 29, 1993. [2]

Signed?

No. [3]

Date of Signature

Not Applicable.

First Optional Protocol to the ICCPR, Recognizing Jurisdiction of the Human Rights Committee

Party?

No. [4]

Date of Accession

Not Applicable.

Signed?

No. [5]

Date of Signature

Not Applicable.

Second Optional Protocol to the ICCPR, Toward the Abolition of the Death Penalty

Party?

No. [6]

Date of Accession

Not Applicable.

Signed?

No. [7]

Date of Signature

Not Applicable.

American Convention on Human Rights

Party?

Not Applicable.

Date of Accession

Signed?

Not Applicable.

Date of Signature

Death Penalty Protocol to the ACHR

Party?

Not Applicable.

Date of Accession

Signed?

Not Applicable.

Date of Signature

African Charter on Human and Peoples' Rights (ACHPR)

Party?

Yes. [8]

Date of Accession

June 22, 1983. [9]

Signed?

Yes. [10]

Date of Signature

August 31, 1982. [11]

Protocol to the ACHPR on the Rights of Women in Africa

Party?

Yes. [12]

Date of Accession

December 16, 2004. [13]

Signed?

Yes. [14]

Date of Signature

December 16, 2003. [15]

African Charter on the Rights and Welfare of the Child

Party?

Yes. [16]

Date of Accession

July 23, 2001. [17]

Signed?

Yes. [18]

Date of Signature

July 13, 1999. [19]

Arab Charter on Human Rights

Party?

Not Applicable.

Date of Accession

Signed?

Not Applicable.

Date of Signature

2016 Record of Votes on the UN General Assembly Moratorium Resolution

Cosponsor

No. [20]

Vote

Abstained. [21]

Signed the Note Verbale of Dissociation

Yes. [22]

2014 Record of Votes on the UN General Assembly Moratorium Resolution

Cosponsor

No. [23]

Vote

Abstained. [24]

Signed the Note Verbale of Dissociation

Yes. [25]

2012 Record of Votes on the UN General Assembly Moratorium Resolution

Cosponsor

No. [26]

Vote

Abstained. [27]

Signed the Note Verbale of Dissociation

Yes. [28]

2010 Record of Votes on the UN General Assembly Moratorium Resolution

Cosponsor

No. [29]

Vote

Abstained. [30]

Signed the Note Verbale of Dissociation

Yes. [31]

2008 Record of Votes on the UN General Assembly Moratorium Resolution

Cosponsor

No. [32]

Vote

Against. [33]

Signed the Note Verbale of Dissociation

Yes. [34]

2007 Record of Votes on the UN General Assembly Moratorium Resolution

Cosponsor

No. [35]

Vote

Against. [36]

Signed the Note Verbale of Dissociation

Yes. [37]

References

[1] Status, Declarations, and Reservations, ICCPR, 999 U.N.T.S. 171, Dec. 16, 1966, http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-4&chapter=4&lang=en, last accessed Mar. 14, 2014.
[2] Status, Declarations, and Reservations, ICCPR, 999 U.N.T.S. 171, Dec. 16, 1966, http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-4&chapter=4&lang=en, last accessed Mar. 14, 2014.
[3] Status, Declarations, and Reservations, ICCPR, 999 U.N.T.S. 171, Dec. 16, 1966, http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-4&chapter=4&lang=en, last accessed Mar. 14, 2014.
[4] Status, Declarations, and Reservations, Optional Prot. to the ICCPR, 999 U.N.T.S. 171, Dec. 16, 1966, http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-5&chapter=4&lang=en, last accessed Mar. 20, 2014.
[5] Status, Declarations, and Reservations, Optional Prot. to the ICCPR, 999 U.N.T.S. 171, Dec. 16, 1966, http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-5&chapter=4&lang=en, last accessed Mar. 20, 2014.
[6] Status, Declarations, and Reservations, Second Optional Prot. to the ICCPR, Aiming at the Abolition of the Death Penalty, 1642 U.N.T.S. 414, Dec. 15, 1989, http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-12&chapter=4&lang=en, last accessed Mar. 14, 2014.
[7] Status, Declarations, and Reservations, Second Optional Prot. to the ICCPR, Aiming at the Abolition of the Death Penalty, 1642 U.N.T.S. 414, Dec. 15, 1989, http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-12&chapter=4&lang=en, last accessed Mar. 14, 2014.
[8] African Commission on Human and Peoples’ Rights, Ratification Table: African Charter on Human and People’s Rights, http://www.achpr.org/instruments/achpr/ratification, last accessed Mar. 14, 2014.
[9] African Commission on Human and Peoples’ Rights, Ratification Table: African Charter on Human and People’s Rights, http://www.achpr.org/instruments/achpr/ratification, last accessed Mar. 14, 2014.
[10] African Commission on Human and Peoples’ Rights, Ratification Table: African Charter on Human and People’s Rights, http://www.achpr.org/instruments/achpr/ratification, last accessed Mar. 14, 2014.
[11] African Commission on Human and Peoples’ Rights, Ratification Table: African Charter on Human and People’s Rights, http://www.achpr.org/instruments/achpr/ratification, last accessed Mar. 14, 2014.
[12] African Commission on Human and Peoples’ Rights, Ratification Table: Protocol to the African Charter on Human and People’s Rights on the Rights of Women in Africa, http://www.achpr.org/instruments/women-protocol/ratification, last accessed Mar. 14, 2014.
[13] African Commission on Human and Peoples’ Rights, Ratification Table: Protocol to the African Charter on Human and People’s Rights on the Rights of Women in Africa, http://www.achpr.org/instruments/women-protocol/ratification, last accessed Mar. 14, 2014.
[14] African Commission on Human and Peoples’ Rights, Ratification Table: Protocol to the African Charter on Human and People’s Rights on the Rights of Women in Africa, http://www.achpr.org/instruments/women-protocol/ratification, last accessed Mar. 14, 2014.
[15] African Commission on Human and Peoples’ Rights, Ratification Table: Protocol to the African Charter on Human and People’s Rights on the Rights of Women in Africa, http://www.achpr.org/instruments/women-protocol/ratification, last accessed Mar. 4, 2014.
[16] African Commission on Human and Peoples’ Rights, Ratification Table: African Charter on the Rights and Welfare of the Child, http://www.achpr.org/instruments/child/ratification, last accessed Mar. 4, 2014.
[17] African Commission on Human and Peoples’ Rights, Ratification Table: African Charter on the Rights and Welfare of the Child, http://www.achpr.org/instruments/child/ratification, last accessed Mar. 4, 2014.
[18] African Commission on Human and Peoples’ Rights, Ratification Table: African Charter on the Rights and Welfare of the Child, http://www.achpr.org/instruments/child/ratification, last accessed Mar. 4, 2014.
[19] African Commission on Human and Peoples’ Rights, Ratification Table: African Charter on the Rights and Welfare of the Child, http://www.achpr.org/instruments/child/ratification, last accessed Mar. 4, 2014.
[20] U.N.G.A., 71st Session, Promotion and protection of human rights: human rights questions, including alternative approaches for improving the effective enjoyment of human rights and fundamental freedoms, paras. 54-71 U.N. Doc. A/71/484/Add.2, Dec. 6, 2016.
[21] U.N.G.A., 71st Session, Promotion and protection of human rights: human rights questions, including alternative approaches for improving the effective enjoyment of human rights and fundamental freedoms, paras. 54-71 U.N. Doc. A/71/484/Add.2, Dec. 6, 2016.
[22] U.N.G.A., 71st Session, Note Verbale dated 7 September 2017, U.N. Doc. A/71/1047, Sep. 13, 2017.
[23] U.N.G.A., 69th Session, Promotion and Protection of Human Rights: human rights questions, including alternative approaches for improving the effective enjoyment of human rights and fundamental freedoms, paras. 141, 144, U.N. Doc. A/69/488/Add.2, Dec. 8, 2014.
[24] U.N.G.A., 69th Session, 73rd Plenary Meeting, pp. 17-18, U.N. Doc. A/69/PV.73, Dec. 18, 2014.
[25] U.N.G.A., 69th Session, Note Verbale dated 28 July 2015, U.N. Doc. A/69/993, Jul. 29, 2015.
[26] U.N.G.A., 67th Session, Promotion and Protection of Human Rights: human rights questions, including alternative approaches for improving the effective enjoyment of human rights and fundamental freedoms, paras. 95-96, U.N. Doc. A/67/457/Add.2, Dec. 8, 2012.
[27] U.N.G.A., 67th Session, 60th Plenary Meeting, pp. 16-17, U.N. Doc. A/67/PV.60, Dec. 20, 2012.
[28] U.N.G.A., 67th Session, Note Verbale dated 16 April 2013, U.N. Doc. A/67/841, Apr. 23, 2013.
[29] U.N.G.A., 65th Session, Promotion and Protection of Human Rights: human rights questions, including alternative approaches for improving the effective enjoyment of human rights and fundamental freedoms, p. 5, U.N. Doc. A/65/456/Add.2, Dec. 8, 2010.
[30] U.N.G.A., 65th Session, 71st Plenary Meeting, pp. 18-19, U.N. Doc. A/65/PV.71, Dec. 21, 2010.
[31] U.N.G.A., 65th Session, Note Verbale dated 11 March 2011, U.N. Doc. A/65/779, Mar. 11, 2011.
[32] U.N.G.A., 63rd session, Promotion and Protection of Human Rights: human rights questions, including alternative approaches for improving the effective enjoyment of human rights and fundamental freedoms, U.N. Doc. A/63/430/Add.2, Dec. 4, 2008.
[33] U.N.G.A., 63rd Session, 70th Plenary Meeting, pp. 16-17, U.N. Doc. A/63/PV.70, Dec. 18, 2008.
[34] U.N.G.A., 63rd Session, Note Verbale dated 10 February 2009, U.N. Doc. A/63/716, Feb. 12, 2009.
[35] U.N.G.A., 62nd Session, Promotion and Protection of Human Rights: human rights questions, including alternative approaches for improving the effective enjoyment of human rights and fundamental freedoms, pp. 3-4, U.N. Doc. A/62/439/Add.2, Dec. 5, 2007.
[36] U.N.G.A., 62nd Session, 76th Plenary Meeting, pp. 16- 17, U.N. Doc. A/62/PV.76, Dec. 18, 2007.
[37] U.N.G.A., 62nd Session, Note Verbale dated 11 January 2008, U.N. Doc. A/62/658, Feb. 2, 2008.

Death Penalty In Law

Does the country’s constitution make reference to capital punishment?

The Constitution provides that no one may be deprived of life except “in execution of the sentence of a court in respect of a criminal offence of which he has been found guilty in Nigeria.” [1] It also provides that appeal from a sentence of death pronounced by a Federal High Court lies as of right to the Court of Appeal and then to the Supreme Court. [2]

Does the country’s constitution make reference to international law?

The Preamble to the Constitution declares that the people of Nigeria are “dedicated to the promotion of inter-African solidarity, world peace, international co-operation and understanding.” [3] The Constitution further provides that a foreign policy objective of the nation shall be to respect international law and treaty obligations. [4]

In 2009, then-Chief Justice Idris Legbo Kutigi signed into law the Fundamental Rights (Enforcement Procedure) Rules under Chapter IV of the Constitution, expanding the obligation of national courts to apply international human rights treaties when considering fundamental rights. Pursuant to these Rules, federal and state High Courts [5] are instructed to respect “regional and international bills of rights,” [6] including the African Charter on Human and Peoples’ Rights and its protocols, the Universal Declaration of Human Rights, and other instruments in the United Nations human rights system. [7] Moreover, fundamental rights contained in the Constitution and in the African Charter are to be “expansively and purposely interpreted and applied, with a view to advancing and realising the rights and freedoms contained in them.” [8] Courts must encourage public interest litigation and cannot strike any human rights case for lack of standing. [9] Human rights cases are to be given priority, and any case involving the liberty of a person “shall be treated as an emergency.” [10] The Rules provide that human rights applications are not affected by limitations statutes. [11]

Have there been any significant changes in the application of the death penalty over the last several years?

While more than 2,600 people were convicted and executed between 1970 and 1999, the rate of executions dropped dramatically after the fall of the military government in May 1999. From May 1999 to 2006, Amnesty estimates that at least 22 people were executed. [12] After a 7-year hiatus without executions, four death row inmates were executed in 2013. [13] In June 2013, President Goodluck Jonathan urged state Governors to sign death warrants for death row prisoners. [14] The four executions took place shortly after in Edo State. [15] All four individuals still had appeals pending when they were executed, according to their lawyers, [16] in violation of Nigerian and international law.

In early July 2010, reports indicated that the Nigerian government had contemplated mass executions of death row inmates, many of whom may have been convicted in unfair trials, in order to somewhat diminish overcrowding. Two (or more) Nigerian NGOs—the Legal Resources Consortium and the Socio-Economic Rights and Accountability Project—obtained injunctions and orders against the execution of death row prisoners as violating a variety of human rights protections. Reports conflict as to whether 824 or more than 870 individuals were affected by these injunctions and orders.

In 2007, Manfred Nowak, the U.N. Special Rapporteur on Torture, observed that the dropping execution rate masks the continued use of death sentences by courts in a system where individuals are held under inhuman conditions on death row for an average of 17 years. [17]

Civilian government has seen the extension of Shariah law to criminal law. According to Philip Alston, the U.N. Special Rapporteur on Extrajudicial, Summary or Arbitrary executions, reporting in 2006, states applying Shariah law have extended the scope of the death penalty to penalize private sexual conduct, violating the ICCPR’s prohibition against the use of the death penalty for non-criminal conduct and conflating moral disapprobation with the criminal law. [18]

In 2014, President Goodluck Jonathan introduced a Cybercrime Bill. [19] A provision of the Bill includes the death penalty as punishment for individuals who hack into the Critical National Information Infrastructure, causing loss of life. [20] At the time of this report, the National Assembly was considering the Bill. [21]

In June 2014, the ECOWAS Court of Justice issued two separate judgments prohibiting Nigeria from executing two death row prisoners. One of the prisoners, Maimuna Abdulmumini, was sentenced to death for murdering her husband at the age of 13. The court held that the death sentence was a violation of the ICCPR’s prohibition on applying capital punishment to minors and awarded Abdulmumini trial costs and damages. In a second judgment, the court ruled that executing Thankgod Ebhos, who has a pending appeal in the Court of Appeal, would be also be a violation of the ICCPR. [22] In March 2014, Justice Minister Bello Adoke had announced that the federal government would suspend executions in accordance with the ECOWAS court’s interim decisions. [23] Nevertheless, he commented that the federal nature of the Nigerian justice system complicates the issue, nothing that the decision whether or not to execute a criminal ultimately resides with state governments. [24]

Is there currently an official moratorium on executions within the country?

There is no legislative or executive moratorium on executions in Nigeria. The last executions were carried out in 2013. [25] In 2007, the Presidential Commission on Reform of the Administration of Justice recommended a moratorium on the death penalty but the federal government did not implement it. [26]

Have there been any significant published cases concerning the death penalty in national courts?

In 1986, the federal Supreme Court ruled that the execution of Nasiru Bello, which took place while his appeal was still pending before the Court of Appeal, was unconstitutional. This ruling prevents executions from taking place unless a prisoner has exhausted the appeals process, provided the prisoner files an appeal. [27] Under the Constitution, appeals against death sentences are as of right. [28]

In 1998, the federal Supreme Court upheld the constitutionality of the death penalty, as long as it is imposed for a criminal offence by a court of law. [29]

Nigeria’s Supreme Court, in a 2007 appeal on a 1985 judgment from the state of Lagos, declined to rule on the constitutionality of the death penalty for armed robbery, instead overturning a conviction on narrower evidentiary grounds. [30]

In September 2012, the High Court (the highest appellate court) of Lagos State declared that the mandatory death penalty was unconstitutional. The court in James Ajulu & Ors v. Attorney General of Lagos also held that execution by hanging or firing squad is unconstitutional. It explained that these methods of execution amounted to “a violation of the condemned’s right to dignity of the human person and inhuman and degrading treatment” and are a violation of the right to human dignity as a person under Section 34(1) of the Lagos Constitution. [31] Its holding is only enforceable in Lagos State.

While we did not find court opinions by Shariah courts, Philip Alston, the U.N. Special Rapporteur on Summary, Extrajudicial and Arbitrary Executions, reported in 2006 that Shariah Courts of Appeal exercised review to limit application of the death penalty, overturning a number of sentences on the grounds that the state’s evidence failed to meet Shariah standards. Shariah appeals courts judges explained that under Shariah evidentiary standards, the death penalty should be only rarely applicable. Shariah Courts of Appeal apply principles that strongly support a presumption against the use of the death penalty, especially with regard to zina, or offenses against sexual mores. For instance, an estranged or divorced woman’s child is presumed to be her husband’s child even after several years have passed; sexual indiscretion cannot be considered adultery unless it is shown that a marriage was consummated; and sexual acts (including homosexual acts) cannot, in the absence of pregnancy or a confession (which can be retracted), be death eligible without the testimony of four witnesses. [32] As of 2006, the federal government’s position was that states applying Shariah law for sexual offenses are acting unconstitutionally, [33] but this issue has not come up for constitutional review.

Where can one locate or access judicial decisions regarding the death penalty?

All the decisions of the Supreme Court of Nigeria since its inception in 1963 are available on the court’s website (http://judgment.supremecourt.gov.ng) and can be searched by title or date. Some recent judgments are also available on the website of the Court of Appeals (http://www.courtofappeal.gov.ng). The website of the Federal High Courts was under construction at the time of research but may in future include judicial decisions (http://www.fhc-ng.com/libray.htm).

Judgments from death penalty cases tried at the state level may also be available on the websites of the relevant courts. The website of the Lagos judiciary, for instance, hosts some judicial decisions (https://lagosjudiciary.gov.ng/jis_new/programs.aspx).

There is no government case law reporting and of the many case reporters published privately over the years, none has lasted long enough to become a single comprehensive source. [34]

What is the clemency process?

According to the Nigerian Constitution, the President and State Governors have the power to grant pardons and commute death sentences. The President may pardon, suspend, or decrease any punishment imposed under a law passed by the National Assembly after consultation with the Council of State and may also exercise these powers with respect to death sentences issued by a court-martial. [35] Governors exercise similar powers with respect to punishments imposed under state law “after consultation with such advisory council of the state on [the] prerogative of mercy as may be established by law of the State.” [36] Prisoners may petition for clemency after they have exhausted all appeals. [37]

Amnesty International reported in 2008 that the absence of clear guidelines obscures access to the clemency process. For instance, prisoners may be eligible for commutation or release after 10 years of good conduct on death row, but there are no guidelines defining good conduct and some prisoners report that bribes are necessary to be listed as eligible for commutation or release. [38]

In practice, pardons and commutations of death sentences occur at both the federal and state levels. In January 2000, for instance, President Obasanjo issued a federal amnesty, ordering the pardon and release of prisoners who had been on death row for over 20 years and commutations to life imprisonment for those who had been on death row for 10 to 20 years. [39] At the state level, in another example, the governor of Lagos pardoned and released three death row inmates in June 2009. [40] According to our sources, many State Governors do not sign execution warrants and the mass commutation of death sentences is carried out predominantly at the state level, usually on national holidays. [41]

Are jury trials provided for defendants charged with capital offenses?

No. [42]

Brief Description of Appellate Process

Individuals charged with federal and certain other capital offenses are tried in the Federal High Courts. Appeal against a capital conviction or sentence lies as of right to the Court of Appeal and then to the Supreme Court. [43]

Muslims in states maintaining Shariah courts, or other individuals who consent to the jurisdiction of a Shariah court, may be tried for criminal offenses by Shariah courts. The Shariah criminal procedure code allows defendants 30 days to appeal sentences involving mutilation or death. [44] Cases are tried before the Lower Shariah Courts, and appealed to the Upper Shariah Courts and then to the Shariah Courts of Appeal. Only one judge sits on lower and upper Shariah courts, whereas between three and five judges sit on the Court of Appeals. [45] Shariah appellate courts have consistently overturned stoning sentences on account of procedural or evidentiary problems. [46] Appeals from Shariah Courts of Appeal lie to the federal Court of Appeal and then to the Supreme Court as of right. [47] The Shariah Court of Appeal of the Federal Capital Territory operates in Abuja. Constitutionally, however, the jurisdiction of the court pertains only to civil matters under Islamic law, although the National Assembly may confer additional jurisdiction on the court. [48]

References

[1] Constitution of the Federal Republic of Nigeria, art. 33(1), May 29, 1999.
[2] Constitution of the Federal Republic of Nigeria, arts. 233(2)(d), 241(1)(e), May 29, 1999.
[3] Constitution of the Federal Republic of Nigeria, Preamble, May 29, 1999.
[4] Constitution of the Federal Republic of Nigeria, art. 19(d), May 29, 1999.
[5] Constitution of the Federal Republic of Nigeria, Fundamental Rights (Enforcement Procedure) Rules, Order I – Application and Interpretation, art. 2, Nov. 11, 2009.
[6] Constitution of the Federal Republic of Nigeria, Fundamental Rights (Enforcement Procedure) Rules, Preamble, art. 3(b), Nov. 11, 2009.
[7] Constitution of the Federal Republic of Nigeria, Fundamental Rights (Enforcement Procedure) Rules, art. 3(b), Nov. 11, 2009.
[8] Constitution of the Federal Republic of Nigeria, Fundamental Rights (Enforcement Procedure) Rules, Preamble, art. 3(a), Nov. 11, 2009.
[9] Constitution of the Federal Republic of Nigeria, Fundamental Rights (Enforcement Procedure) Rules, Preamble, art. 3(e), Nov. 11, 2009.
[10] Constitution of the Federal Republic of Nigeria, Fundamental Rights (Enforcement Procedure) Rules, Preamble, art. 3(g), Nov. 11, 2009.
[11] Constitution of the Federal Republic of Nigeria, Fundamental Rights (Enforcement Procedure) Rules, Order III – Limitation of Action, art. 1, Nov. 11, 2009.
[12] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ pp. 36-37, AFR 44/020/2008, Oct. 21, 2008.
[13] Amnesty Intl, Nigeria executions: “They almost executed him secretly”, https://www.amnesty.org/en/news/nigeria-death-penalty-feature-2013-06-28, Jun. 28, 2013.
[14] Amnesty Intl, Nigeria executions: “They almost executed him secretly”, https://www.amnesty.org/en/news/nigeria-death-penalty-feature-2013-06-28, Jun. 28, 2013.
[15] Amnesty Intl, Nigeria executions: “They almost executed him secretly”, https://www.amnesty.org/en/news/nigeria-death-penalty-feature-2013-06-28, Jun. 28, 2013.
[16] Amnesty Intl, Nigeria executions: “They almost executed him secretly”, https://www.amnesty.org/en/news/nigeria-death-penalty-feature-2013-06-28, Jun. 28, 2013.
[17] U.N.G.A. Human Rights Council, Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, Manfred Nowak, para. 61, U.N. Doc. A/HRC/7/3/Add.4, Nov. 22, 2007.
[18] For example, see: U.N. ESC, Report of the Special Rapporteur on Summary, Extrajudicial or Arbitrary Executions, Philip Alston, paras. 21-26, 32-28, 81, E/CN.4/2006/53/Add.4, Jan. 7, 2006.
[19] Nigerian Monitor, President Goodluck Jonathan Seeks Death Penalty for Cyber Crime, Jan. 29, 2014.
[20] CybercrimeBill 2013, sec 5(3), Jan. 28, 2014.
[21] Eseohe Ebhota, Nigerians React to Cyber-Crime Bill, AllAfrica.com, http://allafrica.com/stories/201402031339.html, Feb. 2, 2014.
[22] Bertram Nwannekanma, ECOWAS Court upholds rights of death row detainees, http://www.ngrguardiannews.com/news/national-news/166818-ecowas-court-upholds-rights-of-death-row-detainees, Jun. 18, 2014.
[23] Ikenna Emewu, ECOWAS Court Stops Death Penalty in Nigeria, The Sun, http://sunnewsonlinEd.com/new/?p=56385, Mar. 15, 2014.
[24] Ikenna Emewu, ECOWAS Court Stops Death Penalty in Nigeria, The Sun, http://sunnewsonlinEd.com/new/?p=56385, Mar. 15, 2014.
[25] Amnesty Intl, Nigeria executions: “They almost executed him secretly”, https://www.amnesty.org/en/news/nigeria-death-penalty-feature-2013-06-28, Jun. 28, 2013.
[26] Amnesty Intl, Nigeria: Amnesty International, Human Rights Watch and Nigerian Civil Society Groups Call on State Governments Not To Resume the Execution of Prisoners, AFR 44/010/2010, Jun. 25, 2010.
[27] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 34, AFR 44/020/2008, Oct. 21, 2008.
[28] Constitution of the Federal Republic of Nigeria, arts. 233(2)(d), 241(1)(e), 251(2&3), 272(1),May 29, 1999, as amended by the Fundamental Rights (Enforcement Procedure), Nov. 11, 2009. Amnesty Intl., Nigeria: Waiting for the Hangman, p. 42, AFR 44/020/2008, Oct. 21, 2008.
[29] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 41, AFR 44/020/2008, Oct. 21, 2008.
[30] Olayinka v. State, S.C. 279/2003, Supreme Court of Nigeria, Apr. 20, 2007.
[31] The Nation, Court Restrains Govt From Executing Five by Hanging, http://thenationonlineng.net/new/court-restrains-govt-from-executing-five-by-hanging/, Sep. 25, 2012.
[32] For example, see: U.N. ESC, Report of the Special Rapporteur on Summary, Extrajudicial or Arbitrary Executions, Philip Alston, paras. 21-26, 32-28, E/CN.4/2006/53/Add.4, Jan. 7, 2006.
[33] For example, see: U.N. ESC, Report of the Special Rapporteur on Summary, Extrajudicial or Arbitrary Executions, Philip Alston, paras. 21-26, 32-28, E/CN.4/2006/53/Add.4, Jan. 7, 2006.
[34] Yemisi Dina, John Akintayo & Funke Ekundayo, Update: Guide to Nigerian Legal Information, GlobaLex, http://www.nyulawglobal.org/globalex/Nigeria1.htm, Mar. 2013.
[35] Constitution of the Federal Republic of Nigeria, art. 175, May 29, 1999.
[36] Constitution of the Federal Republic of Nigeria, art. 212, May 29, 1999.
[37] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ pp. 42-43, AFR 44/020/2008, Oct. 21, 2008.
[38] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 23, AFR 44/020/2008, Oct. 21, 2008.
[39] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 23, AFR 44/020/2008, Oct. 21, 2008.
[40] Amnesty Intl., Death Sentences and Executions in 2009, p. 23, ACT 50/001/2010, Mar. 30, 2010.
[41] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[42] Criminal Procedure Act, art. 368(3), Laws of the Federation of Nigeria Ed. 2000 Ch. 80, Jun. 1, 1945, as updated to Dec. 31, 2000.
[43] Constitution of the Federal Republic of Nigeria, arts. 233(2)(d), 241(1)(e), 251(2&3), 272(1), May 29, 1999. Amnesty Intl., Nigeria: Waiting for the Hangman, p. 42, AFR 44/020/2008, Oct. 21, 2008.
[44] U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[45] Human Rights Watch, “Political Shariah” Human Rights and Islamic Law in northern Nigeria, p. 18, Vol. 16, No.9, Sep. 2004.
[46] U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[47] Human Rights Watch, “Political Shariah” Human Rights and Islamic Law in northern Nigeria, p. 18, Vol. 16, No.9, Sep. 2004.
[48] Constitution of the Federal Republic of Nigeria, art 262(1), May 29, 1999.

Death Penalty In Practice

Where Are Death-Sentenced Prisoners incarcerated?

Death-row inmates are held in Enugu Prison, Lagos Kiri-kiri Prison, Oko Prison, Port Harcourt prison, Benin City Prison and Kaduna prison in Nigeria. [1]

A 2008 report notes that 5 of 11 female death row inmates were held in Kiri-kiri Women’s Prison while the other 6 were “held in the female wings of six other prisons,” such as Katsina Central Prison. [2]

Description of Prison Conditions

Prison conditions and the treatment of prisoners on death row vary somewhat from one facility to another, [3] but conditions are harsh and life-threatening throughout the country. Most prisons in Nigeria were built prior to 1960 and are in such a state of decay that during a recent prison escape the walls of the prison simply gave way. [4]

Prisons are grossly overcrowded, with some prisons holding more than 800 percent of their designed capacity. [5] Lack of potable water and inadequate sewage facilities result in dangerous and unsanitary conditions. Ventilation is insufficient, and prisoners are forced to use buckets as toilets, with little or no privacy. The food provided on a budget of approximately $1.50 a day per prisoner is of very poor quality. [6] Because “prison officials routinely [steal] money provided for food for prisoners,” only those with resources or relatives who are able to bring food have regularly adequate nutrition. Bedding is inadequate; some prisoners must sleep on concrete floors, without blankets. Extortion, abuse and torture are common. [7]

Prisons usually have medical facilities, but many inmates are ill because they lack the money to bribe wardens for access to medical care or to purchase necessary medications. Mosquito netting and basic medicines are lacking. Malaria, influenza, tuberculosis, and the spread of HIV/AIDS threaten prisoners’ lives. [8]

Prisoners suffer from violence. Female inmates report facing threats of rape. [9]

Many prisoners die due to lack of medical care, inadequate nutrition and the spread of serious but preventable diseases. Many prisoners have reported witnessing the death of a fellow inmate due to these conditions. [10]

Death row prisoners are segregated from the general population in cell blocks built to hold 6 inmates but which can hold up to 18-24 people. [11] Death row conditions vary from prison to prison. In some prisons, death row inmates are restricted to their cells throughout most of the day, but in others prisoners are allowed outside their cells during the day. [12] Death-sentenced prisoners do not know when they will be executed. One inmate reported that upon arrival of the hangman at the prison, guards give progressively more precise hints until prisoners are able to determine who will be hanged. Another inmate reported that, in his prison, inmates did not know who would be executed; only after 2 p.m. does a prisoner know that he will not be executed that day. Prisoners who have exhausted the appeals process are often held in a section of the jail where they can see executions taking place. After an execution, other death row inmates are asked to clean the gallows. Condemned prisoners spend an average of 20 years under these conditions, developing serious mental illnesses for which they receive no treatment. [13] One organization is “trying to compel judges to remove mentally ill prisoners from the general population.” [14] Furthermore, individuals accused of death-eligible crimes are forced to wait long periods of time before trial. Of the over 1,000 people who were under sentence of death in Nigeria at the end of 2012, most have waited between five and 10 years to be tried. [15]

Prison officials sometimes reportedly make efforts to improve conditions for death row inmates. According to Amnesty International, Kiri-Kiri Prison officials addressed dark and filthy conditions by painting death row blocks in bright colors, and this had some positive impact on inmates’ mental well-being. [16]

Are there any known foreign nationals currently under sentence of death?

We did not find any reports of foreign nationals currently on Nigeria’s death row. [17]

What are the nationalities of the known foreign nationals on death row?

We did not find any reports of foreign nationals currently on Nigeria’s death row. [18]

Are there any known women currently under sentence of death?

At the end of 2011 an estimated 16 women were on death row. [19] We were unable to find more recent figures.

Are there any reports of individuals currently under sentence of death who may have been under the age of 18 at the time the crime was committed?

There may be juveniles under sentence of death in Nigeria. [20] In 2010, there were 40 death row inmates believed to have been under the age of 18 at the time of their offenses. [21] We have not seen any reports that these death sentences were reviewed. Furthermore, as of March 2013, fifteen of Nigeria’s thirty-six states did not legally prohibit the execution of prisoners who were under 18 at the time of their offenses. [22]

In June 2014, the ECOWAS Court of Justice issued a judgment holding that the death sentence of Maimuna Abdulmumini, who was convicted of murdering her husband at the age of 13, was a violation of the ICCPR’s prohibition on applying capital punishment to minors. The court awarded Abdulmumini trial costs and damages. [23] In March 2014, Justice Minister Bello Adoke had announced that the federal government would not carry out her execution in accordance with the ECOWAS court’s interim decisions. [24] The ECOWAS judgment thus has the potential to change Nigeria’s practice with regard to sentencing juveniles to death.

Comments regarding the racial/ethnic composition on death row

We did not find any specific discussion of racial or ethnic disparity in application of the death penalty.

Are there lawyers available for indigent defendants facing capital trials?

The Constitution provides that the National Assembly may designate a High Court to determine whether a defendant’s “need for legal aid is real.” [25] The Legal Aid Act defines the right to legal representation. [26] While according to some reports the right to legal representation in capital cases is conceded, [27] others indicate that in practice the right to representation in capital cases is not always respected. [28] Attorneys are denied access to evidence, and on at least one occasion an attorney was simply instructed by the court to “sit down” and was not permitted to properly mount a defense in court. In some cases, the attorneys appointed to capital defendants are inexperienced. [29]

According to an in-country expert, legal aid is difficult to come by. When funds are set aside by the District Attorney for legal aid attorneys, compensation is at approximately 10% of the usual rate. Federal legal aid is usually supplied by overworked, inexperienced lawyers who quickly transition to civil litigation practice. People who seek legal aid through other means such as NGOs or via a court appointment may experience delays. It is uncommon for a defendant to have access to an attorney soon after arrest and lawyers may not be present during police interrogations. [30]

According to Amnesty International, the Legal Aid Council, a governmental organization established under the Legal Aid Act, is not required to provide attorneys for individuals accused of armed robbery (a crime which carries the death penalty), although the LAC is required to represent those accused of stealing and affray—less serious crimes. Amnesty reports that, in practice, the LAC increasingly defends those accused of armed robbery. [31]

Are there lawyers available for indigent prisoners on appeal?

We did not find information indicating that indigent prisoners on appeal are able to obtain state-funded attorneys. In 2008, Amnesty International reported that 4 out of 10 prisoners on death row had not filed appeals either because they were denied the right to appeal or because they lacked money for court fees and an attorney. Some prisoners who had served a number of years on death row were reluctant to file appeals because the clemency process is perceived to be a more efficient and reliable path towards release. It is possible that some parts of Amnesty’s study are outdated because they address convictions of individuals under the military regime. With the advent of civilian government, and as the Legal Aid Council has increased its activities, it is possible that the situation is changing for more recent capital defendants. [32]

An in-country expert reported that access to appeals usually depends on money, and that legal aid or pro bono attorneys usually only handle trials. [33] Domestic and international charitable intervention has been effective in affording some defendants an appeal. [34] Our source corroborates that appeals for indigents tend to be the domain of NGOs. [35]

Comments on Quality of Legal Representation

The government sometimes does not respect the defense’s right to review prosecution evidence prior to trial or to mount an adequate defense in the courtroom. [36] Moreover, the government sometimes appoints inexperienced attorneys to represent those facing capital charges [37] and legal aid fees are reportedly set at 10% of the normal rate. [38]

An in-country expert notes that there are few attorneys who specialize in criminal defense work. Due to financial restraints and police intimidation, defense attorneys rarely conduct independent investigations prior to trial. A defense attorney who attempts to investigate may be accused of witness tampering and threatened with arrest. Defense attorneys do not depose prosecution witnesses; they are given a list of witnesses and what those witnesses will say at trial, and the prosecution may withhold information. The defense may be forced to rely on a witness coming forward. Forensics testing is problematic; the police usually have only one forensic pathologist, such experts are usually not used in investigation, and the defense may have to bear the costs of forensic testing (such as autopsies) if an attorney believes that evidence from independent testing is necessary for an adequate defense. Police avoid the use of forensics testing in substantiating charges. [39]

Other Comments on Criminal Justice System

Until recently, Nigeria was ruled by a military government under which individuals were sentenced to death for common offenses by special tribunals and denied the right to appeal. Access to clemency (which still affects those convicted during that period) has, in recent years, been limited to those with financial means. [40]

Some of the human rights abuses related to application of the death penalty have been carried on by the civilian government. A 2000 study revealed that approximately 80% of individuals in Nigerian prisons had been beaten or tortured by police. [41] By 2007 Manfred Nowak, the U.N. Special Rapporteur on torture, reported that “torture is an intrinsic part of how the police operate within the country,” and at criminal investigation detention facilities “it was a challenge to find a detainee who had not been ill-treated. [42] ” Amnesty International reported that, by 2008, more than half of individuals on death row in Nigeria had been convicted on the basis of a confessional statement, with courts often failing to enforce the legal prohibition against the admissibility of coerced confessions. [43]

Individuals may be held for years before being brought to trial. Appeals may be pending for over a decade. [44]

Domestic human rights groups seeking to use the courts to pursue systemic reforms have met with some success, [45] and in general human rights defenders in Nigeria have been recognized as effective and resilient. [46] Notably, the Human Rights Protection Unit and the Office of the Public Defender have had a noticeable impact in Lagos State, according to a 2006 report by Hina Jilani, the U.N. Special Representative of human rights defenders. [47]

Asma Jahangir, the U.N. Special Rapporteur on religious freedom, reported that Muslims have complained of violations of their rights due to an “open ended monopoly of interpreting Shariah” that has been left in the hands of poorly trained judges. Muslim lawyers and scholars complained that they felt too threatened to challenge “the substance or implementation” of Shariah penal law. [48]

References

[1] Ayodeji Adeyami, Waiting Endlessly on Nigeria’s Death Row, Al Jazeera http://www.aljazeera.com/indepth/features/2013/11/waiting-endlessly-nigeria-death-row-2013112094420106741.html, Dec. 4, 2013. Afua Hisch, Nigeria Hangs Four Prisoners, the Guardian, http://www.theguardian.com/world/2013/jun/25/nigeria-prisoners-hanged-benin-city, Jun. 25, 2013. Nigeria: In Overcrowded Prisons, Survival is a Daily Battle, IRIN, http://www.irinnews.org/report.aspx?reportid=57777, Jan. 11, 2006. Amnesty Intl., Nigeria and the World Day 2006: Unfair Trials, p. 1, http://www.amnestyusa.org/actioncenter/actions/action7579.pdf, 2006.
[2] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 28, 29, AFR 44/020/2008, Oct. 21, 2008.
[3] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 26, AFR 44/020/2008, Oct. 21, 2008.
[4] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[5] U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[6] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[7] U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[8] U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[9] U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[10] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 25-29, AFR 44/020/2008, Oct. 21, 2008. U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[11] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[12] Amnesty Intl., Nigeria: Waiting for the Hangman, p. 26, AFR 44/020/2008, Oct. 21, 2008.
[13] Amnesty Intl., Nigeria and the World Day 2006: Unfair Trials, p. 1, http://www.amnestyusa.org/actioncenter/actions/action7579.pdf, 2006; Amnesty Intl., Nigeria: Waiting for the Hangman, p. 4-5, 27, AFR 44/020/2008, Oct. 21, 2008.
[14] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[15] Amnesty Intl, Nigeria: Authorities in Nigeria must not carry out any further executions of death row prisoners, http://www.refworld.org/pdfid/5225cf514.pdf, Aug. 28, 2013.
[16] Amnesty Intl., Nigeria: Waiting for the Hangman, p. 26, AFR 44/020/2008, Oct. 21, 2008.
[17] Mark Warren, Foreigners Under Sentence of Death Worldwide, http://users.xplornet.com/~mwarren/world.html, Jan. 19, 2013.
[18] Mark Warren, Foreigners Under Sentence of Death Worldwide, http://users.xplornet.com/~mwarren/world.html, Jan. 19, 2013.
[19] Amnesty Intl, Annual Report 2012-Nigeria, http://www.amnesty.org/en/region/nigeria/report-2012#section-15-9, last accessed Mar. 7, 2014.
[20] Amnesty Intl., Death Sentences and Executions in 2009, p. 8, ACT 50/001/2010, Mar. 30, 2010.
[21] U.N. CRC, Committee on the Rights of the Child, Concluding Observations: Nigeria, para. 33, U.N. Doc. CRC/C/NGA/CO/3-4, Jun. 11, 2010.
[22] Child Rights International Network, Inhuman Sentencing of Children In Nigeria, http://www.crin.org/docs/Nigeria_UPR_CRIN_FINAL.pdf, Mar. 2013.
[23] Bertram Nwannekanma, ECOWAS Court upholds rights of death row detainees, http://www.ngrguardiannews.com/news/national-news/166818-ecowas-court-upholds-rights-of-death-row-detainees, Jun. 18, 2014.
[24] Ikenna Emewu, ECOWAS Court Stops Death Penalty in Nigeria, The Sun, http://sunnewsonlinEd.com/new/?p=56385, Mar. 15, 2014.
[25] Constitution of the Federal Republic of Nigeria, art. 46(b)(ii), May 29, 1999.
[26] Amnesty Intl., Nigeria: Waiting for the Hangman, p. 17, AFR 44/020/2008, Oct. 21, 2008.
[27] U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Denial of Fair Public Trial, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[28] Amnesty Intl., Nigeria: Waiting for the Hangman, p. 17, AFR 44/020/2008, Oct. 21, 2008.
[29] Amnesty Intl., Nigeria: Waiting for the Hangman, p. 17, AFR 44/020/2008, Oct. 21, 2008. U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Denial of Fair Public Trial, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[30] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[31] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 42, AFR 44/020/2008, Oct. 21, 2008.
[32] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 21, 42, generally, AFR 44/020/2008, Oct. 21, 2008.
[33] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[34] For example, see: U.N. ESC, Report of the Special Rapporteur on Summary, Extrajudicial or Arbitrary Executions, Philip Alston, paras. 21-26, 32-28, E/CN.4/2006/53/Add.4, Jan. 7, 2006.
[35] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[36] Amnesty Intl., Nigeria: Waiting for the Hangman, p. 17, AFR 44/020/2008, Oct. 21, 2008. U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Denial of Fair Public Trial, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[37] Amnesty Intl., Nigeria: Waiting for the Hangman, p. 17, AFR 44/020/2008, Oct. 21, 2008. U.S. Dept. of State, 2013 Human Rights Report: Nigeria, Denial of Fair Public Trial, http://www.statEd.gov/documents/organization/220358.pdf, Feb. 25, 2014.
[38] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[39] Adamu A. Ja’afaru, affiliated with Human Rights Law Service, interviewed by Ellen Wight, Nigeria Doc. Interview-1, Feb. 24, 2010.
[40] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 3, 10, 20-23, AFR 44/020/2008, Oct. 21, 2008.
[41] Amnesty Intl. Nigeria: Security Forces: Service to respect and protect human rights? p. 6, AFR 44/023/2002, Dec. 2002.
[42] U.N.G.A. Human Rights Council, Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, Manfred Nowak, paras. 36, 40, U.N. Doc. A/HRC/7/3/Add.4, Nov. 22, 2007.
[43] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 3, 10, 20-23, AFR 44/020/2008, Oct. 21, 2008. U.N.G.A. Human Rights Council, Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, Manfred Nowak, paras. 36, 40, U.N. Doc. A/HRC/7/3/Add.4, Nov. 22, 2007.
[44] Amnesty Intl., Nigeria: ‘Waiting for the Hangman,’ p. 4, 42, AFR 44/020/2008, Oct. 21, 2008.
[45] For example, see: Human Rights Watch, Nigeria: Civil Society Groups Call on State Governments Not to Resume the Execution of Prisoners, http://www.commondreams.org/newswire/2010/06/25-5, Jun. 25, 2010; Thomas Hubert, Abolitionists Block Nigerian Executions, WCADP, http://www.worldcoalition.org/modules/smartsection/item.php?itemid=443, Jul. 9, 2010.
[46] U.N. ESC, Report of the Special Representative of the Secretary-General on human rights defenders, Hina Jilani: Mission to Nigeria, paras. 4 et. seq., U.N. Doc. E/CN.4/2006/95/Add.2, Jan. 30, 2006.
[47] U.N. ESC, Report of the Special Representative of the Secretary-General on human rights defenders, Hina Jilani: Mission to Nigeria, paras. 30-33, U.N. Doc. E/CN.4/2006/95/Add.2, Jan. 30, 2006.
[48] U.N. ESC, Report of the Special Rapporteur on freedom of religion or belief, Asma Jahangir: Mission to Nigeria, paras. 40-42, U.N. Doc. E/CN.4/2006/5/Add.2, Oct. 7, 2005.

Decisions of International Human Rights Bodies

Decisions of Human Rights Committee

The Human Rights Committee has not issued concluding observations concerning Nigeria’s compliance with the International Covenant on Civil and Political Rights since 1996, when Nigeria last submitted a state party report. [1]

In 1996, the Human Rights Committee expressed concern about the high number of death sentences passed and carried out without the safeguard of fair trials. The Committee also noted that the death penalty could be imposed for offenses that do not meet the “most serious crimes” standard. [2]

Decisions of Other Human Rights Bodies

In June 2014, the ECOWAS Court of Justice issued two separate judgments prohibiting Nigeria from executing two death row prisoners. One of the prisoners, Maimuna Abdulmumini, was sentenced to death for murdering her husband at the age of 13. The court held that the death sentence was a violation of the ICCPR’s prohibition on applying capital punishment to minors and awarded Abdulmumini trial costs and damages. In a second judgment, the court ruled that executing Thankgod Ebhos, who has a pending appeal in the Court of Appeal, would be also be a violation of the ICCPR. [3] In March 2014, Justice Minister Bello Adoke had announced that the federal government would suspend executions in accordance with the ECOWAS court’s interim decisions. [4] Nevertheless, he commented that the federal nature of the Nigerian justice system complicates the issue, nothing that the decision whether or not to execute a criminal ultimately resides with state governments. [5]

In the Human Rights Council’s 2013 University Periodic Review of Nigeria, the death penalty was brought up on several occasions. A few members brought up the four executions that took place in 2013, and asked why Nigeria chose to break its de facto moratorium on the death penalty. [6] Nigeria stated that death penalty laws “could only be changed by through negotiation and persuasion and not by government fiat” and added that the 2013 executions had been carried out in accordance with the law and due process. [7] A number of countries recommended that Nigeria establish an official moratorium on the death penalty and ratify the Second Optional Protocol to the ICCPR aiming at the abolition of the death penalty. [8] Nigeria reserved its response to these recommendations until a later date. [9]

In the Human Rights Council’s 2009 Universal Periodic Review of human rights in Nigeria, council members made numerous recommendations that Nigeria suspend application of the death penalty with a view towards abolition and accede to the second optional protocol to the International Covenant on Civil and Political Rights. Nigeria noted that, as of 2009, it was continuing a self-imposed moratorium on executions. [10] In its national report, Nigeria noted “the global trend for a moratorium on the death penalty.” [11]

In preparation for the Universal Periodic Review, the Office of the High Commissioner on Human Rights submitted a compilation expressing concern that in Nigeria executions are carried out in secret, that under Shariah law individuals can be executed for crimes committed while under the age of 18, and that the expansion of Shariah law could lead to the execution of apostates. [12]

References

[1] U.N. Office of the High Commissioner for Human Rights, Reporting status for Nigeria, http://tbinternet.ohchr.org/_layouts/TreatyBodyExternal/countries.aspx?CountryCode=NGA&Lang=EN, last accessed Apr. 23, 2014.
[2] U.N. Human Rights Committee, Consideration of Reports Submitted by States Parties Under Article 40 of the Covenant: Concluding Observations of the Human Rights Committee: Nigeria, U.N. Doc. CCPR/C/79/Add. 65, Jul 24, 1996.
[3] Bertram Nwannekanma, ECOWAS Court upholds rights of death row detainees, http://www.ngrguardiannews.com/news/national-news/166818-ecowas-court-upholds-rights-of-death-row-detainees, Jun. 18, 2014.
[4] Ikenna Emewu, ECOWAS Court Stops Death Penalty in Nigeria, The Sun, http://sunnewsonlinEd.com/new/?p=56385, Mar. 15, 2014.
[5] Ikenna Emewu, ECOWAS Court Stops Death Penalty in Nigeria, The Sun, http://sunnewsonlinEd.com/new/?p=56385, Mar. 15, 2014.
[6] U.N.G.A., Human Rights Council, Report of the Working Group on the Universal Periodic Review: Nigeria, para. 115, U.N. Doc. A/HRC/25/6, Dec. 16, 2013.
[7] U.N.G.A., Human Rights Council, Report of the Working Group on the Universal Periodic Review: Nigeria, para. 18, U.N. Doc. A/HRC/25/6, Dec. 16, 2013.
[8] U.N.G.A., Human Rights Council, Report of the Working Group on the Universal Periodic Review: Nigeria, para. 137, U.N. Doc. A/HRC/25/6, Dec. 16, 2013.
[9] U.N.G.A., Human Rights Council, Report of the Working Group on the Universal Periodic Review: Nigeria, para. 137, U.N. Doc. A/HRC/25/6, Dec. 16, 2013.
[10] U.N.G.A., Human Rights Council, Report of the Working Group on the Universal Periodic Review: Nigeria, U.N. Doc. A/HRC/11/26, Mar. 3, 2009.
[11] U.N.G.A., Human Rights Council, National Report Submitted in Accordance with Paragraph 15(A) of the Annex to Human Rights Council Resolution 5/1: Nigeria, para. 75, U.N. Doc. A/HRC/WG.6/4/NGA/1, Jan. 5, 2009.
[12] U.N.G.A., Human Rights Council, Compilation Prepared by the Office of the High Commissioner for Human Rights, in Accordance with Paragraph 15(B) of the Annex to Human Rights Council Resolution 5/1: Nigeria, paras. 21, 40, U.N. Doc. A/HRC/WG.6/4/NGA/2, Jan. 5, 2009.

Additional Sources and Contacts

Direct member(s) of World Coalition Against the Death Penalty

Nigerian Humanist Movement
Mr. Léo Igwe
Executive Secretary
PO BOX 25269 Mapo
200002 Ibadan
Oyo State, Nigeria
Tel: +234 80 33 86 10 53
humanistleo@hotmail.com
http://www.nigerianhumanists.com

HURILAWS (Human Rights Law Services)
Mr. Ja'afaru Adamu
Legal/Program Officer
Maritime Complex, 34, Creek Road - Apapa
234 Lagos, Nigeria
Tel: +234 1 745 3732
Fax: +234 1 545 4554
a.jaafaru@hurilaws.org
http://www.hurilaws.org

Legal Defence & Assistance Project (LEDAP)
Mr. Chino Obiagwu
National Coordinator
3rd Floor Lamlat House, 270 Ikorodu Road, Anthony Village
P.O. Box 6828 Shomulu, Lagos, Nigeria
Tel: +234 1 2802009
Fax: +234 1 2802009
info@ledapnigeria.org
www.ledapnigeria.org

Other non-governmental organizations and individuals engaged in advocacy surrounding the death penalty

PRAWA
Federal Capital Territory (F.C.T.)
Abuja, Nigeria
info@prawa.org, uagomoh@prawa.org
Tel: +234 803 6877 166

Reprieve
PO Box 72054
London EC3P 3BZ
United Kingdom
Tel 020 7553 8140
Fax 020 7553 8189
info@reprieve.org.uk
http://www.reprieve.org.uk

Helpful Reports and Publications

Amnesty International, Nigeria: Waiting for the Hangman, AFR 44/020/2008, http://www.amnesty.org/en/news-and-updates/news/poverty-and-the-death-penalty-in-nigeria-20081021, Oct. 21, 2008.

Center for Islamic Legal Studies, Harmonised Shariah Penal Code Annotated, Ahmadu Bello University, Zaria, Mar. 2002.

Human Rights Watch, “Political Shariah” Human Rights and Islamic Law in Northern Nigeria, p. 13, Vol. 16, No.9, Sep. 2004.

Ostien, Philip, Sharia Implementation in Northern Nigeria 1996-2006: A Sourcebook, Chapter 4, pp. 3-21, Philip Ostien, ed., Ibadan: Spectrum Books Ltd., 2007.

Additional notes regarding this country

None.

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