Finding  A  Lasting Solution For The Increasing Nigerian Cases of Police Brutality In  A COVID-19 Pandemic : Enforcement of Extant Laws or A Legislative Intervention? -By Ewulum Ifechukwu Christopher

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In exercise of official duty a police officer is duty bound to take necessary precaution and also to exercise due care and caution in order to avoid causing injury, harm or death of other persons.” Per Amiru Sanusi, JSC in Akinyede Olaiya v The state [2017] LPELR-43714(SC)


The incessant and unlawful killing, brutalization, and extortion  of innocent citizens by some members of the Nigerian police force (NPF) who are charged with the responsibility of protecting the lives and properties of the same citizens is Appalling and sends a bad impression to the international community.[1] Some other reasons like refusal to pay bribe, argument, accidental discharge etc have resulted in the unfortunate death of some innocent citizens in this COVID-19 pandemic. This work therefore provides a comprehensive review of the Nigerian legal framework and judicial decisions on these critical issues with a view to ascertaining whether there should be a legislative intervention or an enforcement of existing laws to provide a lasting solution. It concludes by holding the view that there are enough laws to tackle this issue just that more than mere enforcement of our laws need to be done if we are to achieve any meaningful progress.


1.0 Introduction.

The executive arm of the government headed by the president is saddled with the sacred responsibility under Section 5(1) and (2)  paragraph b of the Constitution of the Federal Republic of Nigeria 1999 as Amended (CFRN 1999) of execution and maintenance of the Constitution, all laws made by the National Assembly and to all matters with respect to which the National Assembly has, for the time being, power to make laws. Hence, the executive executes the laws made by the national assembly etc. It also ensures that the lives and properties of its citizens are protected in the state it oversees its affairs. Little wonder, an important section under the fundamental objectives and directive principles of state policy provides succinctly that the security and welfare of the people shall be the primary purpose of government.[2]

To ensure that these responsibilities are met, the executive has it  as part of its body the police force which is  controlled by the police service commission and headed by an inspector General of Police who is directly responsible to the president of Nigeria. Section 4 of the Police Act[3]  which provides for the responsibility of the police states that The police shall be employed for the prevention and detection of crime, the apprehension of offenders, the preservation of law and order, the protection of life and property and the due enforcement of all laws and regulations with which they are directly charged, and shall perform such military duties within or outside Nigeria as may be required of them by, or under the authority of this or any other Act. Furthermore, in Ona v Okenwa, [4]  the court added that the primary duties of the police officers are that of investigation and detection of crime. With all these stated, it is ironical that those who are charged with these responsibilities are to be heard of to be the ones breaching the same responsibilities.

Few months ago, the National Human Rights Commission released a report revealing that during the first two weeks of the COVID-19 induced lockdown alone, there were a total of 105 complaints of human rights violations by security forces in Nigeria including 8 documented incidents of extrajudicial killings leading to 18 deaths in Kaduna, Abia, Niger, Delta, Ebonyi and Katsina States[5]According to another report by the CableNews on May 30th 2020, a total of 92 persons have been killed within a year[6] and yet the question remains, how many cases have been reported to have been prosecuted successfully? The list of these aberrations both reported and unreported cases are unending and will still continue if substantive measures are not taken. Must the police officers kill while in the exercise of their lawful duty? Must they in exercise of their lawful duty extort, dehumanize or brutalize innocent citizens who they are paid to safeguard?

Before going into these issues, it need to be stressed that this work is conveniently divided into three parts. As a work that touches on principles of fundamental rights, it starts by giving an Appraisal of provisions of the law on fundamental human right; the second part examines case laws on the various subject matter and identifies the major causes of Police brutalization. The work is concluded by offering solutions on how we can solve these problems.

2.0  An Appraisal of the Human Rights  Framework.

fundamental rights have been defined as basic moral guarantees that people in all countries and cultures allegedly have simply because they are people. In Ransome-Kuti v  Attorney-General of the Federation[7] Eso, JSC stated that a fundamental right “is a right which stands above the ordinary laws of the land and which are in fact antecedent to the political society itself” and “it is a primary condition to civilized existence”. Fundamental rights are rights derived from natural or fundamental law

In the words of Jacques Maritain, “The human person possesses rights because of the very fact that it is a person, a whole, master of itself and of his acts, and which consequently is not merely a means to an end but an end, an end which must be treated as such[8]. In Nigeria, these rights are enshrined in chapter IV of the CFRN 1999. The rights which have been mostly breached by the operation of these security operatives include but not limited to right to  dignity of human person, life and Liberty. In Master v Mansur and ors,[9] the court relying on Jacques Maritain’s  book, ‘the  Rights of Man and Natural Law’ stated that the Expression, dignity of human person means that The expression means nothing if it does not signify that by virtue of natural law, the human person has the right to be respected, is the subject of rights, possesses rights. These are things which are owed to man because of the very fact that he is a man[10]

Calling these guarantees “rights” suggests that they attach to particular individuals who can invoke them, that they are of high priority, and that compliance with them is mandatory rather than discretionary. Human rights are frequently held to be universal in the sense that all people have and should enjoy them, and to be independent in the sense that they exist and are available as standards of justification and criticism whether or not they are recognized and implemented by the legal system or officials of a country. The moral doctrine of human rights aims at identifying the fundamental prerequisites for each human being leading a minimally good life –[11]

Section 34 of the CFRN 1999 was very explicit when it states under subsection 1 that Every individual is entitled to respect for the dignity of his person, and accordingly –

(a) no person shall be subject to torture or to inhuman or degrading treatment;

(b) no person shall he held in slavery or servitude; and

(c) no person shall be required to perform forced of compulsory labour[12].

Section 2(1) of the Anti-Torture Act 2017 states that Torture is deemed committed when an act by which pain or whether physical or  mental, is inflicted on a person to – (a) obtain information or a confession from him or a third person; (b) punish him for an act he or a third person has committed or is suspected of having committed; or (c) intimidate or ‘coerce him or a third person for any . reason based on discrimination of any kind, when such pain or suffering is inflicted by or at the instigation of or with the consent or acquiescence of a public official or other person acting an official capacity provided it does not include pain or -suffering in compliance with lawful sanctions. Section 33 (1) of the 1999 CFRN Gurantees that Every person has a right to life, and no one shall be deprived intentionally of his life, save in execution of the sentence of a court in respect of a criminal offence of which he has been found guilty in Nigeria.

Subsection 2 provides exceptions to the provisions of Section 1. It states that A person shall not be regarded as having been deprived of his life in contravention of this section, if he dies as a result of the use, to such extent and in such circumstances as are permitted by law, of such force as is reasonably necessary -(a) for the defence of any person from unlawful violence or for the defence of property:(b) in order to effect a lawful arrest or to prevent the escape of a person lawfully detained; or (c) for the purpose of suppressing a riot, insurrection or mutiny. The same constitution provides for right to liberty under Section 35. Section 46 specifies that Any person that alleges that any of the provisions of chapter IV of the constitution has been, is being or likely to be contravened in relation to him may apply to high court for redress.

Under Section 45 of the 1999 CFRN, only the rights to privacy, thought conscience and religion, expression, association and movement can be derogated based on public policy, public safety and health. Under Section 45(2) of the 1999 CFRN Section 33 and 35 which deals with rights to life and liberty respectively can only be derogated in state of emergency occurring from acts of war. It means that nobody, not even the armed forces is authorized to take anybody’s life save for periods of emergency which must be in a period of war and it must be reasonably justifiable for the purposes of dealing with that emergency.

On the other hand, it is settled law that it is not enough for a plaintiff to merely state that an act is illegal and unconstitutional. He must show how his civil rights and obligations have been breached or threatened. In an application for the enforcement of Fundamental Human Rights, particularly where arrest is alleged, the Applicant must prove specific detention and duration. The the arrestee must prove to the smallest detail that the arrest or intended arrest was unlawful in the sense that the laid down procedure was not followed by the person effecting the arrest.[13]

2.1 How Have the Courts Approached these Issues Before?

The Supreme Court and the court of Appeal in various states divisions have dealt with cases of breach of fundamental human rights of life, dignity and liberty at numerous instances. the purpose of elucidating these cases is to show that the judicial arm has at various instances condemned in strong terms the act of Police officers unlawfully taking the law into their own hands.  Akinyede  Olaiya v The state[14]  is very apt to our discussion. the facts of the case is that  in the morning of 23rd March 2011, a violent  fracas broke out between the members of the Peoples Democratic Party (PDP) and the Action Congress of Nigeria (ACN) at Kota Junction, Omuo Ekiti, in Ekiti State. The fracas was occasioned by accusation and counter-accusation of the tearing of posters of the two rival political parties by their respective supporters.

A police team, comprising seven policemen including the appellant and  one Cp1. Ameh Richard, was sent to the Kota Junction to restore peace and order. The Divisional Police Officer (DPO) led the team. He had a pistol. The appellant and Cpl. Ameh Richard, respectively the 2nd and 1st Accused at the trial Court, each had an AK 47 riffle officially assigned from the office.The mobsters at the scene of the crime were allegedly dangerously armed with guns, cutlasses, bottles etc.

The DPO fired shots into the air to draw attention of the mobsters and warn the volatile crowd. What proceeded thereafter was that the appellant fired shots in the crowd (what was his intention) he admitted killing Faluyi Ayo but pleaded that it was unintentional. His conviction for murder was upheld by the Supreme Court. The Supreme Court came to the conclusion that even though his argument was that he lacked the necessary mens Rea (mental element) his argument does not hold water because he has not shown any lawful justification or excuse for the killing. In the words of Ejembi Eko JSC who delivered the lead judgment :

Let me quickly correct the impression that because the appellant was engaged in a lawful duty, the lives of other Nigerians no longer matter. The lives of other innocent Nigerians matter. Every police officer on a lawful duty and assigned a firearm must bear in mind that those other lives matter… It is therefore, not enough for the appellant’s counsel to submit that the appellant fired the fatal shot that killed the deceased during a discharge of a lawful duty… The learned counsel must show by credible evidence how the appellant, while on lawful duty, fired the shot with due care and diligence, considering the fact that firearm, particularly an AK 47 with live Ammunitions, is prima facie is very dangerous object within the rule in Rylands v Fletcher.[15]

In a concurring judgment by Okoro JSC, his Lordship further buttressed that:

It is unfortunate that a law enforcement officer, who is supposed to bring sanity and Order to the community, gleefully brings out his gun and recklessly fires same into the crowd of protesters without any imminent danger of threat to his life. For not caring about the consequences of that action, he ought to bear the legal consequences of such recklessness. May be, I need to remind the appellant and police officers like him that they are meant to use the guns to safeguard the lives of the citizenry they are paid to protect.


In another case viz Dilly v Inspector General of Police,[16] The Appellant brought an application by way of an originating summons under the Fundamental Rights (Enforcement Proceedings) Rules 2009 seeking to enforce the right to life of her son who died in Police custody upon his arrest by the Police. The trial Judge  heard the application and dismissed it on the 9th October, 2012.


The brief facts of this appeal are that the Appellant filed an application under the Fundamental Rights procedure to demand compensation for her son who at the instigation of the 5th – 7th Respondents was arrested by the Police and refused bail until the Appellant gives the Police the sum of N50,000.00 an amount she could not raise. As she made effort to get the money, the 3rd Respondent called her to say her son is dead. The applicant alleged that her son was severely beaten but the cause of death on the medical report was hypertension and cardiac arrest. She stated that her son never had the history of hypertension before his arrest.


Furthermore, that the Respondents made attempts through the community traditional ruler of the community to persuade her to drop her demands for justice. The court of Appeal unanimously overruled the trial court’s decision that the mother could not claim as she was not the person whose rights were breached. Although that is not our main focus here, the court of appeal upheld her reliefs that the arrest, brutalization and killing of her son is  wrongful, unfair, oppressive, unconstitutional, null and void as it violates the Applicants’ son constitutional rights under section 33, 34, 35, 36, 39 and 41 of the 1999 Constitution of the Federal Republic of Nigeria. The court of appeal has this to say:


There is no doubt that the Respondents contributed to his death even if the final blow that broke the camel’s back was cardiac arrest. Definitely the circumstances leading to the death of the applicants’ son clearly show that his right to life was violated by the beating before death. There is nothing wrong in giving medical care to suspects kept in Police custody indefinitely. The choice to keep suspects in custody without bail is one that should include providing adequate medical care to such suspects. A situation where people arrested could have been released on bail but denied bail until money is deposited is certainly reprehensible and must be condemned. I agree with the applicant that the right to life of her son was violated and therefore damages must follow for that violation. The applicant is entitled to a remedy. Per Yargata Byenchit JCA of Lagos state Judicial division.


Again, the courts have in strong terms condemned the act of inviting police officers to settle civil disputes as it is clearly outside the course of their duty. in Otuekong Raphael Bassey and Anor v Mr Dominic Jessy Akpan and ors[17], the court of appeal warned that the window created by the Constitution to temporarily deprive someone of his personal liberty is further regulated in Section 35 (3), (4) and (5). There is no provision made in any of our laws for the Police to arrest any person arbitrarily. the police  under Section 4 of the Police Act have the statutory duty to prevent and detect crime. The Police are also to carry out duties relating to the apprehension of offenders, the preservation of law and order, the protection of life and property and the due enforcement of all laws and regulations with which they are directly charged. The task before the Police is onerous and serious. The Police therefore cannot endeavour to engage in settlement of civil disputes or collection of customary debts. In the light of our present security challenges the Police must wean itself from this attitude of meddling with issues bothering settling private scores and civil disputes that have no bearing with maintenance of law and order[18]


the Public Officer of a law enforcement agency that allows himself to be used by any member of the public, to commit illegality that results in damages and liability to the Agency or government, should be made to pay such costs or damages, personally, either in part or in whole, if this can serve to warn such officer to act within the rules and scope of his office. The Police in particular, should consider this, to stem the tide of unlawful arrests and detentions, which have resulted in huge financial losses to the Force and the Nation. The court of appeal therefore awarded damages for illegal arrest and detention.


The case of Adekunle v the state[19] borders on the defence of Accidental discharge usually pleaded by police officers when they recklessly end the life of an innocent citizen. The appellant in this appeal was a sergeant in the Nigeria Police Force. On 7 February 1997, he was on anti-crime patrol duty along Sagamu Benin Express-Way. The patrol team was under the command of an Assistant Superintendent of Police. Not long after the arrival of the patrol teams and the taking of their positions, the Commander of the team heard gunshots from the Benin – Sagamu side of the Express-Way. He shouted and asked who fired the gunshots. He saw the appellant walking towards a moving bus with passengers.


The appellant replied to the Commander’s question that the gunshots were fired by him. The Commander asked the appellant why he fired the gunshots. There was no reply from the appellant. The Commander then quickly disarmed the appellant before moving towards the bus where he found three men and a girl, Alice Tominiyi, inside the bus had been hit by the bullets from the gunshots fired by the appellant. The victims were taken to the hospital where the girl, Alice eventually died on 8 February 1997. The trial court’s conviction was upheld by the court of appeal and the Supreme Court. The courts found that the appellant without any reason whatsoever opened up his gun on innocent passengers in a bus. When he was approached by his commander, he did not give any reason but was mute until some days after when he said that the gun failed down and discharged some bullets…

The Supreme Court per Ogbuagu JSC in disbelieve  and without any sympathy held as follows :

It is easy to tell lies, but very difficult at most times to justify the lie. Surely, if a gun/rifle, fell on the ground. And started emitting bullets, first of all, it is evidence that the gun must have been “cocked” for action. Secondly, that the bullets will not fly towards among vehicles and hit the windscreen and hit some passengers in the process.


In another paragraph of the judgment,  his lordship vehemently stated that :


That it is becoming very notorious and most disturbing these days, when policemen, use guns purchased for them with public money and meant for the protection of the citizenry, are freely used to mow down innocent citizens of this country with reckless and careless abandon and in each case or every event, the aggressor policeman, is heard to say and rely on “accidental discharge”. Enough, I think, is enough. Unless the courts “put down their feet” so to speak and make it abundantly clear to our policemen in this country, that never again, will such plea or defence be available to any of them accused of murder or acceptable by the courts, then of course Nigerians will continuously be sprayed with bullets from the police who will hide on the plea “he was killed by stray bullet” or by “accidental discharge”. I suppose that when a gun is properly locked, stray bullets and accidental discharge syndrome will not occur. Invariably, accidental discharge always occur, when some of the drivers, are unwilling and refuse to pay the N 20 (twenty naira) or such money being extorted by the police at every check point, (and there are so many on our roads separated by very short distances). When such drivers refuse to stop, OH yes, “they must be carrying contraband goods or some ‘imagined’ incriminating stuff”. This state of affairs is of common knowledge and it is a notorious fact on our Nigerian roads.


There are plethoras of cases on Police officers breaching human rights in many forms. Let me also restate that human rights are so important that in Peter Nemi v Attorney General of Lagos state,[20]  the  Seven (7) justices of the Supreme Court even went to the extent of holding in an unanimous judgment that  a condemned criminal in a death roll still has his or her rights protected. In this case, the appellant who was sentenced to death for Armed Robbery and conspiracy to commit Robbery on February 1986 have stayed for eight (8) years in prison waiting for execution.


The delay in their trial, determination of their appeals and their non-execution were entirely caused by the due process of law and the appellants have not in any manner whatsoever contributed to the delay. The apex court after listening to the various amicus curiae invited in that case concluded that since the appellant has raised a fresh issue which hinges on right to dignity of human person from the long delay, The appropriate court to determine the suit is the high court irrespective that his sentence for murder was upheld. It shows that a person in death roll still have the right to approach the court for the determination of his rights. The fresh issue was not determined by the Supreme Court because it has no jurisdiction to do so.


2.2 Examining Some of The Most Prominent Causes.

There are so many reasons for the recurring cases of human rights breach by the NPF. They are examined seriatem.

  1. Lack of Diligent Prosecution and Reportage of Cases: in Nigeria, the police force subject to the powers of the Attorney-General can prosecute offences in Nigeria. It is not surprising that police officers may at times try to frustrate the prosecution because it involves a member of theirs and have kept most of the important records that are necessary for that prosecution. Suppose that a police for instance kills another recklessly in a highway, the most competent witnesses there who saw what happened are his fellow police officers and the passengers. In most occasions, the passengers may not be available because of lack of sufficient information to locate them. This happened in Adekunle v The state [21] cited above. In this case, although the incident took place in the presence of all the five (5) members of the police, only two was made available for the Prosecution.
  2. Lack of Professionalism: lack of professionalism in the police force has also been one of the major causes of Police Brutality. This has been caused by way police officers handle citizens because of arguments and failure to pay the said #20 or #50 bribe). It should be stated that there is nowhere it was provided in the constitution or any other legislature that citizens must pay at checkpoints. According to a report by Cable News, the Nigeria police’ style of operation has always been a source of concern, especially when compared to other countries of the world. And its rankings over the years confirm this.

The security agency was ranked the worst in the world by the International Police Science Association and the Institute for Economics and Peace in the 2016 World Internal Security and Police Index (WISPI).[22] The police are often   underfunded and unequipped to deal with local security issues, forcing the Nigerian military to step in and establish order. In most circumstances.

  1. Ignorance Of The Rule Of Law and Blatant Disobedience Of The Provisions Of The Constitution. In Nigeria, there are constitutional provisions and legislative frameworks both national and international that prevents breach of human rights and offer various remedies for breach. The problem is that nobody cares to obey these laws and it seems nothing is done about it.

3.0   Recommendations and Conclusion: A Right without A Remedy?

So far, it can be seen that in Nigeria, there are enough legislations and court decisions to deal with these fundamental right breaches so that the problem cannot be that of legislative intervention or making new a new law. What then is the problem? Why do we keep having increase in number of human rights violations especially in this COVID-19 Lockdown without sufficient amount of prosecutions? What has been done with the reports so far?  It is therefore submitted that more than enforcement of existing laws needs to be done if meaningful progress can be made.

◼ There should be a reform in the Nigerian Police Force. for instance, there should be creation of State police to reduce the financial burden on the federal government.

◼ The Police Service Commission should provide Mechanism that will help to identify and deal with corrupt and other unethical practices by police officers. There should be constant publication and evaluation of reported cases.

◼ There should be an Improvement in the working conditions of Police officers coupled with increased salary. It is obvious that one of the major reasons why police officers collect N20 or N50 bribes in the main road or convert any slightest opportunity as a way of money making is because they underpaid. Part of what will help solve this problem is the creation of state police so that the state government can oversee the financial responsibilities of its own state police force.

◼ Adopting best  International practices and professionalism is also a good option. In advanced countries, police officers don’t torture citizens anyhow. The case of Floyd in the United States is a good example. If a single case that lead to the death of an American citizen coupled that he is a black American can lead to such heavy protest, it shows that these things barely happen. We should not accept it as a norm in Nigeria.

◼  There should be close monitoring and strict enforcement of our laws.

◼ The police service commission should always take deliberate action to mandate police officers who witnessed case of human rights violations to appear in the court or to offer the necessary information required of him for the successful prosecution of cases[23].

Finally, it should be noted that fundamental human rights are very important in any meaningful democratic society. It should not be toiled with at any slighest opportunity. Advocates, activists and legal practitioners should always see it as part of their responsibility to protect these rights as they have been doing.


About the writer.

Ewulum Ifechukwu Christopher is a Law student of the University of Nigeria, he is a writer and Researcher.



[1] Chinedu Asadu, ‘In Detail : Police Kill 92 Nigerians in one year-and Justice delayed for Victims’ [30th June 2020] <> accessed 21st July 2020.

[2] Section 14 Sub 2 of the CFRN 1999.

[3] Cap 19, Laws of The Federal Republic of Nigeria.

[4] 2010] 7 NWLR (Pt.1194) 512.

[5] The National Human Rights Commission Press Release on COVID-19 Enforcement So Far Report On Incidents of Violation of Human Rights [15th April 2020]<> accessed 21st July 2020.

[6] Ibid (n-1)

[7] [1985] 2 NWLR (Pt. 6) 211 at 230,

[8] Available at

[9] [2014] LPELR-23440(CA)

[10] Hassan v Economic and Financial Crimes Commission [2014] 1 NWLR (Pt. 1389) 607.

[11] Ibid (n-8)

[12] Subsection 2 states that for the purposes of subsection (1) (c) of this section, “forced or compulsory labour” does not include -(a) any labour required in consequence of the sentence or order of a court; (b) any labour required of members of the armed forces of the Federation or the Nigeria Police Force in pursuance of their duties as such;(c) in the case of persons who have conscientious objections to service in the armed forces of the Federation, any labour required instead of such service; (d) any labour required which is reasonably necessary in the event of any emergency or calamity threatening the life or well-being of the community; or (e) any labour or service that forms part of – (i) normal communal or other civic obligations of the well-being of the community. (ii) such compulsory national service in the armed forces of the Federation as may be prescribed by an Act of the National Assembly, or (iii) such compulsory national service which forms part of the education and training of citizens of Nigeria as may be prescribed by an Act of the National Assembly. See Articles 5 and 6 of the African Charter on Human and People’s Right. Ratified on 17th March 1983. Cap 10, Laws of the Federal Republic of Nigeria 1990.


[13] Gusau  v  Umezurike  [2012] All FWLR (Pt. 655) 291 @ 31

[14] [2017] LPELR-43714(SC)

[15] [1868] UKHL 1, (1868)LR 3 HL 330

[16] (CA/L/12/2013)[2016]

[17] [2018] LPELR-44341(CA)

[18] In Ogonna v Ogonna [2014] LPELR – 22308 CA;(16) it was held inter alia that : A party that employs the Police or any enforcement agency, to violate the fundamental rights of a citizen, should be ready to face the consequences, either alone or with the misguided Agency. In Ibiyeye v Gold [2013] ALL FWLR (Pt.659)1074;(17) OSIL Ltd v Balogun [2012] 7 WRN 143 at 173 – 174. The court repeated that  the police have no business helping parties to settle or recover debts. We also deprecated the resort by aggrieved creditors, to the Police to arrest their debtors using one guise of criminal wrong doing or another.

[19] (SC 52/2002) [2006]

[20] (SC 303/1990) [1994] 3 (14 October 1994)

[21] Ibid (n-18)

[22] Ibid (n-1)

[23] Under the Freedom of Information Act 2011, information for public or private uses should not be withheld from individuals who seek to use it for public interests like prosecution of criminal offences.

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