Article Citation: Yusuf Tajudeen Abiodun & Sulaiman Muhammad Jamiu (2024). The Problems and Prospects of the Independent Shari`cah Arbitration Panel (ISAP) in Southwestern Nigeria. DEGEL: The Journal of the Faculty of Arts and Islamic Studies, Vol. 21, No. 1. ISSN 0794-9316
THE
PROBLEMS AND PROSPECTS OF THE INDEPENDENT SHARI’AH ARBITRATION
PANEL (ISAP) IN SOUTHWESTERN NIGERIA
By
Yusuf Tajudeen Abiodun & Sulaiman
Muhammad Jamiu
Abstract
The storm
surrounding the declaration of Shari'ah implementation in northern Nigeria in
the late 1990s inspired Muslim communities in southwestern Nigeria to establish
what became known as the Independent Shari'ah Arbitration Panel (ISAP). The
primary aim of the panel is to adjudicate matters related to Muslim social
issues, with jurisdictional boundaries in line with the principles of Islamic
jurisprudence. Efforts were made to achieve the panel’s proposed objectives;
however, the reality has been different, as the panels have faced numerous
challenges that have hindered the smooth operation of justice for Muslims in
southwestern Nigeria. This paper aims to identify the problems facing the
Independent Shari'ah Arbitration Panel (ISAP) in southwestern Nigeria and
explore potential solutions to overcome these challenges, in order to fulfill
the valuable goals behind the establishment of ISAP in the region.
Key
words: Problems, Prospects, Shari`cah,
Arbitration, Southwest.
Introduction
At its
inception in Yorubaland, Islam introduced Shari'ah law, which later
intermingled with the customary law and practices of its adherents. This
occurred prior to the advent of colonial administration. However, the
colonialists explicitly abolished Islamic jurisprudence in Yorubaland1. After
independence, Muslims in the southwest of Nigeria exerted efforts within their
capacity to ensure that the Federal Government re-established the Shari'ah
Court. However, this significant task faced monumental failure, as the
government viewed the adoption of Shari'ah law as a countermeasure to the
conventional court system. Consequently, disputes related to Muslim personal
matters are now handled in conventional courts, mostly by non-Muslim judges who
lack knowledge of Islamic Shari'ah arbitration. This has led to the issuance of
judgments based on English and customary laws, as reflected in the Nigerian
constitution, rather than in accordance with Shari'ah principles. These legal
anomalies have fostered negative attitudes within the Muslim Ummah, with many
perceiving southwestern Nigeria as being sidelined by the secular system of
governance, in which Shari'ah law holds no significant role in the various
legal systems. This, in turn, has impacted Muslims' social activities and
personal law.
In contrast,
the Muslim Ummah in the northern part of the country, where Shari'ah law exists
alongside English law as outlined in the nation's constitution2,
benefit positively from the adoption of Shari`cah law
as it minimizes avoidable conflicts among the Muslims. The Emirs also adopted
arbitration practices and procedures based on the principles of Islamic law as
contained in the Qur’an, Hadith and other supplementary sources of Islamic law.3.
Although, the judicial power of Shari`cah is
usually administered through Islamic judges called Alkali4.
Efforts were
being made by the southwestern Muslims towards inauguration of
Independent Shari`cah Arbitration pane (ISAP).
Prominent are the 1976 memoranda submitted by various Islamic bodies to the
Constitution Drafting Committee set up by the Murtala Muhammad Military
Administration, calling for the extension of the application of Shari`cah to
the southwestern part of Nigeria.5 In May1984, the League of
Imam and Alfas called for the establishment of Shari`cah courts
in Yorubaland.6 Also on 13th October 1984 at a
day Muslim interdenominational seminar on Shari`cah, the
Organization of Muslim Unity (OMU) mounted pressure on the state government
through the State House of Assembly to establish Shari`cah courts
in southwestern Nigeria7, however, to no avail. The Muslims
therefore has to find other means to resolve their judicial problem through the
establishment of ISAP in the southwestern region of Nigeria. However, efforts
to improve the judicial activities of (ISAP) are been affected by divergent
problems. This study therefore, aimed at analyzing the problems and Prospect of
the Independent Shari`cah Arbitration Panel in
Southwestern Nigeria.
Practices
of Shari`cah law in the Southwestern Nigeria
In the colonial
period, the Yoruba people in the southwestern Nigeria conventionally had their
native systems of governance and judicial methods for dispute resolution, which
were intensely entrenched in the Yoruba’s religious and cultural practices. Thus, Shari`cah law
was not the principal legal system in southwestern Nigeria in the pre-colonial
period. However, denial of Shari`cah law was
privately practice by the Muslims in Yorubaland and not in the
running of the state affairs prior to the advent of the British rule as opined
by Ambali (1998) “Although, there was the marked difference between the
practice of Shari`cah law in the north
and the southwestern which is attributable to the effects of Jihad more than
any other factor, particularly where the rulers were Muslims unacceptable”8. However,
history has it recorded, that Shari`cah law was
practiced and applied as a state constitution in some parts of southwestern
Nigeria prior to colonial administration, particularly in some Muslim
communities and towns like Epe, Lagos State, Ede, Ikirun and Iwo in Osun State. Muslims
in these towns of southwestern Nigeria embraced the Islamic religion with its
judicial dictates, after reaffirming Islamic positive impacts on their social
life filled with justice, fairness and equity. Besides, Shari`cah law
regulated many anomalies which in those days characterises the Yoruba society,
in regards to family law and interpersonal behavior,9 such as
marriage of prohibited women, injustices in the vein of debarring female hairs
from inheritance. Shari`cah legal law were
interpreted and applied by Islamic scholars and local rulers in parts of
southern Nigeria, this system co-existed with traditional practices and
customary law. According to an oral interview with Shaikh Hadyatullah asserted
that Shari`cah legal law has taken place in Iwo
town and there is still the house of Alkali (Qadi) (Islamic judge) in the city
today10. According to Oyeweso, (1999), Oba Habibu Olagunju, the Timi
of Ede was distinguished among the Yoruba Muslim kings, owing to his strife, to
amalgamate the Shari`cah law with indigenous
tradition without interference for the governance of the people of Ede town and
environs11. The Oba Olagunju time in power marked the significant
control of legal law, thorough application of Shari`cah law
in a region where traditional and Islamic practices frequently intersected due
to complexity of the crisis between local customs and religious laws, he
managed the application of Shari`cah law to the
highest level in his period. Oba Habibu Olagunju ‘was reported to be most
likely the first Muslim Oba in Yorubaland.12
Conceptual
Clarification of Alternative Dispute Resolution (ADR) in Islamic Legal Authority
Al-Sulh is an Arabic word
means to reconcile and to make peace with the opponent 13.
Technically, Sulh is derived from the verb saluha or salaha that
is to be sound and righteous.” 14 literally means to cut
off a dispute‟ or to finish a dispute‟ either directly or with the help of a neutral third party.
Arbitration is governed by different regulations;15 In Arabic
philology, the word “Sulh” in the context of interpersonal relationship
is from the generic word “salaha” which means “to make peace, become
reconciled, make up, and reach a compromise or settlement”.16
However, in a
wider sense, the Islamic scholars capture Sulh in deferent
wordings but the meaning is identical. For example, the Hanbali jurist Ibn
Qudamah perceives Sulh as ‘an agreement between two disputed
parties which would lead to peace.’’17 According to the Maliki
School of thought, Sulh is an agreement to end dispute even it
is not yet happen’.18
Problem of
the Independent Shari`cah arbitration panels in
southwestern Nigeria
The problem of
the Independent Shari`cah arbitration panels in
southwestern Nigeria is a complex phenomenon, due to peculiar as well as
specific challenges encounters by the panels owing to the following factors:
Cultural and
Religious Differences
Most adherents
of Islam and Christianity in southwestern Nigeria are culturally structured
despite their professing adherents of the two prostelyzing religions. Some
Muslims and majority of the Christian reveals their negative approach, which
led to tension as soon as Shari`cah arbitration is
introduced in the region. Buttressing this view, Green (2011) said that 92% of
Nigerian Muslims and 87% of Nigerian Christians put religion first before
ethnicity or nationality. 19 This according
to Olatoye and Yekini (2019) suggests that apart from the diverse
tribal and ethnic backgrounds, the multiplicity of customary laws, the common
law and other statutory legislation, religious laws like Islamic law will
strongly compete amongst other potentially applicable laws 20 for
dispute resolution. The application of Shari`cah law
in social; related matters in southwestern Nigeria will be for a long time
controversial among Christians and the African Religion Practitioners, because
both religions view Shari`cah law as alien to their
creed and cultural practices.
Legal pluralism
is a circumstance whereby two or more legal system coexists in the same social
arena. Legal pluralism system in Nigeria comprises of constitutional, customary
as well as Shari`cah laws which are all applicable
in the social activities (marriage divorce child custody) in the northern path
of Nigeria. Legal pluralism in Nigeria always creates mystification,
particularly whenever the citizens search for arbitration under Shari`cah legal law
especially if the disputes on ground also involves the state legal system.
Financial
constrained is another major problem confronting the implementation of
Independent Shari`cah arbitration panel in
southwestern Nigeria as most of the arbitration panel are financially
handicapped to successfully run the panel jurisdiction’s activities as required
particularly payment for the judge’s salary. Other panel staffs like the
registrar, clerks and panel members also maintained themselves with affordable
assistance to the panel to achieve the aims and objectives of inauguration of
the ISAP. Other expenses, which cover the arbitration panel’s record printing
materials, secretarial maintenances, as well as other varied expenses are part
of the financial problem21.
Negative
approach of the Muslims is another bottleneck in the implementation
of ISAP in southwestern Nigeria Most of the Muslims in southwestern Nigeria are
aggressive to the establishment of the Independent Shari`cah Arbitration
Panel owing to the fact that the arbiters and the purveyors belong to the same
Islamic group, and Association with similar creed and tenants. For instance,
the ISAP, Ogbomoso chapter is dominated by the Salafist movement
only, which many Muslims perceived as extremists that affirm their doctrines
while condemning other doctrines of Muslims22. Buttressing
the above assertion, Makinde and Ostien (2011), states that some Muslims in
Lagos state brand ISAP as belonging to the respective Muslim group National
Muslim Youth or Supreme Council for Shari`cah in
Nigeria (SCSN) rather than being acceptable to all Muslims.” 23 Similarly,
the Leagues of Imams and Alfas have actively opposed the establishment of ISAP
in Lagos and Oyo States respectively. Buttressing this statement Makinde and
Ostien (2011) remarks that in Oyo state, the League of Imams and Alfas found it
difficult to accept any crop of people other than themselves to run and
adjudicate in such Shari`cah panels. These Ulamah would
rather sabotage the scheme or have some rivals unsurp their exclusive
traditional rights24
Conventional
courts frequently rule out the verdicts given on Shari`cah basis
by the arbitration panel on social related issues, like ALnikkah (marriageI) talaq (divorce)
and Mirath (inheritance). Some of the issues resolved by ISAP are sometimes
refer to the conventional courts of all grades because the award given by
the Shari`cah panels is unfavorable to their
expectation. Since the verdicts on those issues are given on Shari`cah basis.
The conventional courts do not recognize Shari`cah law
in southwestern Nigeria in all issues for a number of reasons which related to
the secular and legal structure applicable in the Nigeria legal system.
Similarly, few
traditional rulers in southwestern Nigeria oftenly reject the verdict awarded
by the Independent Shari`cah arbitration panel,
while some endorsed the awards given by the panels on social related issues.
This may be attached to the level of their faith in Islamic law values in
resolving disputes among warring parties. In addition, most of the traditional rulers
in southwestern Nigeria, are culturally rooted, which made the rulers to reject
some of the arbitration panel’s award on social activities issues, like Al-nikkah (marriageI) talaq (divorce) Haddana (child
custody) and Mirath (inheritance) that are not compatible with
the customary law jurisdictions. For instance, a case of Abdul Kareem Salami
whose three wives disputed on how their late husband’s properties should be
share to his heirs. The last wife khadijah claimed that she is the only legally
married to Abdul Kareem, although she met the other two co-wives with the
husband, the panel awarded the property to khadijat based on her claimed. The
matter was reported to his Royal Majesty, Oba Jimoh Oladuni Ajagungbade III by
the elder brother of the deceased Ibraheem Salami. Oba Oladunni
set aside the award of the arbitration panel (Ogbomoso chapter) and he
distributed the estate to all the children of the deceased in accordance with
the customary law.. Recently the Oba of
Ado-Ekiti, Oba (Adeyema Adeyinka) ordered the dissolve of the
newly inaugurated ISAP chapter of Ekiti state Ado Ekiti, saying that the
establishment of Shari`cah legal system in Ekiti
state is against the traditional system of dispute resolution.
Opposition of
Non Muslim Organization Generally, the Muslims effort of introduction of Shari`cah law
for the Muslims in Nigeria has been a nagging and unsolvable problem for a
quite numbers of years due to rivalry between adherents of the two major
religion of Islam and Christianity in southwestern Nigeria. Several scholars
hypothesize that Shari`cah law is territorially
limited to the northern part of Nigeria. Buttressing this view, Agbede (1997)
and Kumo (1980) among other scholars assert that Shari`cah law
is not applicable in the southern part of Nigeria26. due to its
territorial limitation to northern Nigeria as assumed by the writers. This
reaffirm the non- chanllant attitude of the non - Muslims Organization to the
establishment of the Independent Shari`cah Arbitration
Panel in southwestern Nigeria. Makinde (2017) asserts that ‘the opposition of
non-Muslims (organization), particularly, the Christians to Shari`cah law
compounds the problem of the establishment of Shari`cah courts
in the southwestern Nigeria. ‘The opposition has been vociferously and
maliciously displayed in their views which were expressed in both the print and
electronic media and during conferences organized to debate the issue of
re-introduction of Shari`cah through ISAP27.
Such hate speech has apparently appears in the word of Dodo (2000) who
suggested that ‘When the 1999 constitution of Nigeria will be reviewed, the
Islamic Shari`cah law should be removed completely
in the subsequent constitution and be observed and practiced in the way
Christians do with the ecclesiastia.28
To further
buttress our assertion on the negative approach of non- Muslim Organization to
establishment of the ISAP in southwestern Nigeria is the recent idea of
establishment of Independent Shari`cah Arbitration
Panel in Oyo town by the Supreme Council for Shari`cah Oyo
town. The idea has been confronted with hostility and war from the Christian
Association of Nigeria Oyo state chapter in Ibadan. The announcement sparked
intense debates on social media and within the state, with critics arguing that
the introduction of a Shari`cah court could disrupt
the state’s religious harmony.29 The Oyo State Chairman of the
Christian Association of Nigeria, Apostle Joshua Akinyemiju, dismissed the
initiative, describing it as unconstitutional and a threat to the state’s
secular nature. According to the Christian leader “This should not happen in
Oyo State, where Christians and Muslims coexist in nearly every family as there
is no law to support this, and the government is not aware. We won’t allow
anything that jeopardizes the peaceful coexistence we enjoy,30” The
Yoruba Council Worldwide (Igbimo Apapo Yoruba Lagbaye ) and the Pan Yoruba
Group, the (Afenifere) all make their derogatory remarks on the establishment
of the ISAP in southwestern Nigeria. The Yoruba Council Worldwide has even
threaten to take legal action against the purveyors of the Oyo chapters
of Shari`cah panel if they refused to abstain from
the initiative of the Shari`cah arbitration panel
in Oyo town. Despite that Shari`cah arbitration
panel subsist in most part of southwestern Nigeria include Ibadan. Ogbomoso,
Kish. Oshogbo Ijebu-Ode, Abeokuta, and it have been recently established in
Ekiti state. Despite that the establishment of ISAP in southwestern Nigeria is
in accordance with the provisions of Arbitration and Reconciliation, recently
amended in 2023, non-Muslims organization are still against the move of its
establishment.
Last but not
least, is the lack of coercive authority. The inability of the Independent
Shari'ah Arbitration Panel (ISAP) to compel respondents to defend the
complaints levied against them, as well as the acceptance of the panel's
awards, represents a significant obstacle to the effective operation of the
ISAP in southwestern Nigeria. While the commencement of proceedings in the ISAP
may seem straightforward, prolonged proceedings often render the panel's
efforts at dispute resolution futile, as many litigants fail to comply with the
awards issued by the ISAP in the majority of disputes adjudicated by the panel.
Prospects to
the problems of ISAP in southwestern Nigeria
1. One of the claims of the Nigerian government in its
constitution is the guarantee of freedom of religion and equal protection of
human rights for all citizens, regardless of religious affiliation. The
Nigerian government's responsibility in this regard is to ensure that the
activities of the Independent Shari'ah Arbitration Panel (ISAP) align with the
constitutional framework and safeguard the constitutional rights of adherents
of other religions in southwestern Nigeria. At the same time, Shari'ah law should
not be imposed on non-Muslims. Its scope should be confined to Muslims in
southwestern Nigeria, where the system is practiced. The demarcation of its
jurisdiction should be clearly defined in social matters, such as marriage,
divorce, inheritance, and family issues, and should never infringe upon the
religious or cultural rights of others.
2. The Independent Shari'ah Panel in Nigeria should play
a vital role in addressing the challenges of legal pluralism by encouraging a
balanced and reasonable approach to both Shari'ah and secular legal systems.
The panel should outline its areas of jurisdiction, such as social matters like
marriage, divorce, inheritance, and contracts. In situations where disputes
require the intervention of both secular and Shari'ah laws, the ISAP should
apply the Sulh (mediation) process to ensure that the outcomes reflect the
values of both the Shari'ah and conventional legal systems.
The financial constraints of the ISAP can
be addressed through the proper restructuring of its financial system,
including the reduction of enforcement program costs. Social welfare
activities, such as Zakat distribution, should be extended to the ISAP to meet
its financial needs. Additionally, the wealthy members of the Muslim community
should be consulted to extend their philanthropic activities to the ISAP, and
external aid could also be beneficial if used judiciously to sustain the
judicial administration of the ISAP.
Muslim communities should be consistently
and adequately oriented through seminars, lectures, sermons, and other forms of
social media about the application of Shari'ah legal principles in their daily
lives. They should view its application as a mandate, with non-compliance
resulting in eternal damnation. The Islamic scholars in southwestern Nigeria
who perceive their authority as being undermined by the ISAP should be
adequately consulted and enlightened about the benefits of the panel's judicial
activities for both Muslims and the community at large. In this way, Islamic
scholars will affirm their recognition of the ISAP and acknowledge that they
have a say in the panel's judicial activities.
Traditional rulers, in respect of their
religion, should be included in the proceedings and decision-making process of
the panel’s awards, as well as in discussions about the application of Shari'ah
principles in dispute resolution within the Muslim community. This will promote
a sense of partnership and trust in the minds of traditional rulers toward the
panel. The traditional rulers should be adequately oriented about the ISAP’s
focus on religious and moral guidance, ensuring that it does not undermine their
political authority, which is contrary to Allah's dictates. Additionally, the
arbitration panels should frequently consult traditional rulers on vital issues
that may intersect with their authority, reaffirming that the ISAP values their
insight.
One structural solution to the problem of
the lack of coercive authority for the Independent Shari'ah Arbitration Panel
in southwestern Nigeria is the enforcement of the awards given by the panel to
disputants through legal recognition of the ISAP's judicial activities within
the Nigerian legal system. This can be implemented by integrating the Shari'ah
panel, with defined jurisdictional boundaries, into the Nigerian conventional
legal system. The awards of these panels in dispute resolution can be supported
by the coercive power of the southwestern state governments, though this may
prove difficult. The panel can also collaborate with secular courts to provide
the necessary legal backing to ensure compliance with the arbitration awards
issued by the panels.
Non-Muslim organizations, such as the
Christian Association of Nigeria (CAN) and the Pan-Yoruba groups, including
Afenifere and the Yoruba Council Worldwide (Igbimo Apapo Yoruba Lagbaye), who
oppose the establishment of the Independent Shari'ah Arbitration Panel in
southwestern Nigeria, are acting unconstitutionally. Their opposition
constitutes discrimination against the fundamental rights of Muslims, as
outlined in Article 42(1) of the Nigerian Constitution, which states: "A
citizen of Nigeria, of a particular community, ethnic group, place of origin,
sex, religion, or political opinion, shall not, by reason only that he is such
an individual, be subjected to any disability or restriction which citizens of
Nigeria of other communities, ethnic groups, places of origin, sex, religion,
or political opinions are not subject to.31
A second
constitutional argument is found on the right to freedom of thought,
conscience, and religion as stipulated in Article 38 (1) of the Nigeria
constitution quoted in part that:
‘Every person
shall be entitled to freedom of thought, conscience and religion, including
freedom to manifest and propagate his religion or belief in worship, teaching,
practice and observance’32. The constitution is applicable to
private and public sectors in the Nigeria communities. Likewise, section 277(1)
(2) (a) (b) (c) (d) and (e) of the 1999 of Nigeria constitution has stipulate
what Islamic personal law implies ‘the law of the family and that of
inheritance. 33 in addition section 7(II) gives the
court’s jurisdiction over “civil proceedings in Islamic law in which the
existence or extent [of] a legal right, power, duty, liability, privilege,
interest, obligation or claim due to an individual or individuals is in
issue.” 34 Therefore, southwestern Muslims of Nigeria have
the constitutional right, of litigating their social disputes under Shari`cah legal
law at least in their private affairs, including marriage, divorce inheritance
and child custody among others.
Conclusion
This work
highlights the challenges and prospects of the Independent Shari'ah Arbitration
Panel (ISAP) in southwestern Nigeria. Despite the opportunities available to
Muslims to institutionalize private Islamic arbitration panels following
prolonged efforts, the problems outlined above continue to hinder the smooth
operation of these panels in southwestern Nigeria and urgently need to be
addressed. Among these issues, the most concerning is the apparent lack of
interest displayed by Muslims in the panel’s judicial activities, as evidenced
by the negative attitudes toward the panel. Additionally, the southwestern
Nigerian governments and traditional rulers also exhibit a lack of interest in
the establishment of the panel, driven by political considerations, which
consequently impacts the Muslims' judicial rights.
However, the
southwestern Muslim community cannot be solely held responsible for the
underperformance of certain ISAP chapters in the region, as the aforementioned
problems hinder the achievement of the panel's goals. The pioneers responsible
for the panels must also shoulder some of the blame for the misconduct of
certain panel members. The attitudes of all parties involved suggest that the
Muslims’ advocacy for Shari'ah jurisdiction in southwestern Nigeria is largely
symbolic. Only time will determine the future viability of the Independent
Shari'ah Arbitration Panel in some parts of southwestern Nigeria.
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