OF CONTEMPT OF PARLIAMENT, IN PARLIAMENT, BY PARLIAMENTARIANS AND MATTERS ARISING – THE DISHONOURABLE AND CHAOTIC CONDUCTS BY SOME HONOURABLES OF GHANA POLITICS, WHEN LAW MAKERS BECOME LAW BREAKERS!

….. But before we ask for our pound of flesh, Respect is earned, how we behave or misbehave will determine how the people will behave or misbehave towards us.”[1] Alban Bagbin, 29^th January 2025.

INTRODUCTION

In the time of Socrates[2] in Athens, Greece, citizens could gather at the city center to discuss and take decisions on matters affecting their life.[3] The population and situations at the time permitted such gatherings, making it possible to engage in direct decision making. However, as time went on, and the population increased, it became practically impossible to continue this practice. Consequently, the need arose for people to be elected to represent others in the law making and decision-making forum. It would seem to be a great honour therefore to be elected out of the lot to represent others.

In the Author’s view, being elected to represent others implies that such a representative has been chosen and sent with a purpose, including bringing honour to the people who elected them. Therefore, it is expected that individuals whose constituents have honoured by electing them to Parliament or any other fora would at all times conduct themselves in a manner that brings honour and dignity to their names and constituencies.

Unfortunately, this expectation has not always been met in the Parliament of the Republic of Ghana. On Thursday, January 30, 2025, there was another embarrassing situation in the Parliament of Ghana, particularly in the Appointments Committee, bringing shame, dishonour, disgrace and disrespect to the Honourable Members of Parliament[4] and the nation at large.[5]

A similar scene had occurred during the inauguration of the 8^th Parliament in the election of the Speaker of Parliament in 2021[6] as well as during discussions concerning the admission of the Member of Parliament elect at the time[7] for Assin North.[8] Later in the life of the same 8^th Parliament, in the events leading to the passage of the controversial Electronic Levy Act, there was a similar incident in the august house involving the Honourable Members of Parliament.[9]

The events of 30^th January 2025 happened just some days after a Lawyer and Civil Rights Activist, Oliver Barker Vormawor had been summoned to Parliament before the Appointments Committee for a comment he was alleged to have made on his Facebook wall in relation to a bribery allegation[10] concerning the Appointments Committee of Parliament. Some of the Honourable Members of Parliament took the view that the comments were in contempt of Parliament. In another incident, a senior lawyer and Acting Chief Executive Officer of the Petroleum Commission, Emeafa[11] Hardcastle, had an encounter with Honourable Frank Annoh-Dompreh[12], who subsequently reported the incident to the Speaker of Parliament on the floor of Parliament[13]. The Speaker of Parliament had at the time announced his plans to summon her to appear before the House.[14] The Honourable Haruna Iddrisu[15] for instance called on her to apologise to the Honourable Frank Annoh-Dompreh.[16] The chaotic and dishonourable conducts arose because of the decision of Minority caucus on the Appointments Committee not to continue the vetting for that day. Instead of walking out, they disrupted proceedings as a sign of protest.

In response, the Speaker of Parliament suspended some four members of Parliament[17] who were captured on video engaging in dishonourable conducts. On the 3^rd day of February 2025, the Speaker of Parliament rescinded the suspension[18] after the members of Parliament through their leaders apologized[19] for the unparliamentary conduct. Prior to this, some people had suggested that the four affected members of Parliament could sue the Speaker of Parliament.[20] Nonetheless, a committee has been established to investigate the unfortunate events and report to Parliament.

In this paper, the Author examines the subject of Contempt of Parliament, attempts to answer the question whether Contempt of Parliament is applicable to only non-members of Parliament, (i.e. whether members of Parliament can themselves be in contempt of Parliament), whether or not the Speaker of Parliament has the power to suspend erring members of Parliament who misconduct themselves in the manner they did and bring dishonour and shame to the otherwise respected House of Representatives, and whether the correct procedure was used by the Speaker of Parliament in so acting. The Author will also take the liberty to comment on some events in and from the Parliament in the early days of the 9^th Parliament of the 4^th Republic. The Author does so, not just as a lawyer, but as a citizen of the Republic of Ghana, a student of Political Science, a believer in the institution of Parliament as an important part of our democracy and in the exercise of his fundamental rights and freedom of expression[21] which rights are innate and constitutionally guaranteed, and hopes that he does not fall into the trap of contempt of Parliament in this enterprise.

What is Contempt of Parliament

People are familiar with contempt of Court. The Court of law is the place for the adjudication of disputes and administration of justice, as such respect must be accorded to its sanctity. Anything done by any person that stands in the way of justice, is contempt of Court. The respected former Supreme Court Jurist, Justice Stephen Alan Brobbey, in his book,[22] says that “…. in its simplest sense, contempt of court means any conduct that interferes with or undermines the administration of justice.” In the locus classicus case of Republic v Moffat and Others, Ex Parte Allotey[23], the court explained that, “any conduct which tends to bring the authority and administration of the law into disrespect or to interfere with any pending litigation is contempt of court…”

By this analogy therefore, the Author suggests that any conduct that seems to bring the image of Parliament or the work of Parliament into disrepute may amount to contempt of Parliament. According to Erskine May[24], “Generally speaking, any conduct or omission which obstructs or impedes either the House of Parliament in the performance of its function, or which obstructs or impedes any Member or officer of such House in the discharge of his duty, or which has the tendency, directly or indirectly, to produce such results, may be treated as contempt even though there is no precedent of the offence.” The Parliament Act[25] in section 26 provides that, “An act which impedes or tends to impede Parliament in the performance of its functions, or affronts the dignity of Parliament, is contempt of Parliament…”. Section 27(1) provides that, “It is contempt of Parliament (a) for a person to assault, obstruct, molest or insult the Speaker or a Member while that person is within the precincts of Parliament or is on the way to or returning from the proceedings of Parliament. Section 27 (2) provides that it is contempt of Parliament (a) for a person to endeavour, by means of bribery, fraud or the infliction or threatened infliction of violence, restraint or spiritual or temporal injury, to influence a Member in the performance of function……(c) for a Member to accept, or procure for personal gain or for any other person, a benefit in return for undertaking to perform any of the function of the Member in a particular manner or by reason of anything done or omitted to be done by the Member in the performance of functions.” The above sections provide some scope of what goes into contempt of Parliament. It is also contempt of Parliament to interrupt with the proceedings, for a stranger to sit or vote. It is contempt for a member to persistently obstruct the proceedings of Parliament, whether or not in contravention of the Standing Orders.[26] The scope of contempt of Parliament from the Act 300 seems wide and includes false or incomplete evidence,[27] disobedience by witnesses[28]. Disobedience by members,[29] disobedience by strangers, including for a stranger to enter or remain within the precincts of Parliament in disobedience of an order or for a stranger to behave within the precincts of Parliament otherwise than in accordance with the Standing Orders[30]. The above provides the statutory scope of Contempt of Parliament. The Standing Orders also provides that, “An act or omission which (a) obstructs or impedes Parliament in the performance of the functions of Parliament; (b)obstructs or impedes the Speaker, a Member or an officer of Parliament in the discharge of the duty of the Speaker, the Member or the officer, (c) affronts the dignity of Parliament; or (d) tends either directly or indirectly to produce a result referred to in paragraph (a)(b)(c) is contempt of Parliament”[31]. Aside from these, the Standing Orders also provide other specific acts that constitute contempt of Parliament or breach of parliamentary privilege. These acts include without limitation , disorder on the part of a stranger such as riotous or disorderly action to hinder or promote the passing of a Bill or other legislative measure or Motion or any other matter pending before the House or a Committee of Parliament,[32] insulting behaviours on the part of a witness who appears before the House of a Committee of Parliament;[33] presenting to Parliament or a Committee of Parliament frivolous, false, scandalous, groundless or fabricated documents or similar allegations in an petition;[34] any act or conduct calculated or intended to deceive Parliament or a Committee of Parliament;[35] misconduct, fraud, dishonesty or moral turpitude in the execution of official duties by a Member, the Clerk or an officer of Parliament;[36] causing or effecting the arrest of the Speaker, a Member, the Clerk or an officer of Parliament during the proceedings of Parliament or in the course of the official duties of that person;[37] molestation or intimidation of the Speaker, a Member, the Clerk or an officer of Parliament in connection with the performance of their duties. There are other incidents in the various laws and Standing Orders that amount to contempt of Parliament. The Author agrees with Erskine May, when it says in Chapter 8 thereof among others that, it is impossible to list every act which might be considered to amount to contempt, but the power to punish for such an offence being of its nature discretionary….

Can Members of Parliament commit Contempt of Parliament?

Article 122 of the 1992 Constitution provides that, “An act or omission which obstructs or impedes Parliament in the performance of its functions, or which obstructs a member or officer of Parliament in the discharge of his duties or affronts the dignity of Parliament or which tends either directly or indirectly to produce that result, is contempt of Parliament.” The scope of contempt of Parliament, from the Constitution, Parliament Act and Standing Orders give an indication that the issues that constitute contempt is broader than limited.

The laws that provide for contempt of Parliament[38] in the view of the Author, is not person specific. As long as the act or omission of the person brings the image of Parliament into disrepute and diminishes the dignity of Parliament, or any conduct that falls within the scope of Article 122, that is contempt. The Author takes the view that, contempt of Parliament therefore is not only applicable to non-members of Parliament, but bona fide members of Parliament alike. Contempt can be committed by strangers, visitors and even members of Parliament. In fact, there have been previous instances where sitting Members of Parliament have been so summoned. The Honourable Ken Agyapong, was cited for contempt of Parliament and was reprimanded upon being found guilty.[39]

Although the 1992 Constitution provides immunity for members of Parliament, when a member of Parliament is charged with contempt of Parliament, the person is unable to raise the issue of immunity as a defence. Article 115 of the 1992 Constitution provides that, “There shall be freedom of speech, debate and proceedings in Parliament and that freedom shall not be impeached or questioned in any court or place out of Parliament.” the Author submits that this privilege or immunity is limited to speeches and debates on the floor of Parliament and does not extend to other conducts which are offensive to law. Immunity under Article 115 is so provided to ensure that members of Parliament contribute to debates without having any fear of personal liability. However, it is submitted that if the conduct being deemed to be contempt of Parliament goes beyond speeches and debates, Article 115 cannot avail such a member of Parliament. Such a member cannot even raise Article 115 for an offence committed in Parliament that does not arise from a speech or debate, implying that a member of Parliament can be charged with a criminal offence, for instance destruction or damaging public property under Section 172 of the Criminal Offences Act 1960, Act 29. A member of Parliament can be charged and prosecuted for any offence committed, be it rape[40], defilement[41], stealing[42], defrauding by false pretence[43] among others and such a member cannot raise Article 115 as a defence, not even Article 116.

Oliver Barker Vormawor and Emeafa Hardcastle’s sin against the ‘Honourables’

That week[44] had been full of activities involving two people who are coincidentally lawyers. Oliver Barker Vormawor was alleged to have made two statements that were seen to be in contempt of Parliament. The said comments and the debate that arose from same delayed the vetting for some minutes, but in the end, he was invited to face the committee. He was ably represented by a seasoned lawyer of enormous respect and experience at the Bar, Nana Ato Dadzie[45]. He denied one of the posts, admitted the other and apologized for same if his point were misconstrued by the Honourables. In the Author’s humble view, the statement that was admitted and sought to apologize for was open to several interpretations and that formed the basis of the attempted justification. The author of that post, having apologized for it or for how the statement was construed, the Author does not intend to spend any further ink on that subject. The Author, however, takes the view that Parliament or the Committee of same is not a ‘mercy chamber’ where people are expected to automatically apologise once summoned as was portrayed. A person must be heard in defence of himself as happens in any other forum, and an impression ought not to be created as if the people are accountable to their representatives and therefore must exact apology from them at all costs. The Author notes the way and manner the learned Nana Ato Dadzie was handled in the discharge of his professional duty before the Appointment Committee left much to be desired. One’s years at the Bar and seniority is one treasured in the practice of law and would sound preposterous the manner Counsel for the invitee was treated in the manner that was witnessed.[46] A lawyer’s duty to his or her client at all times among others is to ensure that he or she does not make statements that are self-incriminating or prejudicial to his or her interest and his or her rights are protected, and in that line of duty, no one, no matter how self-important that person feels, should be seen to be putting impediments in the way of Counsel in his professional duty. The people’s representatives, the Author suggests, should not suddenly feel overly important and seemingly untouchable since there is no known automaticity in that regard. The Author celebrates the learned Nana Ato Dadzie for the professional maturity he demonstrated at the Committee hearing made up of members of Parliament, some of whom come nowhere near the respected statesman and lawyer, in age and experience in politics and at the bar, as the case may be.

In the Emeafa Hardcastle encounter, the Honourable Frank Annoh-Dompreh[47] alleges that, Lawyer Emeafa had disrespected him by allegedly made the reference ‘Silly child’ to his person. From the footage in the public domain, as a result of the social media comment allegedly made by Oliver Barker Vormawor, the members of the Appointments Committee were not agreeable on whether to vet Honourable Omane Boamah or not until that issue is resolved. During the controversy, it seems Emeafa Hardcastle, and other invited guests urged the members of the Appointments Committee who had left the conference room to go and sit down and vet the nominee, because people had been in Parliament for a long time, to which Honourable Frank Annoh-Dompreh responded that they won’t vet them. Then, Emeafa responded that “what can you do, with your micro minority…” It is the use of the word micro minority that raised tempers. People had sought to argue that the NPP side is a micro minority because of their numbers as compared to the NDC caucus with over 183 members. It seems the adjective micro used by some to qualify the nature of the current minority NPP caucus in parliament is one that the minority would not want to hear. This is despite the fact that the minority themselves refer to the majority as having a super majority and one wonders why reference to the minority as micro or mini minority should spark controversy. At least now the minority have settled on the adjective Mighty Minority or Mighty few, whatever that means to which the Author shall return. It remains to be seen whether with subsequent events, the Honourables will still have the courage of conviction to summon Emeafa Hardcastle as previously contemplated.

In the Author’s view, real might is not a function of what one says, but a function of what one does. It is rather people who must ascribe that adjective to the minority, as to whether they are mighty or weak. It is rather unusual that the minority refers to themselves as mighty minority when in fact by their numbers, Parliament can conduct a lot of government business without them. The minority calling themselves mighty minority is akin to a person erecting a statue in honour of himself or a person who gives himself an award or accolades for good service. The believers of the Bible are familiar with a passage in the Bible that says, “Let another man praise you, and not your own mouth. A stranger, and not your own lips.”[48] There has in the Author’s view been powerful minority caucus in Ghana’s Parliament before and the Author notes for instance the NPP minority in the 2^nd Parliament of the 4^th Republic which at the time was led by the venerable J.H. Mensah and some stalwarts like Nana Addo Danquah Akufo Addo (as he then was[49]), Hackman Owusu Agyeman, Papa Owusu Ankomah, J.H. Owusu Acheampong, Kwamena Bartels, Gladys Asmah, Christine Churcher, Hawa Ogede Yakubu, Kwadwo Baah Wiredu, Courage Quashigah, S.K Boafo, Richard Anane, Kofi Konadu Apraku etc. These men and women (some of whom have departed to the other world ahead) did not label themselves with accolades, but Ghanaians saw their worth and their names are written in history. To such, it is worthy to sing the hymn authored by William George Tarrant “Praise we the wise and brave and strong, who graced their generation, Who helped the right and fought the wrong and made our folk a nation.”[50]

Chaos at Appointments Committee

People have had cause to question whether the alleged comment by Lawyer Emeafa Hardcastle if so made was justified[51] following some subsequent events that have occurred in and outside the august house of Parliament.[52] In the event of 30^th January 2025, the Honourable Minority Chief whip is seen on video among other Members of Parliament, ordering people to lift the table and putting chairs on a table in a manner that is coterminous to little school children expressing their displeasure about an unhappy situation in school, a conduct that in the Author’s view is unparliamentary to say the least. One member of Parliament,[53] has explained that the disruption was a strategic move by the Minority to ensure thorough scrutiny of ministerial nominees,[54] which in itself is worrying because if this is what Parliament has been reduced to, then one wonders what is ahead of the country in this 9^th Parliament. As if that was not enough, the Minority Leader on that same 30^th day of January 2025, in an abusive manner, verbally descended on the Clerk to the Appointment Committee[55] with all manner of allegations against her in the conduct of her work.[56] The good thing is that an apology has been rendered to her by the Minority leader.[57] To add more insults to injury, the Minority Chief Whip and the ‘victim’ in the Emeafa Hardcastle encounter was on 6^th February 2025 heard on radio making certain remarks, that in the Author’s respectful view and that of many Ghanaians, was unbecoming of an Honourable Member of the august house of Parliament. Commenting on the matter of the Ablekuma North Parliamentary election, this is what he had to say when he had the opportunity to share what he had in his mind on 6^th February 2025, “…if you go and meet an NPP person and an NDC person fighting, help the NPP person to beat the NDC person, and let’s beat him well. If the NDC led by Mahama Ayariga, will not be reasonable and understand that Ablekuma North, based on all the evidence available we have won and make up their mind to bring hooliganism, they will continue, they are not going to allow the EC to collate, they will never have peace in Parliament… If the IGP has made up his mind to look on and allow these people to do foolish things and misbehave, we will continue to demonstrate. Me too, I like demonstration and it’s been a while since I went on a demonstration….”[58] Such comments on a platform are unbecoming of a person of that stature, not honourable to emanate from the mouth of an otherwise Honourable Member of Parliament. Not only is the comment not honourable, but it seeks to ignite the passion of others and has the tendency for leading people to commit violence. It was not surprising that some people called on the security agencies to cause his arrest.[59]

Usually, some of the Honourable Politicians justify such comments with the excuse that they are politicians and were on the political platform and were charged, by whatever spirit remains unknown, save that the Author recalls the learned Ayikoi Otoo[60] once acting as counsel for the late Kwadwo Owusu Afriyie popularly called Sir John, in the Supreme Court called it gbeshie[61]. The Author suggests that, being on a political platform is not a justification to utter reckless statements, neither does a political platform offer politicians the opportunity to make irresponsible statements with the hope of escaping the consequences, but rather an opportunity to share quality ideas and refined thoughts of how one wants to address the challenges and problems that confront the society they seek the power to lead.

Allegations against the Honourable Members of Parliament.

This is not the first-time allegations in this nature has been made against the members of the august house of Parliament. Parliament as a house has suffered many bribery allegations even as recent as the 8^th Parliament, but just like adultery, which is difficult to prove, one can hardly prove bribery in these circumstances even if there is any such. Some members of Parliament have been involved in one such controversy or another, but there has always been the difficulty of proving same. In his book, The President Ghana Never had, the respected journalist, Manasseh Azure Awuni recounts, in Chapter 25 captioned ‘The Cash from Jubilee House to Parliament’, instances that leave no one in doubt that the phenomenon is not alien to the Parliament of Ghana. He narrates at page 241 for instance thus, “Some MPs however told me in separate interviews that bribery and cash inducements were a common feature of Ghana’s Parliament. They said nominees for vetting often came with cash, sometimes through businessmen or the nominee’s associates. The payment, they said, was meant to “soften the ground”, especially when the nominee had controversies that were expected to draw swords”. The Ghanaian Akan adage is trite, ‘(ensuo ret), n’anso ef3my3 den)’ to wit, ‘it is raining, but the ground is dry’, hence softening the grounds become imperative to some Honourables. He continues thus, “A former MP said cash inducement in Parliament was so rampant that state institutions and individuals appearing before any committee of Parliament were expected to pay the committee members. He said the Public Accounts Committee of Parliament, which demands answers from public officials and institutions involved in infractions captured in the Auditor-General’s report, was not excluded from the payments made by people appearing before committee. In 2014, the current Speaker of Parliament, Alban Sumana Bagbin, said some MPs took bribes to articulate the interests of individuals, and organisations on the floor of Parliament.” To the Author’s mind, if these comments are true then same are alarming and unbecoming of people supposed to be Honourables. In 2022 when some NPP members of Parliament agitated for the removal of the then Finance Minister, Ken Ofori Atta, it emerged that a businessman went to Parliament with a bag of cash to bribe the MPs to back down.[62] Again, Manasseh narrates that, “During the vetting of ministers in Akufo-Addo’s first term, the NDC minority alleged an attempt to bribe them to pass the President’s nominee for the Ministry of Energy, Boakye Agyarko. Mr. Agyarko had passed disparaging remarks about former President John Mahama and called him corrupt. The NDC MPs on the Appointment Committee were poised to exact their pound of flesh when it emerged that cash had been brought to the committee in the name of Boakye Agarko.” At page 242, he states, “Beyond allegations of extortion by parliamentary committee, some individual MPs allegedly indulge in illegal schemes to make money. The immediate past Minority Chief Whip, Mohammed Mubarak Muntaka, said the desire for money had driven some MPs into illicit activities. He recounted a complaint he had received about an MP (now out of Parliament) who had always pestered the Director of the Passport Office to print passports for his constituents. The MP was later found to be extorting money from people and helping them acquire passports. He added that most embassies had also lost trust in Ghanaian MPs because some MPs engaged in criminal activities such as visa racketeering” … You cannot have up to 100 members of the 275 MPs who want to do the work of Parliament. People come [to Parliament as MPs], and all they want to do is to look for money” Muntaka said. He blamed the worsening situation on excessive demands on MPs and the practice that has made money the main success factor for being elected as an MP.” The Honourable Muntaka goes ahead to sound a caution, which the Author shares, “If we don’t take care, drug barons and businesspeople will soon take over Parliament….” Manasseh further records in his celebrated book at page 242-243 thus, “Regarding Mahama Ayariga and some NDC MPs’ allegation that the Appointments Committee had received money from Boakye Agyarko, Muntaka maintained the position he held when the allegation first came up in 2017. He said it was untrue and added neither he nor Joseph Osei-Owusu had met Boakye Agarko before the allegation. He insisted that no such cash had come from Boakye Agyarko to him”…. Muntaka however mentioned that the only cash that came to the Appointments Committee was from the Jubilee House, the Office of the President. When I asked who had sent the money, and what it was meant for, Muntaka said it had been a longstanding practice that during the vetting of ministerial nominee, the Chief of Staff would periodically send money to the members of the Appointments Committee. That cash usually come at the end of the week, and the members of the Appointments Committee shared it. He said the practice did not begin with the Akufo-Addo administration. In the past, individual nominees came to the vetting committee with cash for members. However, not all nominees could afford the payment, so it became a practice since the Atta Mills presidency in 2009 that the Office of the President would give the money to cover the nominees. He would not disclose how much the presidency usually sent.” The above narrations show that, these bribery allegations are not new in Ghanaian politics, neither are Ghanaians not unfamiliar with such allegations.

It was one such allegation that caused the ‘Honourables’ to invite a citizen who had made some comments to appear before them. Much as the Author believes that people must not make statements about others’ reputation without basis, it is also fair to suggest that public officers must be slow to feel offended by virtue of the nature of the position they assume. In one of the hilarious sayings of the famous El Lizato[63], he cited the quotation by Wisdom Sticker with which the Author agrees, that, “If you are easily offended you are easily manipulated.”

Contempt of Parliament verses Freedom of Speech

The members of Parliament are elected by their constituents and paid for by the taxpayers whom they represent. In essence, the members of Parliament exercise powers on behalf of their constituents and ought to be answerable to the constituents. It seems to the Author that the frequent activation of the powers of contempt against the citizens for expressing their views does not only have the potency to gag the citizens, but tantamount to the situation, where the servant is calling his or her employer to render account to him rather than the opposite.

Freedom of speech is guaranteed by the 1992 Constitution. It should therefore not be seen that Parliament invokes its powers of contempt on any public comment made by citizens in the public square. One wonders if Parliament proceeds in this manner, whether it will have time to do parliamentary business.

Power of the Speaker of Parliament

Commentators have sought to challenge the basis of the Statement by the Rt. Honourable Speaker by suspending some four Members of Parliament. While the Author believes the statement and step taken by the Speaker of Parliament is essential and imperative at the time. To answer the question whether the Speaker had the powers to suspend the four Parliamentarians, there is the need to review some provisions in the law.

Order 20 of the Standing Orders of Parliament provides that, (1) The Speaker of Parliament is the head of the institution of Parliament and presides over the sittings of Parliament. Subsection 4 provides that, “The Speaker shall (a) uphold the honour, dignity and sanctity of the House”. This provision confers on the Speaker the duty to maintain the honour and dignity of Parliament, in doing so, he or she must be fair, impartial[64] and must act in accordance with law. The law provides for how the Speaker may deal with issues such as contempt. Upon a compliant being filed, “The Speaker may direct that a complaint made of a contempt of Parliament or breach of parliamentary privilege be referred to the Committee of Privileges and Immunities[65]”. It is further provided that, “Despite anything contained in these Orders, the Speaker may refer any matter of privilege to the Committee of Privileges and Immunities for examination, investigation and report”.[66] By these provisions, before a referral is made as to contempt, there must be a Committee of Privileges and Immunities in place to refer such a member to, whether there is a complaint or the Speaker acts suo motu. Order 35 of the Standing Orders, however, gives the Speaker some power to momentarily suspend a member whose conduct in the view of the Speaker or person presiding is grossly disorderly. It provides that, “Where in the opinion of the person presiding over the House or a Committee, the conduct of a Member is grossly disorderly, the person presiding may order the Member to withdraw from the precincts of Parliament and that Member shall immediately leave the precincts and shall not enter the precincts against during the remainder of the day’s sitting.” This same provision finds expression in the Parliament Act.[67] The Speaker may reprimand the person found liable for contempt,[68] or the person may be suspended for a period not more than nine months.[69]

Under the Parliament Act[70], section 26 provides that, “An act which impedes or tends to impede Parliament in the performance of its functions, or affronts the dignity of Parliament, is a contempt of Parliament, and the setting forth in this Act of particular contempt shall not be taken to affect the generality of this section.”

Section 36 deals with Suspension of Member in contempt and provides that, “(1) Where a Member is found by Parliament to be guilty of contempt of Parliament, Parliament may suspend the member from the service of Parliament for a period not exceeding nine months, whether or not that period extends beyond the end of the session. (2) Where a Member is suspended from the service of Parliament, the Member (a) shall forthwith leave the precincts of Parliament and shall not enter them again while the suspension continues; (b) shall forfeit the allowances to which the Member would otherwise be entitled as a Member in respect of the period in suspension; (c) if intitled to a salary and allowances as a Minister or as a Deputy Speaker there shall be deducted therefrom an amount equal to the amount which would be forfeited by the Member under paragraph (b) of this subsection if that person were not so entitled;

Under section 37(1) “Where a Member is found by Parliament to have been guilty of conduct which, whether or not it amounts to contempt of Parliament, is so grossly improper as to indicate that the Member is unfit to remain a Member, the Member may be expelled from Parliament.” (2) A resolution for the expulsion of a Member under subsection (1) shall be on no effect unless (a) at least seven days’ notice that it was to be moved was given in the manner required by Standing Orders for the giving of notices of motions, and (b) it is supported by votes of at least two-thirds of the total number of Member.

The Standing Orders of Parliament also offers some basis for which the Speaker can act to ensure that the dignity, honour and sanctity of Parliament is not compromised either by strangers or by the members of the august house. Rules 20 provides for the general function of the Speaker. Under (20)(1) The Speaker of Parliament is the head of the institutions and presides over the sittings of Parliament. (2) The Speaker shall certify by signature financial Bills passed by Parliament for assent by the President. (3) The Speaker is (a) the official spokesperson of Parliament; (b) the principal liaison between Parliament, the Executive, Judiciary, Council of State and the National House of Chiefs; and (c)the president of the local chapter of every international parliamentary association of which the Republic of Ghana is a member. It provides further that, (4) The Speaker shall (a) uphold the honour, dignity and sanctity of the House; (b) promote consensus on matters under consideration in the House; (c)be impartial, fair and firm in every matter in the performance of functions of the Speaker in these Orders; (d) protect and preserve the rights of Members; (e) ensure the provision of reasonable facilities to Members of Parliament; and (e) perform ceremonial opening of Parliament at the commencement of a Session of the House and give the valedictory address at the final Sitting of the House before the dissolution of the House.”

Punishments for Contempt of Parliament

It was said by Honourable Johnson Asiedu Nketia aka (General Mosquitoe)[71] that, a law without punishment is an advice. It implies that laws must be accompanied by sanctions upon breach. The Constitution of Ghana 1992 provides among others that, “A person shall not be charged with or held to be guilty of a criminal offence which is founded on an act or omission that did not at the time it took place constitute an offence[72]” This implies that before one considers punishing a person for a crime, the act against which the person is sought to be punished must have been an offence at the time of the conduct, and not subsequently so. The Constitution provides further that, “No person shall be convicted of a criminal offence unless the offence is defined and the penalty for it is prescribed by a written law[73]”

The law provides various forms of punishments that can be meted out to one found guilty of contempt and could include, exclusion of a disorderly member from proceedings for the remainder of the day,[74] reprimand of a member in contempt by the Speaker,[75] suspension of the member in contempt for a period not exceeding nine months[76] during which periods the suspended member may also forfeit allowances he would have otherwise been entitled. When the person found guilty of contempt is a stranger, Parliament may order him or her not to enter the precincts of Parliament for a period not exceeding nine months. According to the law, such a member shall forthwith leave the precincts of Parliament and not enter again while the suspension continues,[77] he or she shall forfeit allowances to which he or she would otherwise have been entitled as a member in the period of suspension[78] and if he or she is entitled to a salary and allowance as a Minister or Deputy Speaker, there shall be deducted from that amount an amount equal to the one which would be forfeited by the member under section 36(2)(b). The Author suggests in this regard that, if the member is a Minister or Deputy Speaker, his or her entitlement as a Minister or Deputy Speaker must be affected because he or she may have occupied that position because he or she is a member. Under Section 41, when a stranger is found by parliament to be guilty of contempt, parliament may order the stranger to appear at the bar of Parliament to be reprimanded by the Speaker.

Section 43 of Act 300 which provides for criminal prosecution is to the effect that, “A stranger who is guilty of contempt of Parliament is liable to a fine not exceeding two hundred and fifty penalty units[79] or a term of imprisonment for one year or both the fine and the imprisonment”[80] It is unclear from the Act whether the imposition of the fine of penalty units is done by Parliament itself or by a Court of competent jurisdiction in the judiciary in whom final judicial power is vested[81].

Can Parliament order the Attorney-General to prosecute for contempt of Parliament?

Section 43(3) provides that, Subject to article 88 of the Constitution, Parliament may order the Attorney General to prosecute a person whom it suspects to have committed a contempt of Parliament which constitutes an offence under this section or any other enactment. It is the Author’s view that the constitutional right and duty of the Attorney-General to prosecute is unfettered and not subject to the direction or orders of any person. Therein lies, in the Author’s humble opinion a constitutional challenge. In the Author’s view, that the Attorney-General in the exercise or discharge of its constitutional mandate under Article 88 of the Constitution is not subject to the direction, instructions or orders of any person and any attempt by any law, inferior to the Constitution is unconstitutional and may amount to a backdoor amendment to an entrenched provision of the 1992 Constitution. The Attorney-General cannot be ordered to prosecute anyone under the law, since the discretion to prosecute is in the absolute remit of the person occupying that office. In the Author’s view, under section 43(3) Parliament can only lodge a complaint with the Attorney-General for possible prosecution according to his discretion which discretion must be exercised in accordance with law.

Attempts to belittle the potency of the SOP as a non-Member of Parliament

It is not for nothing that the Constitution provides that the Speaker of Parliament must not be a member of Parliament. When the Speaker takes certain steps, some people are quick to raise the issue about the Speaker of Parliament not being a Member of Parliament. The Author believes that it is because the Speaker is expected to be above partisanship and be able to rise above partisan interests to remain impartial and be able to instill discipline in the house. In the Author’s view, the Speaker of Parliament not being a member of the House raises him above impartiality to be able to oversee the affairs of the house and in this context to apply sanctions and bring sanity when members decide to go wayward like happened on 30^th January 2025.

External Influence and Pressure on Members of Parliament

Parliament is made up of the members of Parliament who represent their constituencies but are sponsored on tickets of political parties. Members therefore may sometimes have a dilemma on whether to heed to the voice and call of their constituents or their political parties. To ensure that members of Parliament are aligned to their party’s position, both sides of the house have elected Whips whose duty it is to ensure that all members are whipped into line. It is therefore not surprising to have party members and executives enter the chamber of Parliament to ensure that their Members of Parliament vote on a particular issue in a particular line. On the inauguration of the 9^th Parliament, the minority took issue with the manner the Rt. Hon. Speaker Alban Bagbin was elected as such by the Political party before the house had the opportunity to elect the speaker. For instance, the Minority Leader had this to say on the floor of Parliament in seconding the nomination of the Speaker of Parliament after referring to Article 95 of the 1992 Constitution, “……Mr. Chairman, I have in my hand, a statement, issued by the Office of His Excellency John Dramani Mahama, titled ‘President Elect, mandates NDC Parliamentary Leadership to nominate Rt. Honourable A.S.K Bagbin as Speaker of 9^th Parliament’ it reads, the President elect, His Excellency John Dramani Mahama, has in consultation with the National Executives and Parliamentary leadership of National Democratic Congress, mandated the nomination of the Rt. Honourable Sumana Kingsford Bagbin, as Speaker of the of the 9^th Parliament of the fourth republic. Mr. Chairman, this letter is signed by Mr. Felix Kwakye Ofosu, as Special Aide. Mr. Chairman, the preliminary issue, I am raising, is to the effect that, the nomination, only required the consent, of the person to be nominated. The situation where, the Executive now directs that a member should nominate this makes this House of Parliament the appendage of the Executive”[82]. During the passage of the e-levy bill, the General Secretary of the National Democratic Congress (NDC) at the time was seen in the public gallery of Parliament ostensibly to whip their members into line in voting in a particular manner. This practice is not uncommon and hence out of place in the Author’s view for anyone to think the nomination of Speaker Bagbin was novel. In 2021, even before the Members of Parliament could elect their own Speaker of Parliament, the New Patriotic Party had not just elected Rt. Hon. Mike Aaron Ocquaye, they were so optimistic of his being elected as Speaker of Parliament that they had printed his name and picture in the brochure of the Inauguration of the President.[83] In the end, it turned out that the Honourable Prof. Mike Ocquaye was not the one elected as such, but rather Rt. Honourable A.S.K. Bagbin. It therefore does not lie in the mouth of the Minority to raise a challenge about the approach used to elect the Speaker, when their hands are tainted and are guilty of a similar conduct, in any case the maxim of equity is that he who seeks equity and he who comes to equity must come with clean hands. The Author suggests that, he who comes to equity must come not just with cleans hands but their whole bodies must be clean

It seems to the Author that already, the impression is that some Members of Parliament instead of doing the business of Ghana, rather focus of playing to the gallery and to the pleasing of their supporters and their parties. When political parties or their executives who are outside Parliament purport to exert unnecessary pressure on their members of Parliament to pursue a particular agenda, it is the state that suffers. In recent times, we have heard of leaders of Parliament making the point that there were some form of pressure brought to bear on them by their parties. The Honourable Majority Leader[84] has alluded to the fact that, the minority’s decision not to approve some ministers was as a result of external pressures.[85] The 1^st Deputy Speaker of Parliament and Chairman of the Appointments Committee[86], Honourable Ben Ahiafor has also made a similar point[87]. It is suggested that members of Parliament elected to serve their constituents, also sponsored by political parties, must be given some degree of freedom to work in an independent manner without any external control or pressures. If this is not checked, a time may come where members of Parliament in the chamber of Parliament would be remote controlled by some external forces whom the electorates have not voted into Parliament or into power, and that in the Author’s view will pose a danger and threat to the country’s nascent democracy.

The Purpose of Vetting under the Constitution 1992

The Constitution of Ghana 1992 in the spirit of separation of power and checks and balances, provides that some appointments by the President as leader of the Executive are subject to prior approval of Parliament. This means that if the President appoints a person and Parliament does not give prior approval to that appointment, such persons cannot assume the office to which they would have otherwise been appointed. When the President for instance appoints the Chief Justice[88] and other Supreme Court Justices[89] in consultation with the Council of State and with the prior approval of Parliament[90] hence such persons must go through Parliament for approval. In relation to this subject, Ministers of State, whether cabinet or otherwise are also appointed by the President with the prior approval of Parliament. In this regard, the Constitution provides that, “Ministers of State shall be appointed by the President with the prior approval of Parliament from among members of Parliament or persons qualified to be elected as members of Parliament, except that the majority of Ministers of State shall be appointed from among members of Parliament”[91] (emphasis the Author’s). In relation to Deputy Ministerial appointments, the Constitution provides that, “The President may, in consultation with a Minister of State and with the prior approval of Parliament, appoint one or more Deputy Ministers to assist the Minister in the performance of his functions”[92] The Constitution is silent on the nature the prior approval must take. The closest the Constitution comes to in the Author’s view is Article 78 (2) which provides that “The President shall appoint such number of Ministers of State as may be necessary for the efficient running of the state.” The necessity and efficiency of which seems to be the sole determination of the President. Although the Constitution is silent on the mode in which the prior approval is obtained, the Constitution provides that, “Subject to the provisions of this Constitution, Parliament may, by standing orders, regulate its own procedure.”[93]

The controversy of ‘Prior approval of Parliament’ arose in the celebrated case of J.H Mensah v Attorney General.[94] In that case, in the second term of H.E. President Jerry John Rawlings, it was announced at the beginning of the term that he had decided to retain some of his ministers who served in his first term and since they had been vetted and approved in his first term, they would not be presented to Parliament for vetting despite the constitutional provision of prior parliamentary approval. One of such Ministers was the Honourable Kwame Peprah who was due to present the government’s budget. The minority at the time, led by the venerable J.H Mensah, opposed the decision on the grounds inter alia that no one could be appointed or act as a minister or deputy minister during the second term without being vetted by the new Parliament since the tenure of the previous ministers had ended with the dissolution of that Parliament. The minority leader then commenced this action against the Attorney General and sought declarations inter alia that upon a true and proper interpretation of articles 57(3), 58(1) and (3), 66(1) 76(1) and (2) 78(1), 79(1), 80, 81 97(1), 100(1) and 113(1) and (3) no person could act as a minister of deputy minister without prior approval of the second Parliament, that the necessary incident of prior approval was the consideration and vetting of each nominee for ministerial appointment and that a person who had not been so approved. It is instructive to note that, prior to the determination, the Appointment Committee, which was chaired by Honourable Kenneth Dzirasah had deliberated on the matter and decided that where an incumbent minister or deputy minister is retained as such by the President, it shall not be necessary for them to be summoned to appear before the Appointment Committee for recommendations for reapproval. To them therefore, and erroneously so in the Author’s view, once approved by the previous Parliament, there was no need for the current Parliament to vet and approve their nomination. Not only did the Appointments Committee so decide, he introduced a motion in Parliament calling on Parliament to accept the decision of the Committee mentioned above. Thereupon, Parliament resolved that if a person has been appointed a minister or deputy with prior approval of the previous Parliament and retained, it was not necessary for the current Parliament to give another approval of such, a position the Speaker agreed and conveyed the resolution to the President thus, “If a person has been appointed a Minister or Deputy Minister with the approval of Parliament as an incumbent Minister or Deputy Minister, he is retained by the President, it shall not be necessary for Parliament to give another approval of such Minister or Deputy Minister.” This was one of the issues the writ issued by the minority leader at the time, Honourable J.H. Mensah brought up for determination, which determination has enriched our Constitutional and Parliamentary jurisprudence in the Author’s view. Their Lordships in their determination agreeing with the minority held that, “Articles 78 and 79 (1) of the Constitution, 1992, which provided that the President should appoint his ministers and deputy ministers with the prior approval of Parliament did not draw a distinction between fresh and reappointed candidates. Consequently, both new or reappointed candidates should obtain the prior approval of Parliament.” The Court went ahead to say thus, “…Although the expression “prior approval” was not defined in the Constitution 1992, it could not have been the intention of the framers of the Constitution, 1992 that it should necessarily imply consideration and vetting whenever it had been used in any provision of the Constitution because of the variety of definitions of the world [sic] (1) “approve” had been given in the Consultative Assembly and furthermore, that interpretation could not be consistently applied in all the provisions of the Constitution where the expression “prior approval” was used. Thus, the term “prior approval” was not a term of art. But the commonsense implication of the expression was to obtain the consent of the relevant authority. Where that authority was Parliament, article 110(1) of the Constitution empowered it by Standing orders to regulate its own procedure provided they did not infringe a provision of the Constitution. Thus, the court could not under article 2 and 130(1) of the 1992 Constitution direct Parliament on how to conduct its proceedings when granting “prior approval” under article 78(1) of the Constitution, 1992”. Ampiah JSC for his part had this to say, “[The words “prior approval”] are not terms of art; they are ordinary words which must be interpreted in their ordinary sense. The words “prior approval” … appears at various portions of the Constitution, 1992. “Prior” means – coming before in time; and “approval” means – feeling or showing or saying that one think something is good or acceptable or satisfactory… The words “prior approval” therefore means simply that before the President appoints a minister of state or deputy minister he or she must be put before Parliament to feel, show or say that such person is good, acceptable or satisfactory. While the word “prior” connotes acceptance before an appointment becomes valid, “approval” simpliciter connotes acceptance after the appointment.” The above dictum of the Court confirms that Parliament has the right under the Constitution to decide the mode in which they give the prior approval.

In the view of the Author, the essence of the vetting or Parliamentary approval is to ensure whether the persons so appointed could perform the task assigned to them by the President. The curious question that comes to mind in this regard is, whether persons who have not been vetted before they become Members of Parliament can vet a person who have been appointed as Ministers to show their suitability for the task. The Author notes that the entry requirement into Parliament of Ghana under the Constitution has no criteria to ensure that the person so elected can be fit for purpose. The law provides that, “Subject to the provisions of this article, a person shall not be qualified to be a member of Parliament unless – (a) he is a citizen of Ghana, has attained the age of twenty-one years and is a registered voter; (b) he is resident in the constituency for which he stands as a candidate for election to Parliament or has resided there for a total period of not less than five years out of the ten years immediately preceding the election for which he stands, or hails from that constituency; and (c) he has paid all his taxes or made arrangements satisfactory to the appropriate authority for the payment of his taxes”.[95] (Emphasis the Author’s). These are the qualification criteria one needs to possess before a person can qualify and be eligible to become a member of Parliament, without more. Not only are these the requirements to enter Parliament, but the President is by law compelled to appoint majority of his Ministers from Parliament as per Article 78(1) cited supra. This implies that the quality of Parliament, in terms of the knowledge, skill and competences of members of Parliament, has a direct relationship with the quality, knowledge skill and competence of the Executive and by extension the Government. The Author is not alone in this view, the respected Constitutional law expert Prof Sir Kofi Kumado in his book[96], ‘A Handbook of the Constitutional Law of Ghana and its History’ at page 168 thereof had this to say, “As with the Presidency, the qualification criteria for membership of Parliament also suffer from major defects. They are solely based on nationality, age, residence and place of origin. No formal education is required. There is no language qualification. Parliament is yet to equip itself with facilities to enable members to speak in their indigenous language. Parliamentary documents are only available in English which is also the language of parliamentary proceedings. One may argue that it is only by accident that university graduates, professionals from all kinds of disciplines and literate people are found in Parliament. For this outcome we have the political parties to thank. Competition amongst them provides Parliament with the quality that it has. Perhaps this dynamic situation will continue and so there is no need to look for a conscious solution. The Author suggests that the qualification criteria for entry into Parliament may have to be enhanced to include some formal education and other qualifications to the extent that majority of the ministers of state are supposed to be appointed from that pool.

The purpose of the vetting therefore is not an opportunity to settle personal scores, retaliate and see an apology from what an opponent had done before, or even to seek to whitewash someone who has been painted black by a political opponent, but rather to test the capability or eligibility of the appointee or nominee for the position for which he or she has been designated as such.

Super Majority and Micro Minority Controversy

In the parliamentary democracy of Ghana, there has been instances where either party has been on both sides of the isle, both majority or minority. In the Parliament of 1992 to 1996, it was made up of only NDC Members of Parliament because the NPP boycotted the Parliamentary elections. In the years 1996 to 2000, the NDC had a majority of 133 MPs with the NPP having 60 seats[97]. In 2000-2004 Ghanaians gave the NPP a majority of 100 seats while the NDC had 92 seats, in 2004 NPP had 128 seats and NDC had 94[98], For the first time in the 4^th Republic, there was a hung Parliament with almost equal number of Members of Parliament on both sides with only the Member of Parliament for Fomena an Independent Candidate, the Honourable Andrew Amoako Asiamah[99] who decided to caucus with the NPP that gave them a slim majority of 138 vrs 137. In the 9^th Parliament, however, there has been a remarkable trend resulting in one party having almost two-thirds majority, with the NDC having about 183 seats and NPP 88 seats. This clearly shows that the NDC has a super majority with almost 2/3 of the seat and almost over 100 members more than their NPP counterparts. This has caused some commentators to qualify the nature of the caucuses in the 9^th Parliament and sometimes to the chagrin of the Minority Leader. Indeed, the Minority Leader himself has had occasion to refer to the NDC majority as a Super Majority.[100] Indeed, the Minority leader has used this term to refer to the Majority on several occasions and rightly so.[101] It is conceded that the Standing Orders has nothing like a super majority for any caucus, but, the word, ‘super’ is an adjective that qualifies a noun. It is therefore preposterous that when the Minority is referred to as micro minority, anyone including the Minority leader takes issue[102] so as to generate controversy[103] which in the Author’s view is needless.

Beyond Parochial Partisan Interests, Perceiving a Common Nationhood

Professor Kwame Gyekye[104], a former lecturer at the Department of Philosophy authored a book titled, Beyond Cultures, perceiving a common humanity. In that book, he argued that, although there are cultural barriers and other factors that seem to divide a society, there is one commonality which was the humanity of the society. He advocates that, that was what the focus of the society should be. At page 2 of the book, he says thus, “Imagine a group of people – men, women, and children – in some natural environment, or a group of people who find themselves in a particular geographic space in the wake of, say, a shipwreck or a disaster of some sort, or a group of people in pursuit of sheer determination to relocate in order to fulfill certain existential needs. Imagine, also, that these people come from different lineages or ethnic backgrounds, related to one another by both kinship and non-kinship ties; but they have come or become coerced to live together. They will immediately feel the need to evolve a shared life and establish a social framework within which they can function as human beings. To fulfill this need, they will evolve certain values, practices, institutions in short, common forms or ways of life. They will nurture certain values, practices, meanings, and other symbols concomitant to a shared life…..”

In our Parliament and by extension our national politics, there seem to be some division along partisan lines. The partisan stance of people involved in nation building sometimes makes it difficult to see beyond the partisan lines to perceive a common nationhood or nationality. The Author takes the view that all political parties are claiming to have the solution to the problems of the country. The point of departure may be ideological or approach to governance. That in itself is good and same must not be allowed to divide us even to the point of destruction. It is high time; the extreme partisan stance is jettisoned in favour of the national interest.

In the House of Parliament, one would expect more consensus building rather than grandstanding or attempts to play to the gallery to suit partisan and external influence. The Members pf Parliament ought to know that although they belong to different political parties, they are there to represent the citizens of Ghana and hence all they do must be geared towards the national interest which in the Author’s view is superior to any partisan stance.

It is not for nothing that our members of Parliament are given an honourable status, they occupy important and honourable positions, and they must be honourable or carry themselves out honourably. In the Author’s view, if they behave in a dishonourable manner, they stand to lose the respect, and protection offered them by the State. The Author cannot resist the temptation in applying mutatis mutandis the dicta of Lord Patrick Devlin in his renowned book entitled, The Judge (1979) at page 4, “If a judge leaves the law and makes his own decision, even if in substance they are just, he loses the protection of the law and sacrifices the appearance of impartiality which is given by adherence to the law. He expresses himself personally to the dissatisfied litigant and exposes himself to criticism. But if the stroke is inflicted by law, it leaves no sense if individual injustice; the losing party is not a victim who has been singled out; it is the same for everybody he says. And how many a defeated litigant has salved his wounds with the thought that the law is an ass.” If the Honourables of Ghana Politics do not amend their ways and conduct themselves in a manner that corresponds to the titles they so proudly wear, a time may come, some Ghanaians may protest the use of such in reference to them on the basis that they are not in fact Honourable or the term Honourable may lose its value.

Conclusion

From the above, the Author submits that the august House of Parliament is an honourable house, the members who get in there to represent their constituents are privileged and have a duty to be honourable and show respect to their constituents from whose taxes they are remunerated. If they put up behaviours that is inconsistent with the honour and title citizens confer on them as Honourable, like was witnessed on 30^th January 2025 and other such incidents, they do not deserve the respect of their constituents and hence the title Honourable.

[1] https://www.myjoyonline.com/respect-is-earned-speaker-bagbin-tells-appointments-committee/

[2] Socrates was a Greek Philosopher from Athens who is credited as the founder of Western Philosophy and as among the first moral Philosophers of the ethical tradition of thought.

[3] The Assembly (“Ekklesia”) was the regular gathering of male Athenian citizens (women also enjoyed a certain citizen status, but without political rights) to listen to, discuss, and vote on decrees that affected every aspect of Athenian life, both public and private, from financial matters to religious ones….

[4] https://www.myjoyonline.com/chaos-erupts-at-appointments-committee-as-minority-and-majority-clash/

[5] https://www.modernghana.com/news/1377694/vetting-chaos-i-was-shocked-to-see-mps-fight.html

[6] https://citinewsroom.com/2021/01/chaos-during-inauguration-of-8th-parliament-unjustifiable-bagbin/

[7] The Honourable James Gyakye Quayson

[8] https://citinewsroom.com/2021/01/chaos-in-parliament-as-ndc-caucus-rejects-clerks-decision-to-bar-injuncted-assin-north-mp/

[9] https://www.myjoyonline.com/social-media-reacts-to-chaos-in-parliament-during-e-levy-voting/

[10] https://www.myjoyonline.com/barker-vormawor-summoned-to-appear-before-appointments-committee-over-bribery-allegations/

[11] The name Emeafa is different from Emefa. Emeafa means ‘inside or the situation will be cool or may be cool’ or ‘it will be peaceful’, while Emefa means ‘it is cool’ or ‘it is peaceful’

[12] https://www.ghanaweb.com/GhanaHomePage/NewsArchive/More-details-emerge-on-the-altercation-between-Emeafa-Hardcastle-and-Frank-Annoh-Dompreh-1969349

[13] https://www.ghanaweb.com/GhanaHomePage/NewsArchive/Frank-Annoh-Dompreh-cries-to-Speaker-of-Parliament-over-clash-with-Emeafa-Hardcastle-1969351

[14] https://citinewsroom.com/2025/01/bagbin-to-summon-emeafa-hardcastle-over-clash-with-annoh-dompreh/

[15] Member of Parliament, Tamale South and Minister of Education

[16] https://www.myjoyonline.com/apologise-publicly-for-harming-annoh-domprehs-reputation-haruna-iddrisu-tells-hardcastle-following-heated-exchange/

[17] https://www.myjoyonline.com/speaker-suspends-dafeamekpor-annoh-dompreh-and-2-others-over-appointments-committee-chaos/

[18] https://www.ghanaweb.com/GhanaHomePage/NewsArchive/Speaker-Badgin-rescinds-suspension-of-4-MPs-1970152, https://citinewsroom.com/2025/02/bagbin-lifts-suspension-of-four-mps/

[19] https://www.facebook.com/Oyerepa100.7Fm/videos/minority-leader-hon-alexander-afenyo-markin-on-behalf-of-the-minority-caucus-npp/2583740685145161/

[20] https://www.ghanaweb.com/GhanaHomePage/NewsArchive/Sue-Speaker-Bagbin-Martin-Kpebu-urges-four-suspended-MPs-1969800

[21] Article 21 of the 1992 Constitution of the Republic of Ghana.

[22] The law of Chieftaincy in Ghana

[23] [1971] 2 GLR 391

[24] Parliamentary Practice, 23rd edition

[25] 1965 (Act 300)

[26] Section 28 of the Parliament Act

[27] Section 29 of the Parliament Act

[28] Section 30 of the Parliament Act

[29] Section 31 of the Parliament Act

[30] Section 32 of the Parliament Act

[31]Order 30 of the Standing Orders of the Parliament of Ghana

[32] Order 31 (a) of the Standing Orders of the Parliament of Ghana

[33] Order 31 (b) of the Standing Orders of the Parliament of Ghana

[34] Order 31 (d) of the Standing Orders of the Parliament of Ghana

[35] Order 31 (e) of the Standing Orders of the Parliament of Ghana

[36] Order 31 (g) of the Standing Orders of the Parliament of Ghana

[37] Order 31 (i) of the Standing Orders of the Parliament of Ghana

[38] 1992 Constitution of Ghana, Parliament Act 1965 Act 300 and Standing Orders of Parliament.

[39] https://citinewsroom.com/2019/02/ken-agyapong-reprimanded-for-insulting-parliament/

[40] Contrary to section 97 of the Criminal and Other Offences Act, 1960 (Act 29)

[41] Contrary to section 101 of the Criminal and Other Offences Act, 1960 (Act 29)

[42] Contrary to section 124 of the Criminal and Other Offences Act, 1960 (Act 29)

[43] Contrary to section 131 of the Criminal and Other Offences Act, 1960 (Act 29)

[44] The week of the 30^th January 2025 incident

[45] A Former Chief of Staff and a lawyer with over 50 years standing at the Bar

[46] https://www.youtube.com/watch?v=AsY4ut–Hio&t=51s

[47] Member of Parliament for Nsawam Adoagyiri and Minority Chief Whip

[48] Proverbs 27:2

[49] At the time, member of Parliament for Akyem Abuakwa

[50] MHB 896 Stanza 2

[51] https://www.ghanaweb.com/GhanaHomePage/NewsArchive/Netizens-backtrack-on-Hardcastle-criticism-after-Annoh-Dompreh-s-controversial-remarks-1970544

[52] https://starrfm.com.gh/2025/02/annor-dompreh-has-made-hardcastle-look-very-good-jantuah/

[53] Honourable Micheal Okyere Baafi, member of Parliament for New Juaben South

[54] https://www.myjoyonline.com/we-had-no-choice-but-to-instigate-vetting-chaos-npp-mp/

[55] Mrs. Gifty Jiagge-Gobah

[56] https://citinewsroom.com/2025/01/afenyo-markin-clerk-to-appointments-committee-is-a-typical-ndc/

[57] https://www.gbcghanaonline.com/news/politics/i-am-sorry-afenyo-markin-to-clerk-of-appointment-committee/2025/

[58] https://citinewsroom.com/2025/02/help-your-npp-colleagues-beat-ndc-members-annoh-dompreh-to-supporters/

[59] https://www.ghanaweb.com/GhanaHomePage/NewsArchive/Arrest-Minority-Chief-Whip-for-inciting-violence-GFL-to-police-1970733

[60]A respected Lawyer, Former Attorney General and Former Ambassador to Canada

[61] https://www.modernghana.com/news/482697/sir-john-was-possessed-by-gbeshieayikoi-otoo.html

[62] Manasseh Azure Awuni, in his book, The President Ghana Never Got at page 239

[63] El Lizato is a famous social commentator who dishes out funny but wise sayings

[64] Order 20 (4)(c) of the Standing Orders of Parliament

[65] Order 34 (1) of the Standing Orders of Parliament

[66] Order 34 (2) of the Standing Orders of Parliament

[67] Section 34 of the Parliament Act

[68] Section 35 of the Parliament Act

[69] Section 36 of the Parliament Act

[70] Act 300

[71] National Chairman of the National Democratic Congress (NDC)

[72] Article 19 (5) of the 1992 Constitution of Ghana

[73] Article 19(11) of the 1992 Constitution of Ghana

[74] Section 34 of Parliament Act

[75] Section 35 of the Parliament Act

[76] Section 36 of the Parliament Act

[77] Section 36(2)(a) of the Parliament Act

[78] Section 36(2)(b) of the Parliament Act

[79] The current value for a penalty unit is GHS12.00 according to the Fines (Penalty Units) Act 2000 (Act 572)

[80] Section 43(1) of the Parliament Act

[81] Article 125 (3) of the 1992 Constitution, “The judicial power of Ghana shall be vested in the Judiciary, accordingly neither the President nor Parliament or any other organ or agency of the President or Parliament shall have or be given final judicial power”

[82] https://www.youtube.com/watch?v=YigP5_hh2r4

[83] https://www.adomonline.com/mike-oquaye-appears-in-2021-inauguration-brochure-as-speaker-of-parliament/

[84] Mahama Ayariga

[85] https://www.gbcghanaonline.com/news/politics/ayariga-minority-pressure/2025/

[86] Afenyo-Markin told me he is under pressure from the NPP – Chairman of Parliament’s Appointment Committee, Bernard Ahiafor #TV3GH | By TV3 Ghana | Facebook

[87] https://www.ghanaweb.com/blogs/zeqblog/Bernard-Ahiafor-reveals-that-Afenyo-Markin-told-him-that-his-actions-were-due-to-pressure-from-his-party-8626

[88] Article 144(1) of the 1992 Constitution of the Republic of Ghana

[89] Article 144(2) of the 1992 Constitution of the Republic of Ghana

[90] Article 144 of the 1992 Constitution of the Republic of Ghana

[91] Article 78 (1) of the 1992 Constitution of the Republic of Ghana

[92] Article 79 (1) of the 1992 Constitution of the Republic of Ghana

[93] Article 110 (1) of the 1992 Constitution of the Republic of Ghana