By Akin Ogunlola, esq
It goes without saying that wherever corruption thrives, the rule of law suffers, and human rights are inevitably undermined. Corruption represents a major obstacle to socio-economic and political development in Nigeria. While the country is richly blessed in natural and human resources, entrenched corruption has made it impossible for us as a nation to effectively harness these resources for common good or to translate same into economic development. Despite its size and the opportunities presented by its large population, corruption remains a major turn off for most foreign investors who want to invest in the country. It must be emphasized however that corruption is a universal epidemic that plagues both the developed and developing countries of the world. It is not peculiar to Nigeria alone because it transcends national boundaries and cultural frontiers. But it is so bad in the country that it has virtually eroded public trust in the government and taken away trustworthiness from all government institutions at large, as it continues to negatively impact the image of the country globally.
Corruption takes many forms and the perpetrators are skilled in developing new ways to engage in corrupt practices as well as to cover their tracks to the extent that there is no agreement on a conclusive definition of the term, “corruption”. According to Transparency International (TI), corruption can be defined as the “abuse of entrusted power for private gain”. Similarly, the African Development Bank (ADB) defined corruption as “the act of offering, giving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party”. The International Monetary Fund (IMF) on the other hand views corruption as the “use of official position for private interest”. Finally, according to the Independent Corrupt Practices Commission (ICPC), “corruption means any dubious act that takes place when people try to get what they do not deserve by using money, official position, tribal connection, religion, family name, threats, harassment and other negative means”. We can therefore reasonably conclude that corruption is a form of dishonesty or criminal activity undertaken by a person or organization entrusted with a position of authority, often to acquire illicit benefit, or, abuse of entrusted power for one’s private gain.
Among the causes of corruption in Nigeria are, the persistent culture of primitive capital accumulation, instant gratification mentality of the people, mass poverty among the populace, greed, weak legal and judicial process, long period of military misrule, low wage policy, institutionalization of mediocrity in political recruitment and governance, and most importantly is the weak regime of the intertwined concepts of ethics, accountability and transparency in the country’s public sector. In other words, it is safe to say that low level of accountability, lack of transparency, and poor leadership are responsible for the high level of corruption in Nigeria. While there are several types of corruption and corrupt practices generally, the most common ones in Nigeria are abuse of power, trading in influence, money laundering, bribery, kickbacks, over invoicing, irregularities in the award and execution of capital projects, favoritism and nepotism, misappropriation of public funds, under remittance and non remittance on government accruals, payment of salaries or wages to non-existent workers (ghost workers), lack of accountability and transparency in the management of public funds, as well as impunity on the part of key public officials and top civil servants.
What is “Sustainable development”?
According to the Brundtland Commission (1987) Report of the World Commission on Environment and Development, United Nations, “Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs”. It contains within it, two concepts: the concept of needs, in particular the essential needs of the world poor, to which overriding priority should be given; and the idea of limitations imposed by the state of technology and social organization on the environment’s ability to meet present and future needs”. The concept of sustainable development in its present form focuses largely on economic development, social development and environmental protection for the future generations. Accordingly, the United Nations has come up with collection of seventeen global goals (sustainable development goals) designed to be a “blueprint to achieve a better and more sustainable future for all” by the year 2030. Among these goals are eradication of poverty and hunger, provision good health and well being, provision of quality education, ensuring gender equality, provision of clean water and sanitation, affordable and clean energy, decent work and economic growth, industry, innovation and infrastructure, reduction in inequality, peace, justice and strong institutions etc. Without doubt, high rate of corruption in Nigeria will continue to make the attainment of these sustainable development goals very difficult if not impossible.
In Nigeria, the Executive branch of government has greater access and control over public funds and resources than the other two arms of government combined. As a matter of fact, over Ninety six percent (96%) of money appropriated (budgeted) by the Legislature in any given year has consistently gone to the Executive branch. Accordingly, experience has shown that while corruption may have permeated every facet of Nigerian society, for obvious reason stated above, more egregious and outrageous forms of corruption (grand corruption) involving public funds takes place within the executive branch of government as amply demonstrated by reported or prosecuted corruption cases of corruption in the country. Worrisome too is the fact that, due to the growing influence and powers of the Executive branch, parliamentary scrutiny of public accounts statements have virtually disappeared in the country to the point that the pursuit of public accountability is popularly viewed as unpatriotic or causing embarrassment to a ruling party – a culture which poses great threat to transparency and achievement of sustainable development.
In line with the United Nations millennium goals and subsequent sustainable development goals, the 1999 Nigerian Constitution (as amended) not only places the government under the obligation to meet the needs of the people and enhance their well-being (Tokunboh 1990), but also provided in its section 15(5) that “the state shall abolish all corrupt practices and abuse of power”. Chapter 2 of the Constitution broadly provides for fundamental objectives and directive principles of state policy. This Chapter lays out the broad principles and objectives that the State should aspire to in order to attain good governance and sustainable development. In particular, Sections 4(2) and 14(2)(b) of the Constitution provides that: ‘The National Assembly shall have power to make laws for the peace, order and good government of the Federation or any part thereof’. Furthermore, section 14(2)(b) of the Constitution proclaims that “the security and welfare of the people shall be the primary purpose of government”.
Notwithstanding these provisions in virtually all the past and present Nigerian Constitutions, the country has not been able record any appreciable success in that regard due largely to corruption. As already stated, corruption undermines good governance; it fundamentally distorts public policy, leads to misallocation of resources, erodes peoples’ trust in government, hinders development and harms the poor people who are the major priority of the United Nations sustainable development goals. Among the internationally accepted anti-corruption tools or mechanisms are integrity pacts, oversight, transparency, accountability, compliance, political will, ethics, and rule of law. “Legislative oversight” and “accountability” are therefore mechanisms designed to combat corruption in public administration or government. That Legislative oversight and accountability are critical components of good governance and anti corruption mechanism while good governance is an inevitable precondition for achieving sustainable development.
Legislative oversight could be described as the authority of the Legislature to conduct inquiries or investigations of the executive, to have access to records or materials held by the executive, or to issue subpoenas for documents or testimony from the executive. According to Woodrow Wilson (28th US President), ‘oversight’ is the “duty of a representative body to look diligently into every affair of government and to talk much about what it sees. It is meant to be the eyes and the voice and to embody the will and wisdom of its constituents.” Legislative oversight therefore involves lawmakers keeping an eye on the activities of governmental agencies especially the executive branch on behalf of the people (electorate). In Guide to Legislative oversight in the National Assembly by Policy and Legal Advocacy Center (PLAC), Madue (2012:435) argued that since oversight can be performed ex-ante-during the design and implementation of a program or policy, as well as ex-post, after its implementation, “it follows that oversight entails the informal and formal, watchful, strategic and structured scrutiny exercised by the legislature in respect of the implementation of laws, the application of the budget, the strict observance of statutes and the constitution”. It can therefore be summarized as the power of the Legislature to oversee, review and investigate the activities of the Executive branch.
Naturally, one is tempted to ask the question, where does the legislature derive the power of oversight to oversee or investigate the Executive arm of government? The answer lies in the democratic principles as well as practical purposes. Oversight also derives from the many and varied express powers of the Congress in the Constitution. It is implied in the legislature’s authority, among other powers and duties, to appropriate funds, enact laws, raise and support armies, provide for a Navy, declare war, and impeach and remove from office the President, Vice President, and other civil officers. Congress could not reasonably or responsibly exercise these powers without knowing what the executive was doing; how programs were being administered, by whom, and at what cost; and whether officials were obeying the law and complying with legislative intent. John Stuart Mill, the British philosopher, insisted that oversight was the key feature of a meaningful representative body: “The proper office of a representative assembly is to watch and control the government”. Woodrow Wilson also equated oversight with lawmaking, which was usually seen as the supreme function of a legislature. In Congressional Government (Boston: Houghton Miffin, 1885 at page 297, he wrote, “quite as important as legislation is vigilant oversight of administration”. The philosophical underpinning for oversight is the Constitution’s system of checks and balances among the legislature, executive, and judiciary.
The answer to the source of Legislative power of oversight therefore differs from country to country but generally speaking, this power is either (a) implied by the constitution, or (b) expressly granted by the constitution. For example, as stated above, it is implied in the United States that the Congress (Legislature) has the power as a direct result of its law-making power responsibility. On the other hand, the oversight power of the Nigerian National Assembly (Legislature) is expressly given by the Constitution in Nigeria. The express oversight powers of the Nigerian Legislature are contained in sections 88, 89, 128 and 129 of the 1999 Constitution. First two sections relate to the National Assembly at the federal level while the last two deal with state Houses of Assembly.
For the purpose of this discussion, we shall concentrate on the National Assembly. Sections 88 gave the National Assembly power to conduct investigations. Specifically, section 88 (1) stated inter alia that each House of the National Assembly (House of Representatives or the Senate ) shall have power by resolution to direct or cause to be directed, investigation into any matter or thing with respect to which it has power to make laws; and the conduct of affairs of any person, authority, ministry or government department charged or intended to be charged with the duty of, or responsibility for (i) executing or administering laws enacted by the National Assembly, and (ii) disbursing or administering moneys appropriated by the National Assembly. Furthermore, S.88(2)(b) specifically conferred on the National Assembly the power to investigate and expose corruption, waste, or inefficiency in the execution or administration of its laws, and, in the disbursement, administration or management of funds appropriated by the National Assembly. The oversight functions of the Nigerian National Assembly therefore include scrutinizing and authorizing revenues and expenditures of the government and ensuring that the national budget is properly implemented.
Again, Section 89 (1) stated that for the purposes of any investigation under section 88 of this Constitution, the Senate or the House of Representatives or any of their committees, shall have power to: (a) procure all such evidence, written or oral, direct or circumstantial, as it may think necessary or desirable, and examine all persons as witnesses whose evidence may be material or relevant to the subject matter; (b) require such evidence to be given on oath; (c) Summon any person in Nigeria to give evidence at any place or produce any document and examine him as a witness; (d) issue a warrant to compel the evidence of any person; and (e) the warrant issued under this section can be served or executed by the police or anyone authorized by the Senate President or the Speaker of the House.
As a direct consequence of the provisions in both sections 88 and 89 of the Nigerian Constitution therefore, the National Assembly can conduct hearings basically for three reasons: (a) to consider pending legislations; (b) to investigate issues that may require legislation in the future; and (c) to investigate and oversee federal programs. It is this investigating and overseeing federal programs and projects that is referred to as legislative oversight. Other forms of legislative oversight under the Constitution include control of public funds, otherwise known as power of the purse which is vested in the Legislature by virtue of section 80 (3) and (4) of the 1999 constitution as amended. Section 80 (3) provides that “no money shall be withdrawn from any public fund of the federation other than consolidated revenue fund of the federation unless the issue of those moneys has been authorized by an act of the National Assembly”, while section 80 (4) also provides that “no money shall be withdrawn from the consolidated revenue fund or any other public fund of the federation except in the manner prescribed by the National Assembly. These constitutional provisions are not only designed to prevent unauthorized withdrawals of money by the Executive but also to fight corruption generally. It is in that spirit that the 1999 Constitution in section 85 (2) further gives power of audited reports to the National Assembly by providing that “the public accounts of the federation and of all offices and courts of the federation shall be audited and reported to the Auditor- General who shall submit his reports to the National Assembly”.
Whether implied or express, legislative oversight generally serves a number of overlapping objectives and purposes among which are the fact that it serves to improve the efficiency, economy, and effectiveness of governmental operations;, it also helps to detect and prevent poor administration, waste and fraud, abuse, arbitrary and capricious behavior, or illegal and unconstitutional conduct, thus making the government accountable to the people; it help to evaluate programs and executive performance too. Other purposes or benefits of oversight include being used to protect civil liberties and individual rights of the citizens by curbing the excesses of government; it helps to improve the transparency of government operations and enhances public trust in the government; it is useful in gathering information to develop new legislative proposals or to amend the existing laws while also ensuring that there is administrative compliance with the law and legislative intent. Finally, legislative oversight is an effective tool in combating corruption and ensuring national development. What then is the scope or applicability of Legislative oversight in Nigeria? It can be said that since legislative oversight prevents waste and fraud; protects civil liberties and individual rights; ensures executive compliance with the law; gathers information for making laws and educating the public; and evaluates executive performance, it generally applies to every Cabinet department, Executive agencies, Regulatory agencies, all the Nigerian MDAs, and the Presidency.
Broadly speaking, there are three main types of hearing associated with Oversight power of the Legislature. The first is often referred to as (a) Legislative hearing or public hearing which is a situation where Committees hold hearings on measures or policy issues that may become public law. This hearing provides a forum where facts and opinions can be presented by witnesses with varied backgrounds, including members of the national Assembly, other government officials, interest groups, civil society organizations and academics, as well as those citizens that are likely to be directly or indirectly affected by the proposal; The second type is simply called (b) Oversight hearing which is hearing review or study the law, issue, or an activity, often focusing on the quality of federal programs and the performance of government officials. The Oversight hearing as this is called, often seeks to improve the efficiency, economy, and effectiveness of government operations. It should be noted that the two above, legislative hearing and the oversight hearing can be combined sometimes. The third type of hearing associated with oversight power of the Legislature is the (c) Investigative hearing. Investigative hearing substantially shares some of the characteristics of legislative and oversight hearings. The difference only lies in the Legislature’s stated determination to investigate. This usually happens when there is a suspicion of wrongdoing on the part of public officials acting in their official capacity, or private citizens whose activities suggest the need for a legislative remedy. The power of the U.S. Congress to investigate is broad and it has exercised this authority since very long time. Its most famous inquiries are benchmarks in American history.
Notable examples are Watergate, and Iran-contra. Another good example is the ongoing impeachment hearing of President Donald Trump by the U.S. Congress over suspected abuse of power, extortion, bribery and possible violation of his oath of office in the manner he related with the Ukranian President, Volodymyr Zelensky a U.S ally whose country had relied on U.S military assistance in an ongoing war with the Russia.
This leads us to the Power of the Legislature to compel appearance or testimony of a witness or issue a subpoena. The question here is, with the constitutionally granted and judicially recognized powers of the Legislature to conduct hearings and investigations into appropriate matters within its legislative competence, what happens if a witness refuses to appear before appropriate Committee of the Congress or National Assembly? To answer this question, we need to examine the established practice and judicial attitudes in the United States and Nigeria respectively regarding the power of the Legislature to issue subpoenas and compel appearance of witnessed.
The statement of the U.S. Supreme Court in McGrain v. Daugherty, 273 U. S. 135 (1927) is instructive when it stated that: “a legislative body cannot legislate wisely or effectively in the absence of information respecting the conditions which the legislation is intended to affect a change, and where the legislative body does not itself posses the requisite information –which not infrequently is true –- recourse must be had to others who posses it. Experience has taught that mere requests for such information often are unavailing, and also that information which is volunteered is not always accurate or complete, so some means of compulsion are essential to obtain what is needed.” Id, at p. 175
Ordinarily, most individuals respond favorably to an invitation to testify, believing it to be a valuable opportunity to communicate and also publicize their views on a question of public policy. However, if a person refuses to honor an invitation to appear or testify, a Committee or sub Committee may compel his/her appearance through the issuance of a subpoena. Committees may also subpoena correspondence, books, papers, and other documents. In McGrain v. Daugherty the U.S. Supreme Court described the Congressional power of inquiry as “an essential and appropriate auxiliary to the legislative function”. The court went further to state that the “issuance of a subpoena pursuant to an authorized investigation is “an indispensable ingredient of lawmaking.” Similarly, in Eastland v. United States Servicemen’s Fund (1975) 421 U.S.491 the Court stated that “issuance of subpoenas such as the one in question is a legitimate use by Congress of its power to investigate”, and the subpoena power may be exercised by a Committee acting on behalf of one of the Houses (Senate of House of Representatives). The U.S. Court of Appeal for the District of Columbia had earlier stated in the same case that “a compulsory mechanism like a subpoena is “inherent in the power to make laws”.
Based on the above decisions, one is tempted to conclude that the oversight power of the Legislature to compel witness appearance at its hearings or to subpoena needed documents is absolute. The truth however is that the power of the legislature to undertake legislative oversight is not absolute. For instance, Chief Justice, Earl Warren, an American Jurist and Politician captured the limits on the power of Legislative oversight when he stated thus:
“the power of the congress to conduct investigation is inherent in the legislative process. The power is broad; it encompasses inquiries concerning the administration of existing laws as well as proposed or possibly needed statutes. It includes surveys of defects in our social, economic or political system for the purpose of enabling congress to remedy them. It comprehends probes into department of the Federal Government to expose corruption, inefficiency and waste. But broad as this power of inquiry is, it is not unlimited. There is no general authority to expose the private affairs of individuals without justification in terms of the functions of the congress… nor is the congress a law enforcement or trial agency. There are functions of the executive and judicial departments of government. No enquiry is an end in itself; it must be related to, and in furtherance of the legislative task of congress. Investigation conducted solely for the personal aggrandizement of the investigators or to “punish” those investigated is indefensible…”
The U.S. Supreme Court in line with that broadly outlined philosophy therefore held in Warkins v. U.S. 179 (1957) that “the power to investigate must not be confused with the power of law enforcement; those powers are assigned under the Constitution to the Executive and Judiciary. Congress has no power to expose for the sake of exposures”. Therefore the power to summon a person would have no application where the subject matter involved bears no relevance remotely to lawmaking. The power of investigation cannot be used to interfere with judicial proceedings.
Following in that footstep, the Nigerian Court also recognized the non absolute nature of the power of National Assembly to compel witness appearance, To support that position is the case of Tony Momoh v. Senate of the National Assembly (1982) NCLR, 105, where the court held that the legislature is not given powers to usurp the general investigating functions of the executive nor the adjudicative functions of the judiciary. Therefore, any invitation issued by the legislature to any person outside the purpose defined in the relevant section is invalid. Also, the prosecution of persons found guilty of corrupt practices or gross inadequacies or misconduct in the discharge of the public office is left to the executive. Furthermore, any investigation which is sought only to expose or ridicule persons, especially their private affairs, without any legislative intent, will not be entertained. See guide to Legislative oversight in the National Assembly by PLAC.
The Nigerian Supreme Court enumerated same position while spelling out the limits on the oversight and investigative powers of the National Assembly in Guardian Newspaper Limited v. AGF (1999) 9 NWLR (pt.618) 187, 249. The court held that the refusal by the Attorney General of the Federation (AGF) to respond to Senate invitation has the support of the Constitution. The Court explained further that in reaching its decision, the Court was guided by Tony Momoh’s case where Hon. Ademola Johnson Ag. CJ pointedly admonished that section 82 of 1979 Constitution, which is now section 88 of 1999 Constitution as amended, is not designed to enable the legislature usurp the general investigational functions of the executive and the adjudicatory functions of the judiciary. Accordingly, “any invitation by the National; Assembly to any person outside the purpose defined in Section 82(2) of 1979 Constitution, now Section 88(2) of 1999 Constitution (as amended) is unconstitutional and invalid”.
The applicable standard for determining the validity or otherwise of the Legislature’s power of investigation with its attendant power to issue subpoenas and compel the appearance of a witness therefore is the degree to which it complied with the provisions and intent of Section 88 of 1999 Constitution. In other words, National Assembly’s Committee investigations or inquiries must be authorized by the Congress; it must pursue a valid legislative purpose, and raise questions that are relevant to the issue being investigated.
Furthermore, Congressional or Legislative inquiries may not interfere with adjudicatory proceedings before a Court, Department or Agency in order to be valid and constitutional; (a) Committee investigation or inquiries must be authorized; (b) investigation must pursue a valid legislative purpose; (c) must raise questions that are relevant to the issue being investigated; and (d) it should not interfere with ongoing adjudicatory proceeding.
Notable challenges to Legislative oversight in Nigeria include lack of established democratic culture, unbridled corruption, personal interests and ambitions of legislators who are always seeking contracts from the directors of supervised MDAs thus making them stooges of the Executive. Other impediments include docile citizenry, undue interference by the Executive who practically determined the composition and leadership of the Legislature in the first place, ethnic loyalty, as well as Executive lawlessness. Frequent changes in the membership of the National Assembly during elections coupled with the inexperience or outright ignorance on the part of the newly elected members as well as leadership tussles and frequent changes in the leadership the legislative houses, amongst others, are great impediments to effective legislative oversight as a credible anti corruption mechanism in the country. Former Nigerian President Olusegun Obasanjo in 2012 while commenting on the composition of the National Assembly claimed that it has turned into a preserve for crooks, mediocre, riffraff’s, and self-centered people. With such people constituting the majority in its membership, the legislature could not effectively perform its oversight functions or promote national development.
Another notable problem is judicial corruption and lack of regard for public policy in courts judgments. Many of Nigerian judges also appear eager to directly interfere with even the most basic of the legislature’s powers. For example, just recently, a Court ignorantly issued an injunction to stop the Nigerian Senators from considering or debating a particular bill on the floor of the Senate! Our judges, for unknown reasons often exhibit total ignorance of most elementary and basic democratic principles, the existence or the objectives of the United Nations sustainable goals and ways of attaining them, or even the global push among all the countries to eradicate corruption generally. Finally is the public perception and poor outcomes of past oversight hearings conducted by the National Assembly. The impression is that the motive behind every investigative hearing of both houses (Senate and the House) is to personally enrich the lawmakers. This is borne out of the fact that no meaningful outcome has ever been accomplished through such hearings. For example, people have questioned the number of completed investigations by the Legislative Committees that have been subsequently referred to the Economic and Financial Crimes Commission (EFCC), the Independent Corrupt Practices Commission (ICPC) or other law enforcement agencies for prosecution.
Notwithstanding the enumerated challenges to Legislative oversight, it has helped, and continues to help in no small measures to curb Executive lawlessness, expose corruption and waste of public resources. For instance, the 6th Assembly House of Representatives under Speaker Dimeji Bankole as a result of performance of its oversight function ensured that Federal Ministries, Departments and Agencies (MDA’s) returned unspent budgeted funds amounting to about N450 billion to the government treasury in 2007. In the same vein, another sum of N350 billion was again recovered in 2008. In total, the House of Representatives ensured the return of about 1 trillion naira unspent funds by MDA’s as part of the annual budgetary process under Bankole’s speakership. These were unprecedented in the history of oversight in Nigeria’s legislature. Up until then, MDA’s did not return unspent funds. Also, the House of Representatives discovered that about 5 trillion Naira generated revenue were never remitted by MDA’s for the past 5 years before investigation.
In the same vein, oversight power of U.S. Congress has helped to force officials out of office, change policies, and provide new statutory controls over the executive. In 1949, for example, probes by special Senate investigating subcommittees revealed corruption among high officials in the Truman administration. This resulted in the reorganization of certain agencies and the formation of a special White House commission to study corruption in the government. The Senate Foreign Relations Committee’s televised hearings in the late 1960s helped to mobilize opposition to the Vietnam War. U.S. Congress’s 1973 Watergate investigation exposed White House officials who illegally used their positions for political advantage, and the House Judiciary Committee’s impeachment proceedings against President Richard Nixon the following year ended his presidency. In 1987, oversight efforts disclosed statutory violations in the executive branch’s secret arms sales to Iran and the diversion of arms profits to anti-government forces in Nicaragua, known as the contras. Congressional findings resulted in proposed legislation to prevent similar occurrences.
Altogether, Nigeria is committed to the pursuit and attainment of all the sustainable development goals as declared by the United Nations and has therefore taken notable and commendable steps in the fight against corruption by implementing virtually all the mandatory policies recommended by Article 6 (1) and (2) of the United Nation Convention Against Corruption (UNCAC) by establishing anti-corruption bodies such as the EFCC, ICPC, Code of Conduct Bureau (CCB), the Public Complaint Commission (PCC) etc with legal regimes for a series of corruption preventive mechanisms. All these, together with the power of legislative oversight are designed to fight corruption and unleash the country’s potentials towards achieving the goals of sustainable development. Regrettably Nigeria continues to be viewed as either a “fantastically corrupt” or simply corrupt country. For the country to record any genuine and commendable success in the fight against corruption there is the urgent need to undertake a complete review and overhaul of existing approach with a view to laying greater emphasis on the preventive aspect of corruption by increasing the level of engagement or involvement of the people in the fight, just as decisiveness and impartiality of the government in the fight against corruption must be convincing. As a country, we must change our entire value system. Transparency, accountability and good governance (rule of law) must be embraced by public officers and political leaders alike, while the judiciary must return to being truly unbiased, competent and independent before legislative oversight or any other device can serve as a reliable anti-corruption mechanism in Nigeria. The country must therefore be honest in its commitment to, and discharge of all the recommendations of the United Nation Convention Against Corruption (UNCAC) in order to successfully eradicate corruption and achieve any sustainable development goal.
Ogulola Esq is the Senior Special Assistant (SSA) to the Rt. Hon Speaker, House of Representatives, Abuja on Anti-Corruption.