The Republic
The Constitution

2nd Alteration2010· Act No. 2, 2010

Constitution (Second Alteration) Act, 2010

Pre-election matters and the 180-day petition rule — the architecture of modern election litigation.

The record

The Second Alteration Act of 2010 created the constitutional skeleton of modern Nigerian election litigation. It introduced strict timelines for the resolution of pre-election matters (180 days) and for the determination of election petitions (180 days at the tribunal, 60 days on appeal), and it shifted the burden of providing election-petition jurisdiction wholly into the Constitution rather than the Electoral Act.

It is the Act that produced the now-familiar phrase 'time is of the essence' in Nigerian election jurisprudence. Petitions filed even a day outside the timeline are statute-barred — a rule the Supreme Court has applied without exception since ANPP v. Goni and CPC v. INEC.

The Act also tightened the qualifications for elective office under §§65, 66, 131, 137, 177 and 187 by reinforcing the disqualifications for indictment, dual citizenship by registration, and bankruptcy.

Sections altered

  • §65

    Qualifications for election into the National Assembly.

  • §66

    Disqualifications — indictment, allegiance, bankruptcy.

  • §68

    Tenure of seats and cross-carpeting consequences.

  • §131

    Presidential qualifications — codified the school-certificate requirement.

  • §137

    Presidential disqualifications.

  • §177

    Gubernatorial qualifications.

  • §187

    Deputy Governor — election and qualifications.

  • §285

    Detailed timelines for tribunals (180 days), appeals (60 days), and pre-election matters.

Notable cases

  • CPC v. INEC (2011)

    (2011) LPELR-9012(SC)

    Election petitions cannot extend the 180-day timeline; the period runs from the date of filing.

  • PDP v. CPC (2011)

    (2011) 17 NWLR (Pt 1277) 485

    Time begins to run from filing, not from service.

Methodology

Tier 1 · primary

Courts. Gazettes. National archives.

Tier 2 · corroborating

OCCRP. HRW. BudgIT. TheCable.

Tier 4 · tertiary, flagged

Wikipedia only where primary is pending. Always labelled.