Leader of the Opposition in the Federal House from 1959 after losing the Premiership of the West to the Federation.
The Clifford Constitution (1922) replaced Lugard's advisory Nigerian Council with a true Legislative Council of 46 members, including — for the first time anywhere in British West Africa — four elected African seats (three for Lagos, one for Calabar). The Richards (1947), Macpherson (1951) and Lyttleton (1954) constitutions successively expanded suffrage, brought in Northern representatives (1947), introduced regional Houses (1951), and federalised the system (1954) into a Federal House of Representatives plus three Regional Houses.