The BNI and Police Powers of Arrest and Detention

A Review of the Conflicting Roles of the BNI and Ghana Police Service

Asante Fordjour LLB(Hons), LLM International Law And Criminal Justice


Social theorist Morris Rosenberg once pointed out that there is some sort of human currency to be measured and this currency, value, or rate, is actually measured by the person. These established tests and appraisals permit both criminal and social psychologists to measure self-esteem or self-consciousness of the human and in our present hearing, the Ghana Police Service. Thus a person with high confidence, might project an image of a person that is much better than what they really are, and the confidence makes up for the difference. The focus of Ghana Police as it now puts, is on forming strategic partnership with the public in the fight against crime. To achieve this community policing, is now being encouraged in identifying potential crime problems and together with the Service map out strategies to check them. The Service prides itself of manpower strength of about 23,000. Yet it seems to Research Group that image, crucial in contemporary state policing, is its greatest enemy.


State policing indeed requires the collective efforts of every citizen. Yet conservatively argued, and in the context of constitutional rule, it is neither the members of Bureau of National Investigations (BNI) nor the armed forces but the police, who could stop, question, arrest, detain and charge any person for any criminal offence. Are you therefore, not puzzled over the legal basis of the meddling of bni-cum-military in the process of arrest and detention in Ghana? To resolve this issue, perhaps we might need a bit of history to explain the usurpation of this customary police powers and authority.

Ghana Police Service: Brief History

The Ghana Police Force writes on its website that the professional policing that we see in Ghana today was introduced by the British Colonial Authorities to the Gold Coast in 1821. Before then, maintenance of law and order as the Service put it, was organized by traditional authorities such as the local headsmen and chiefs (the so-called asafo/ahenfie police), who employed unpaid messengers to carry out the executive and judicial functions in their respective communities. But with the institutionalization and formalization of police and the passing of the Police Ordinance in 1894, legal authority for the formation of a civil police force arose. Ever since, Gold Coast Police and its British counterparts have undergone a lot of introspections in the context of the remit of their respective traditions and history. Understandably, human development that comes as a result of educational training and personal adventurism and self-consciousness, have changed the faces and dimensions of the world and yes, how people behave and (re)act.

From the archives of Ghana Police, the Africanization of the police which in 1958, poled Mr. E. R. T. Madjitey as the first Ghanaian Police Commissioner, goes as far back to 1952, where a large number of Africans were enlisted into the Police Force as junior officers. This included the women branch of the service which became responsible for Juvenile crimes and offences committed by women. Today, the Service renders other important services such as (1) Motor Traffic duties to ensure safety on our roads; (2) Vetting and issuance of Police Criminal check certificates; and (3) Assisting and helping the female gender to deal with what it describes as traumatic and psychological problems of sexual abuse (usually against minors) as well as maintenance of law and order during elections.

In 1902, the Service, was split into General, Escort, Mines and Railway Police, and was legalized by the Police [Amendment] Ordinance of 1904. The Marine Police was formed in 1916 but disbanded in 1942 and replaced by Customs Excise and Preventive Service. The formation of Criminal Investigation Department [CID] in 1921 became operational in 1922 with the finger print section. And by 1948, the Police Reserves Unit has come into existence and with the mandate to combat riotous mobs, following the 1948 riots. In an effort to step up rapid and effective communication links within the colonies, the wireless and Communications Unit was established in 1950 with the formal opening of the Police Information Room in Accra by Governor Sir Charles Noble Arden Clark, in June 1950. By virtue of Article 200(3) of the 1992 Constitution, today, the Police Service must be equipped and maintained to perform its customary role but in whose image and orders?

Ghana Police Service: The Image Question

Section 1 of the Police Force Act, 1970 (Act 350), states among others that: “It shall be the duties of the Police Force to prevent and detect crime, to apprehend offenders and to maintain public order and safety of persons and properties”. Yet a visit to its developing website offers little guidance on its Codes of Practice. Apart from its stated primary functions as set out in the cited Act, the citizen is at large as to how these duties are to be carried out. Hence one is misled in perceiving the Service as colonially-fashioned and perhaps at pains in the reconstruction of its crowned “bully poster” of 24 February 1966. Thus since that coup the service continue to suffer not only what seems to many as irreparable “low-esteem” to the armed forces but also, doubt whether it is really an honest partner for a safer Ghana. We might look through this with different political spectacles but we may agree that we would be bargain at price that we tag on ourselves.

In the context of Ghana, one might argue that the Africanization of the Service in the latter part of 1950 and indeed at Ghana’s self-rule came with a soaring socio-political cost. This is in reference to contentious issues surrounding what the Service describes as the ongoing joint operations with its traditional pal- the armed forces in clamping down the said increasing rate of armed robbery that seems to have engulfed the country and which in the words of the police, has yielded tremendous success which cannot be over emphasised? Indeed JusticeGhana concedes that arrest and detention could be effected by every citizen where there is obvious necessity to believe that crime is being or about to be committed. So for example, the Immigration and Preventive Officer at the airports as well as the Prison Officer at our various prisons, depending on the circumstances, can also invoke these powers. But there are reasonable qualifications to this Victorian norm- here where it can be shown that it is impracticable for the police to be called to its duty?

The Police Powers and Process of Arrest

In the Kingdom of Great Britain, there is general police power to stop and search a person without arresting him. This is provided for in Police and Criminal Evidence Act 1984 (PACE) ss.1-7. The power can be exercised if a police officer has a “reasonable suspicion” that “a stolen or prohibited article” may be found on the suspected person(s). Although Plowden(2008) explains that arrest is without a definition and will often occur with a constable touching the person, the rule in Christie v Leachinsky (1947) AC 573 (UK) states that it is “the beginning of imprisonment”. Arrest could also be initiated either by the citizen or through the issuance of an arrest warrant. Arrest warrant is an official document that has been signed by an officer of the court ordering the arrest and detention of a named individual. But because arrest and detention impose restrictions on our personal liberties, it is said that no matter how grievous our crimes, the arresting officer ought to make it clear to us either by words or actions that we are not free to go.

Due to what Plowden describes as continuing issues with disproportionate use of stop and search powers on members of minority ethnic groups, the Code stresses that the action of the police must not be exercised in discriminatory manner. PACE Code A sets out how these powers should be exercised. In the spirit and letter of the law, the powers to stop and search must be used fairly, responsibly, with respect for people being searched and without unlawful discrimination. The Race Relations Act (Amended) Act 2000 makes it unlawful for police officer to discriminate on the grounds of race, colour, ethnic origin, nationality or national origins when using their powers, Code A, para 1.1.

The court has held that the use of the power must be fully justified and officers exercising the power should consider if the necessary objectives can be met by other, less intrusive means. Thus arrest must never be used simply because it can be used. In the Plowden’s explanation is that absence of justification for exercising the powers of arrest may lead to challenges should the case proceed to court. It is said that “When the power of arrest is exercised it is essential that it is exercised in a non-discriminatory and proportionate manner.” The Police Code G, para 1.2 and 1.3 go on to emphasise that ultimately it will be a matter for the “operational discretion of individual officers” whether a particular necessity condition is made out. Thus it is suggested that as Code G notes, it is likely that there will be an increase in the number of arguments at court as to whether an arresting police officer could have reasonably believed that it was necessary to arrest.

But in Fiak (2005) EWCA Crim 2381, the Court of Appeal held that arrest was a process, not a single event, and that it should not be “artificially compartmentalised” but could be postponed. Here Fiak was seen by the police sitting in the driving seat of a stationary BMW, throwing up into the gutter. When the police spoke to him he smelt of alcohol and was unsteady on his feet. The police suspected that he was drunk in charge of a motor vehicle. Fiak told the police that he was only sitting in the car and had left his house nearby for a few minutes to cool off after a row. On this basis the suspecting police officer told him to wait while she went to confirm his story. Knowing he was lying, Fiak refused to wait as instructed and tried to force his way into his house. At this point, a struggle ensued and was charged with criminal damage to his police cell. He argued that his original arrest had been unlawful because he had not been arrested by the officer before she went to confirm his story so he was acting lawfully in entering his own home.

This decision is said to be difficult to reconcile with authority- and that it might be better to follow the court’s alternative rationale-namely that the arrest was arguably completed at the point when Fiak was told to wait in his car, even though the word “arrest” was not used. Here in UK, PACE s.1(2) permits a constable to search any person or vehicle or anything in or on a vehicle for “stolen or prohibited articles”. The list of prohibited article” included: (a) Offensive weapons (b) Bladed instruments (as prohibited by s.139 Criminal Justice Act 1988) (c) Articles made or adapted for use in dishonesty offences (ie. theft burglary, taking a motor vehicle without consent) and (d) Articles made, adopted or intended for use in an offence of criminal damage (eg. Spray paint, etching tool). A caution should be given as soon as there are “reasonable grounds” to suspect a person of an offence: James [1996] Crim L R 650. It is incumbent on the police to inform the suspect reasons for his arrest and warn him about his answers to police questions.

The Police Caution on Arrest

A caution is a warning to a person that what they say or do not say may now have legal consequences. The terms of caution are laid down by PACE Code C para 10. “You do not have to say anything but it may harm your defence if you do not mention, when questioned, something which you later rely on in court. Anything you do say may be given in evidence. Do you understand?” Failure to state facts that are later relied upon in court can have adverse inferences. This strikes the balance between our legal rights to silence and/or civic obligation to give factual answers to police questions that might dilute their subjective “reasonable grounds” to suspect and arrest us of an offence.

In the words of Plowden, the objective basis for that suspicion must be based on facts- information and /or intelligence which are relevant to the circumstance and can never be supported on the basis of personal factors alone without reliable supporting intelligence… or some specific behaviour by the person concerned. Reasonable suspicion cannot be based on political generalisation or stereotyped images of certain groups or categories of people- person’s race, age or appearance, as more likely to be involved in criminal activity. Thus the fact that Kwame Asante is known to have previous conviction of stealing cassava or hen, cannot be used alone in/or in combination with each other as the reason for searching him. Arguably, the ruling in O’Hara v. Chief Constable RUC [1977] Crim LR 432 seems to give different limbs to “unreasonable generalisation test”.

Here the House of Lords held that the test fell in two parts first, there must be actual suspicion on the part of the arresting officer; secondly, there must be reasonable grounds (judged objectively, rather than subjectively) for that suspicion. It was not enough simply to say that the officer was acting on instruction from his superior; he must show “reasonable grounds for suspicion”. Thus, here the officer formed a genuine suspicion as the result of the briefing from his superior, and that that suspicion was reasonable. Accordingly, the O’Hara, arrested on suspicion of being a terrorist but later released on grounds of lack of evidence, could not win his claim against the police. This legal reasoning was also approved by the European Court of Human Rights as lawful: O’Hara v. United Kingdom, (2002) 34 E.H.R.R. 32. The legal analogy is that although Sections 44-47 UK Terrorism Act 2000 bestow on the UK Police a wide ranging power to stop and search any citizen without reasonable suspicion; the green light ought to be signalled by a senior officer- in this case of assistant chief constable rank or more senior.

What attempts to convey here is that while modern state policing sometimes relies on rumours and murmurs, it ought to be linked to accurate and current intelligence if effective, legitimate and secure public confidence and collaboration were to be restored. Thus the obiter, it appears, is that if the Prosecution were to secure a reputable charge and conviction, the arresting officer must form genuine opinion which must be backed by yes, reliable intelligence and protocol beefed by superior authority. In O’Hara, had this not been the case, the scale would have probably swayed against the State. It might not be an exaggeration to say that even today; about 99 per cent of the Ghanaian population still believe that the Police/BNI can stop, search and arrest, detain, charge and arrange you before court at its whims even if the crucial evidence is missing.

The Ghana Police Service cannot travel on this path if it were to be able to combat both domestic and the emerging transnational crimes such as money laundering, human and drug trafficking as well as terrorism and sex-slavery. A compelling area that JusticeGhana had expected the BNI with all its seemingly human resource and overriding statutory authority over other security services, to have been at the forefront in Sate’s intelligence gathering and projections. But not electioneering predictions, car clamping and immigration controls which are well within the reach of the police and the Customs and Preventive Service. Yet the omnipresent Bureau appears to have lost face and faith with the Ghanaian and ultimately, helpless and arguably, frustrated because of its political origins. Yes, has no scientific proof but it seems to us that if there is any pitfall in Ghana’s criminal justice system, then it is the shared power of arrest and detention of the Police and BNI whose statutory clarification, is long overdue.

JusticeGhana’s contributing advice is that for Ghana Police to restore its struggling image and be proactive in its intelligence gathering and analysis crucial for its role, it needs the collective efforts and trust of all but not the designed coercion and oppression associated with warring armies who had sought victories through infliction of psychological threats and pain- either by showcasing their degraded captives or abusing women and children in a manner inconsistent with rule of law which history, had shown all to be simplistic.

Written by

Gina is the Director of Health and Publisher, JusticeGhana Group.

6 Comments to “The BNI and Police Powers of Arrest and Detention”


    The writer had a very good topic but failed to educate the reader on how the power of arrest of the BNI conflicts with that of the Ghana Police service.
    it is my humble submission that the article is legally pathetic and factually empty and detracts from the topic. my reasons for this submission are provided below…..
    Under our laws, the power of arrest does not reside solely in the bosom of the police. see Criminal and other offences (Procedure) Act,1960 (Act 30)
    Parliament as the body with authority to make laws, can enact laws which confer on bodies other than the police the power of arrest in certain limited instances. To attempt to blame the woes in the criminal justice system on the arrest power given to BNI is a pitiful exercise.
    In any case, ACT 562, which established the BNI amongst others, conferred certain duties on it.(see section 12 of the said ACT). In other to have the maximum result, it is only prudent that BNI be given some power to enable it effectively discharged its duties.
    The author,contends that the arrest power of the police and BNI has not been clarified by statute, this is a very pathetic claim and demonstrates legal deficiency.A statute must be read as a whole and in conjunction with similar legislation. As earlier stated, parliament may make laws to confer arrest power on a body other than the police in certain limited instances. a careful look at Section 40 of ACT 562 clearly shows that the BNI’s power of arrest is limited to section 12 that ACT. for the benefit of other readers i quote section 40;
    “Subject to the Constitution, an employee of any of the Internal Intelligence Agencies shall in the performance of his duties under this Act have the same rights and powers as are conferred by law on a police officer in the performance of his duties and shall have the same protection”
    from this section it is clear that BNI can only arrest in the performance of its functions as provided in section 12. section 12 provides that;

    Section 12—Functions of the Intelligence Agencies.

    “(1) The Intelligence Agencies shall have the following functions—

    (a) collect, analyses retain and disseminate as appropriate information and intelligence respecting activities that may constitute threats to the security of the State and the government of Ghana;

    (b) safeguard the economic well-being of the State against threats posed by the acts or omissions of persons or organisations both inside and outside the country;

    (c) protect the State against threats of espionage, sabotage, terrorism, hijacking, piracy, drug trafficking and similar offences;

    (d) protect the State against the activities of persons, both nationals and non-nationals, intended to overthrow the government of Ghana or undermine the constitutional order through illegal political, military, industrial or other means or through any other unconstitutional method; and

    (e) perform such other functions as may be directed by the President or the Council”
    the Ghana police service, has expansive if not unlimited powers of arrest which can be exercised at all times subject only to the constitution and the enabling ACT. see sections 1-10 0f ACT 30.
    the author must come again on his position….the pitfalls in the criminal justice system has no nexus with the power of arrest given the BNI by ACT 562.

  2. fordjour says:

    [1] The preamble to the 1992 Constitution proclaims the people as the source of authority; that the people derive that authority from God who grant them their natural and alienable rights. It further states that the people in the exercise of that God-given authority, have given to themselves present Constitution which has among its prime commitments ‘protection and preservation of Fundamental Human Rights and Protections’.

    [2] In keeping faith with this commitment and to rebury the omens of the Re Akoto and Others (1961), in relation to its consistency with the interpretation of the Art 13(1) of the 1960 Republican Constitution as against the Preventive Detention Act (PDA) of 1958 (No.17), the 1992 Constitution makes provision for array of guaranteed fundamental human rights and freedoms and also makes provision for their protection and preservation by the court and a national human rights institution, the Commission on Human Rights and Administration Justice (see Chapter 5, the 1992 Constitution).[see Re: Akoto and The Supreme Court Revisited].

    [3] If the police arrest us which process must it follow? And from the cited similar powers shared by the police and the BNI and of course similar security agencies, what must the Bureau do if for example, it intends to arrest someone from a coffee shop or a radio station, for insulting a high authority in the State or in extreme scenario, a suspect purported to have unlawfully caused market fires?

    [4] “Security personnel were not only at the centre of coups d’etat and of ruling juntas established prior to Ghana’s fourth effort at republican rule, they were also heavily involved in extra-judicial executions and punishment, human rights violations, and in the widespread and prolonged infringement of a wide range of basic civil rights.” (Oquaye 1980; Jackson 1999; Westwood n.d.) Legally, when we talk of conflicting roles of the Ghana Police, the BNI and the Power of Arrest, then we are concerned with its constitutional process of arrest and detention.

    [5] Ashley Crossman (, Sociology) writes that role conflict occurs when people are confronted with incompatible role expectations in the various social statuses they occupy and role conflict can take several different forms. “When the roles are associated with two different statuses, the result is known as status strain. When the conflicting roles are both associated with the same status, the result is known as role strain. Conflict may also occur when people disagree about what the expectations are for a particular role or when someone simply has difficulty satisfying expectations because their duties are unclear, too difficult, or disagreeable.”

    [6] Of course we concede that the 1992 Constitution explicitly stipulates that (Article 85) that ‘No agency, establishment or other organization concerned with national security shall be established except as provided for under this Constitution. Hence the Security and Intelligence Agencies Act 1996, no.526, codified and accordingly, given constitutional authority under which the BNI- an offshoot of Ghana Police Service, and the military [foreign] intelligence have to operate?

    [7] Reading the statute as a whole and in conjunction with similar legislations as you entreat us, it cannot be the case that the BNI has special arrest and detention powers outside that of what the Constitution gives to the police and other security agencies to withhold its ailing suspects beyond their graves without recourse to the international human rights standards and ethics. (see, PACE 1984, UK, particularly- Admissibility of confessions, sections 76, 78)

    [8] In the Kingdom of Great Britain the Police and Criminal Evidence Act 1984 (PACE) was introduced to tackle police abuses; especially the practice of verballing officers saying that the suspect made some kind of admission to him when in fact no such conversation took place. For example, Code provides at C11.7(a) that an accurate record [of the arresting police officer] must be made of each interview; in practice, this means that interviews are now tape recorded.

    In Ghana, what are the standard codes of practice of the BNI personnel in forecasting for example, the outcome of a political party internal presidential or national presidential election contest? Yes, a citizen [only] can “arrest” a criminal if he witnesses the commission of the crime by the criminal. But s/he may not use deadly or excessive force when detaining a criminal because if this arrest is made improperly, the alleged criminal may have a legal right to sue the citizen.

    • Ivan Mensah Dadzie says:

      Dear Asante Fordjour, LLB(Hons), LLM International Law And Criminal Justice

      I think it is fair to repeat the first line of Mr. Twumasi’s comment.
      The writer (YOU) had a very good topic but failed to educate the reader on how the power of arrest of the BNI conflicts with that of the Ghana Police service.

      What I have realized is that they do not have a Code of Practice (as you rightly pointed out) as they seem to always employ arbitrariness in their operations and are often seen involved in Acts which the police are competent to handle, and sometimes which clearly are provided under Act 804 (the EOCO Act of 2010), creating role conflicts. You rightly pointed out the role conflict but my difficulty with your article is that it offers no clear line on how the power of arrest of the BNI is in conflict with that conferred on Police.

      You could have been more specific on instances in which there are such conflicts either in the Acts which create the two institutions or in the Acts as enabled under law.

      Again, your employment of British arrangements, I doubt helps much because it offers no bearing on your topic despite your second attempt to clarify your position. At one point, I read you saying that the BNI has no power beyond that which is granted to any security agency to detain people beyond the constitutionally allowed 48 hours or deny persons invited for interrogation access to counsel.

      I harbour no pain, therefore in agreeing with Mr. Twumasi that your article is a pitiful exercise as it detracts from the perceived limits of the topic.

      I wish you can come again and this time, please let’s understand you clearly!

      • ginford says:

        *I wish you can come again and this time, please let’s understand you clearly!
        * You could have been more specific on instances in which there are such conflicts either in the Acts which create the two institutions or in the Acts as enabled under law.
        * I harbour no pain, therefore in agreeing with Mr. Twumasi that your article is a pitiful exercise as it detracts from the perceived limits of the topic….
        The Bureau of National Investigations (BNI), had been on record for debt collection; and attending to mere verbal assaults. When we are arrested by the police, a specific series of events follows. The BNI is in conflict/confused in drawing a fine line between its operational evaluations and objectives- especially…

        [0] It is established in most international and domestic legislations that the police must follow legal procedures during the actual arrest process, and at many other stages along the way to actually placing a suspect in jail.

        [1] We begin by clarifying the point that there is, respectfully, no such thing like Act 562 as quoted in Twumasi’s commentary. It ought to have read: the Security and Intelligence Agencies Act 1996 (Act 526).

        [2] On the issue of conflicts and specifics, it is unclear but for now, it seems to most Ghanaians that the Bureau of National Investigations (BNI) is neither a police service/force nor part of the Ghana Armed Forces. We doubt not however, that it derives some sort of operational existence and goals from the police.

        [3] We learn even that some of the nucleus of the Bureau, were drawn from and indeed trained by the de facto Special Investigations Branch(?SIB) of the Ghana Police before the 31 December 1981 coup d’etat.

        [4] The conflict as illustrated and explained elsewhere in our articles covering the Ghana’s BNI, attempting to exist and perhaps, respected, like the MI5 or the CIA, is a farce. It lacks, unfortunately, not only in the said basic professional ethics- and here, on its core investigative roles but also, arresting powers that to some extent, we all have on matters bordering on national security and serious crime prevention.

        [5] The Bureau had been on record for debt collection; attending to mere verbal assaults in radio/TV stations. It had been also documented for scuffling and wresting not only with some members of main opposition political parties of the day but also, some sections of the media and the general public at large.

        [6] This is incomprehensible- for an “under-ground” organization, photocopied from abroad and locally minted to rely heavily on the help, support and the solidarity of the public on its intelligence gathering and processing.

        [6.1] The BNI is either in conflict or confused in drawing a fine line between its operational evaluations and objectives- especially, on which task/mission it has to turn down to the plain-cloth/uniform police.

        [6.2]Yet we are hesitant and yes, unable to conclude that the BNI has difficulty in the understanding of the letter and the spirit of Act 526.

        [7] In the Great Britain the Police and Criminal Evidence Act 1984 (PACE)( sections 76, 78), was introduced to tackle police abuses; the practice of some officers alleging that the suspect made some kind of admission to them when in fact no such conversation took place.

        [7.1] In 1966, the U.S. Supreme Court ruled in Miranda v. Arizona, that individuals who are under arrest for suspicion of having committed a crime have certain rights that must be explained to them before any questioning may occur. Yes, today the US- the home modern democracy, is coining its self-centered Guantanamo criminal justice system.

        Yet, the BNI can’t just bounce on us in a radio studio for saying our mind on how our country is being governed. At least, not where, no coup is being staged to incite or topple a corrupted regime or government. Clearly Not possible!


      well i have read your response and it still fails to establish the nexus between our failed justice system as your posited and the role played by the conflicting powers of arrest by the police and BNI.
      like it is provided in section 40 of Act 562, in the exercise of the power of arrest by the BNI the benchmark is the constitution. The arresting officer must not go beyond the constitutionally stipulated guidelines provided in article 14 of the constitution 1992.
      In all sincerity, i cannot fathom your response to my earlier post.
      i would appreciate if you will clarify your position further because the central idea of your article appears to be still shrouded in mystery.

      • ginford says:

        Dear Twumasi

        Thanks for visiting JusticeGhana and for the comment.

        [1] We think we don’t have to agree at all cost. Could you, then, consider a rebuttal article on the topic to be published here?

        [2]Before then, you may wish to refresh your memory that the Act of Parliament ought to read: Intelligence Agencies Act 1996 (Act 526).

        [2.1] But not Act 562 as you had been mistakenly, citing in your responses. For the purposes of some of our readers we respectfully, consider it below:

        [3] It seems to us that the Act 562- LAWS OF GHANA (REVISED EDITION) ACT 1998 (ACT 562), reads in part:

        Section 1-Appointment of Law Revision Commissioner.

        (1) The President in consultation with the Council of State and the Minister for Justice shall appoint a Commissioner to be known as the statute Law Revision Commissioner to prepare a Revised Edition of—

        (a) all Acts in force on 1st January, 1999; and

        (b) all subsidiary legislation in force on 1st January, 1999.

        (2) Where the Commissioner is for any reasonable and just cause unable to perform the functions assigned him under this Act, the President may in accordance with the advice of the Minister for Justice appoint another person qualified to be Commissioner during the period of absence of the Commissioner.


        [4] We would be most grateful to you therefore, if this could be rechecked and advised or informed accordingly.

        On that note, JusticeGhana wishes you a healthy merry Christmas and a Prosperous New Year.

        Thanks for the patience and the loyalty.

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