Friday, 11 November 2016

Pass the ATI Bill—The proof of its pudding will be in the eating



My son, Bayethe, was born in 2004, only a year after the Media Institute of South Africa (Malawi Chapter) and other organisations with the help of the Open Society Initiative for Southern Africa (OSISA) had drafted for this country the Access to Public Information Bill. Bayethe—I use him to measure how long we have groped in the dark to have our MPs pass this Bill into Law—is now in form 1. In between so much has happened, more importantly the ransacking of the public purse at Capitol Hill, the seat of Government, an event that has no parallel in the history of public thievery in the country—I mean the scandal christened Cashgate.

I am sure that if we had passed the ATI Bill by 2005 or thereabout some of these scandals could not have found a rung to perch on in our democracy. Today there is talk of probing the late President Bingu Mutharika’s accumulation of wealth estimated at over MK60 billion, all this ‘made’ within the short period of time before his untimely death in April 2012. As I am writing, the first multiparty President, Bakili Muluzi, the man Bingu had succeeded, is answering, no, has been answering corruption charges.

Only a few weeks ago, news was rife in the country erupting from the ICT rumour mill of the social media that the President had either died or was dying in the United States. When the President finally arrived and was unable to use his right hand, for he went about greeting those gathered, using his left hand, like Caesar, the lie-peddlers felt the prophecy had hit home. Days later, the President told the nation how that rheumatism had made it a bit numb, that now, though seventy-something, he had the entrails of someone in the thirties. In fact, he invited one Malawian boxer resident abroad for a fight. You would think things ended there. In Malawi things do not end like that. After an event like that, you expect some pushing and shoving, some blame-shifting, some press release and finally, some apology. The rest has happened in that order except the last, for a war is raging by the day between the private media and the President backed by the State House communication machinery. As I’m writing, the private media houses have released a communication to the effect that they will give coverage involving the President some blackout, to demonstrate their frustration.

Many have said things like these should have been avoided if we had taken a proactive stance, passing the ATI Bill into Law only a year or two after it had been drafted. Today, because information from the high places is so scarce, people have to resort to the grapevines for the health of their President.

Some years ago, one professor, I think at a conference that took place in Mzuzu, made an interesting observation on consequences when a national broadcaster is left to serve only those in power or those connected. He warned that every time people are denied an entry from the front door, they learn to make it through the backdoor. What he meant was that monopolizing the national radio was by and by creating a floodgates of backdoor communication. What he meant by this was that if you do not proffer the people a formal opening, the people will find , because if you do not provide the people with the normal channel of communication for their civic participation, they learn to do it via the backdoor. How right this man was, for years later that’s exactly what has happened, that the people created their own platform from where they launched gossip of worst nature and effect—saying our President was ill and was dying.

The worst thing with those rumours was that some within the ruling party had started realigning themselves with those they thought would ascend to power, and this they did, on the strength of the rumours that were circulating. A few days ago, the President made it clear he heard everything when he said, “I am surrounded by Judases.”

A society that is open saves itself from the inconvenience of fighting rumour. Access to public information, which also encourages deliberate provision of communication, would ensure the people were kept abreast with the illness of their leader so those with a heart of GOD would spend time of their knees, praying for their leader.

Apart from creating an environment of certainty among the people, ATI would also form an important instrument in the creation of policy ownership among the people. A story about my own life can illustrate this.

When I was thirteen I moved to a village called Mtendere near Zomba Sawmill. The village is at the foot of the Zomba Plateau, then a natural facility endowed with everything beautiful—natural green, wild animals, fruit of all nature, tranquility and hope. As young boys, we spent most of the days in the forest, gathering fruit or just playing under the watchful eye of nature. None among us would engage in an activity to disturb nature. If any would suggest that we should set the forest on fire, we would all be on him, for the forest symbolized our survival, our very existence. Today, every year, between August and November, that forest cackles with flames of huge fires. Unfortunately, I have never heard any politician talk about this yet that plateau is part of Zomba. There are three places where you get the sweetest natural water in Malawi: Mulanje, Mzuzu and Zomba. There is a lake in Zomba, Lake Chilwa, whose life is dependent upon Zomba. Politicians have no time for that; they go about persuading us to accept that they are constructing us quality macadamized roads, that they are better than their predecessors and and so on and so forth. In the end, we are breeding a generation of people that feed on lies, a generation that does not know what it means to own our natural resources let alone the temporary physical infrastructure the politician is erecting in the name of serving us.

When young I could not think of setting my forest on fire; I owned it. The same applies to policy. No matter how nice a particular policy, if you do not connect with the people so they should own and protect it, you risk what is referred in policy language as ‘policy sabotage’, where the implementers deliberately shun carrying out a particular project because they fear doing so would spark anger in the beneficiaries.

Malawi is undergoing the most ambitious public sector reforms ever, and this despite advice to the contrary that best reforms are those implemented incrementally, i.e. one facet upon another. History of public sector reforms in the country—from the first wave of PR reforms that followed the 1964 Skinner Commission and those that followed the Economic Commission for Africa to the second wave of reforms authored by IMF/World Bank through the structural adjustment programs (SAPs) in the late 1980s—one vice keeps showing up for their failure: the efforts were perceived by the people as a stepping stone to formalizing corruption in the high places and as a mechanism to reward cronyism. This mistrust still reigns today, and I believe that one of the reasons the people have refused to believe in such important undertakings by their governments is that they see such efforts as institutions built and run in secrecy to serve interest of the elite few. If the ongoing PS reforms are to work, the people have to be afforded an opportunity to follow them and contribute where they can. They must also be given an opportunity to ask their Government to explain decisions the people do not understand. The danger with disregarding this component on the reforms is that they will be deprived of ownership, and without general ownership, reform sabotage results, and with it, reform failure.

When a human being owns a problem, that problem is as good as solved. This is what Malawi needs today. Malawi does not have a people who can own their problems and work collectively to solve them. People develop the mentality to own their problem when they are afforded an opportunity to understand the magnitude of the problem and when they perceive that they are part of the solution. Access to Public Information can play an important role in triggering ownership among the people.

There is another important reason why Malawi desperately needs ATI Bill today and that is that the civil service in the country has now changed from an institution that used to protect the people to one that preys on them. Unfortunately, criminal law, the very instrument that was created to stand for the people has been found wanting. In the Lutepo Case, the Judge, Honourable Justice Professor Kapindu said the following words, which I find, illuminating:

I must begin by pointing out that the sum of money which the convict herein conspired with others to defraud the Malawi Government of, and which he actually laundered, at MWK 4,206,337,562 (Four Billion, Two Hundred and Six Million, Three Hundred and Thirty Seven Thousand, Five Hundred and Sixty Two Kwacha), is unquestionably so huge. I have gone to the lengths, breadths, and depths of jurisprudential research—carefully going through all the available African Law Reports (Malawi Series), the Malawi Law Reports from the initial volume of 1923 to present, decisions published online, and I have also gone through a panoply of unreported decisions of superior courts in Malawi, both old and new. I could find no single case where a person was ever convicted for conspiring to defraud, defrauding and/or laundering, or otherwise embezzling, sums of money of such huge proportions as in this case. None of the cases of this genus or species could come even close.

Honourable Justice Professor Kapindu was expressing dismay at the plunder at Capitol Hill that came to be known as Cashgate when top crook politicians colluded with businessmen and women and banks to defraud Government of money, claiming these were payments for goods supplied and services rendered to government departments when in fact all this was a creation from the studio of satan.

In the Lutepo Case, the convict had confessed to be used as a go-between in the thievery at a commission of slightly 10%.

The learned man later expressed dismay at the mismatch between the plunder and the sentences as our Parliament had put forth in our statutes:

The legislature set the maximum sentence for money laundering at 10 years imprisonment and for conspiracy to defraud at 3 years imprisonment. The maximum sentence under the MLA (Money Laundering Act) is particularly strange considering the possibilities of very serious crimes that may be committed contrary to that Act. I am not sure why the maximum penalty was pitched so low. Perhaps the framers of the legislation might not have envisaged that offences under the Act might assume huge proportions of the magnitude encountered in the present case. . . . The law makers should seriously reflect on whether the punishments we have on the statute book are sufficient to address the mischief intended to be cured by the legislature through the Money Laundering, Proceeds of Serious Crime and Terrorist Financing Act.

Put simply, his lamentations were that we are faced with that type of pillage that has no parallel in the history of crime in the country, a kind of punishment, total punishment, to the poor. And sadly, we have reached a point where crime is making mockery of any form of punishment under the Malawi criminal justice system.

It is funny that when Malawi just attained Independence in 1964, there was great hope that the criminal justice system would work so well as to prevent future mischief. The Cashgate plunder has made it all look a joke, a looooooong joke.

I think a diversion should help here for contrast.

In the early days after our Independence, one white man, Rendall-Day (Rendall-Day v Rep [1966-68] ALR Mal 155), was charged with five counts of theft. Rendall-Day was Chief Executive Officer of the Malawi Housing Corporation, and part of his duties was to approve and sign cheques on behalf of the Corporation. He bought for his own use a house upon which the Corporation had paid a deposit of £385. The Board of the Corporation agreed to lend this deposit to the appellant (him) until the house was transferred to him, but he later made out cheques in the Corporation’s name for a further £1,400 without authority. He also carried out extensive improvements to the house, using workmen paid by the Corporation and ordering materials on corporation order forms. When the dealer’s bills arrived for payment, he asked the Corporation accountant to make out vouchers and paid them by cheque. He was sentenced to 25 months imprisonment with hard labour. Rendall-Day appealed, but the appeal was dismissed or put differently, it never succeeded.

The court, in rejecting the defence argument that the sentence of 25 months imprisonment was excessive, said:

In an emergent country (young nation, Malawi as was then), it is inevitable that many persons occupy positions of trust in relation to public money. However they may not have had a sufficient education or that rigorous discipline in honesty by which young persons benefit in countries with a long history of settled law and order. It has therefore, been regrettably necessary to impose heavy sentences in this country for thefts of money, particularly theft of public money, to induce a climate of opinion where to steal is condemned not only by the law but as a bad moral course. Such sentences are intended to rehabilitate offenders, and to deter the many others who are tempted to steal the money they are handling.

Although this sentence, a sentence of just over two years, was criticised for being insufficient for the theft of over $3,000 public money in Malawi in 1966, the rationale for the sentence impresses me, especially that this was in 1966, and the court was able to foresee the need to deal with plunder of public resources to deter the same. Some fifty years later, we can steal with impunity and leave the whole nation reeling in deprivation, making a mockery of every nature of sentence our judges can think of.

If in 1966 the people needed public trust; they need it more today. Today, the criminal justice system has lost its saltiness; it’s insipid, and legal scholars are now suggesting that we should resort more to the concept of trust and equity (which can go beyond legal barriers to trace loot) to ensure no one takes advantage of the people to siphon public resources. Access to Public Information legislation serves better on this framework because it could enable the people monitor whether Government (and in the law of trust, it can be argued that a government owes a special relationship to take care and protect the people) is doing everything according to their wishes. The basis of our Constitution is that power is given to those in power on trust; those who give them this power must thus, be afforded the opportunity to see through what happens inside their Government.

The importance of ATI law to Malawi is not just that we should add to a catalogue of laws that know only to bite the poor; this one is for the poor to bite those that bite them.

It seems this time Parliament is determined to pass the ATI Bill into law; unfortunately, it seems there are still disagreements over the contents of this legislation.

A few days ago I read inputs by stakeholders to the Bill, some genuine, but some pure confusion.

First, a number of stakeholders have raised concerns that, this Bill, if passed in its present form, will be an instrument powerful in name only. Some have taken Government to task for hiding under the Official Secrets Act to deny the people an opportunity to access public information; some have bemoaned the removal of the provision for an independent body on matters of complaint where particular information is denied; and some have even expressed worry that ‘information will be accessed through the Internet’ and that some fee will be required to ‘buy’ it. And some have added, they want this legislation to be guided by principles of maximum disclosure, minimum exemptions, and that Government should allow the people to access information based on the ‘public interest’ yardstick.

First, these things are reported in the media, and at times I have doubts whether those reporting give us an accurate representation of what was said. This I am saying because I find some things confusing, and I question whether some of such points did indeed come from the sources the reports attribute them to.

In one article I heard something like the Government was denying the people to access public information based on public interest. I think what this means is that Government is saying that no one should use ‘public interest’ as a criterion to request public information.

Public interest
Let me just suppose that Government had indeed taken this position, which I do not believe is what the Government meant by this, for, in all fairness I can never see an Advisor advising Government thus, and this is for a number of reasons.

First, public interest is everything the Government does in one word. It is the hub of the Constitution of the Republic of Malawi, the centre of everything our Constitution is. Anything Government does hinges on public interest, even the PS reforms (mandated under s. 30 of the Constitution) have a backing of public interest. The power those in power have is on trust as per sections 6 and 12 of the Constitution. So how could the Government say the people should not access information bases on this? This is why I say someone must have quoted our Government wrong. But suppose the Government had indeed taken this position, then judicial review (a process where a person with a legal position can seek clarification from the courts on the process a particular public officer or public office followed in making some decision he considers unfair to him) will have to do its job, and fortunately, there is enough case law precedent all over on judicial review on ATI issues. It is a position Government can never sustain. So people should fear nothing on this; I think the only problem maybe will be we have very few judges in the country.

How about maximum disclosure, et cetera?
Maximum disclosure simply means that only under rare circumstances should the public be refused access to information. People think it’s easy for Government just to wake up and say, “You cannot access this information.” It must give convincing reasons why accessing the same will not be in the interest of the people, otherwise, the mechanism is that if you assert and you fail to redeem yourself, you lose it. I am never perturbed by issues of maximum disclosure. Access to public information takes care of itself on the ground.

What people forget is that when it comes to ATI, rarely do the public get what they want. True access comes in when the courts begin their work especially where a legitimate request is denied on reasons that are frivolous or senseless.

Retrospectivity of the law and ATI
Many people think that the fact that Government takes a stand that the law will not apply retrospectively means access of old record or information will not happen in practice. If you read it that way, then you are missing the interesting facet of this legislation. I will give just one example on this. In 2006, in a court case involving Mittasteel SA Ltd (formerly ISCOR Ltd) and Hlatshwayo, the South African Supreme Court held that a private institution formerly owned by government is duty bound to release information generated in the period during which it had been a public entity. This is an example of issues that define themselves with time on issues ATI. An issue cannot be clearly provided for in the Act, but situations will show you how that should shape up. This is why I welcome the ATI in any form—the legislation will shape itself on the ground with time.

The Mittasteel Case talks of ‘releasing the information’ but ‘release’ is not usage though the essence of ATI is both access and usage, and as way back as the 1870s, in the case involving Sturla and Freccia, Lord Blackburn defined public document as “a document made by a public officer for the purpose of the public (i.e. the public getting or accessing it) making use of it and being able to refer to it (getting or accessing it and using it).”

If the Government thinks that by retrospectivity it will bar the people to access, then it is reading it all wrong; the question, I think should be whether such information would be admissible in court or whether you can use it to lodge a claim or a complaint. Otherwise it will mean once that once such information is generated it will live to be destroyed. Usually in most ATI regimes, there are periods prescribed for particular information to be released.

On people accessing minutes from cabinet meetings
From a number of cases I have read on this, the principle looks simple: for those meetings where there won’t be harm (harm in terms of derailing a particular public policy issue for the people), the cabinet can be justified to keep it a secret, but not forever. Or for those meetings bordering on high national security, the cabinet are privileged to keep it under wraps. However, Government should justify why this is the case. Otherwise facts on the ground will demand that they release it.

No matter what the Bill says, if Government insists that it shall never ever release minutes from their meetings, then they are reading it all wrong, and I have no doubts courts shall be provided with fodder to spurn the same.

On using the Official Secrets Act (Cap. 14: 01 of the Laws of Malawi)
Which country in the world would want their high security sold on the roadside? None. So what is the fuss on this? Well, it could be that people fear the Government can use it as an excuse to refuse every request. Do not forget that when Government refuses a particular piece of information it will have to give convincing reasons for that. These reasons can appear ‘convincing’ on their side, but when you test them on the harm test or public interest test, their justification can be found wanting. Remember, principles on ATI are evolving on a case-by-case basis. Besides, read the “1996 Johannesburg Principles on National Security, Freedom of Expression and Access to Information” and measure for yourself the yardstick for a genuine claim for threat of national security. In short, the issue of Government using the Official Secrets Act is blown out of proportion. Reality on the ground will be different.

On 22 Acts of Parliament that would restrict ATI legislation
I think the major work on this Bill should have been revisiting the identified 22 Acts of Parliament people say can restrict this legislation not to fear the shadow postures by those in power, for those will be dealt with on the ground. It would be important to be anticipatory and therefore read such provisions against those in the ATI to predict how they will live side by side. As far as I am concerned the danger to ATI lies in marrying it with those 22 anti-ATI legislation Acts already on the ground.

Independent Commission
An independent commission was going to be the best arrangement for our country, but if they insist otherwise, let them go with it, because they will not run away with it forever. The High Court is also mandated with the power to analyse how public decisions are arrived at through a mechanism called judicial review as I already stated. People should not lose faith on ATI; let Government give us anything; we shall perfect it with time, though my only concern is on how truly independent our courts will be on these issues. I have never even once believed that a system chosen by someone can turn round to insult that chooser. It is like saying Judges can handle a case in which they are asking for pay rise for themselves by themselves which happened once in 2006. Every time I read that judgment, I laugh, because a great attempt was made to justify why though it was something to do with them, they were still going to handle it, and they were going to be independent. Now you ask me how that case ended? I give you the opportunity to judge.

Other Instruments on ATI
Apart from my concern from the more than 22 Acts of Parliament that can restrict ATI in the country (something we do not seem willing to address now), ATI will also be non-starter without a robust record management system in the country. This is a problem even in the judiciary where one would naturally expect good record management, them being people who deal justice. Bu in “An Overview of Malawi Legal Information Institute”, Mariya-Badeva Bright minces no words on this when she says “Record-keeping practices in justice sector institutions are generally poor.” She adds by saying the same affects the smooth delivery of justice.

Paul Lihoma in his PhD Thesis “The impact of administrative change on record keeping in Malawi”—2012, proffers an interesting history on why the country generally fares poorly when it comes to public record management. Lihoma observes that the Malawi Public Service Regulations, a collection of principles or guidelines for the civil service, was a renaming and revision of a similar document that was guiding the civil service before 1964. He points out a deliberate flow, namely the deliberate omission of orders which mandated public officers to exercise meticulous public record management. The predecessor guiding document had this component yet the new Malawi omitted it when the MPSR came into being on 15th June, 1966. Worse still, throughout the revisions to this document, none has seen any wisdom to include the record management component in the document.

One would question whether there could be a mechanism to force or encourage a government to start keeping its house in order as far as record management is concerned. In 2006, a constitutional court in Hungary delivered an interesting ruling on this. In Re The Constitutionality of Provisions on Record Keeping of Governmental Sessions, the court held that government is under the obligation to keep records for public information. It said this can be for a short or a long period of time. It said not to do so would restrict the people from accessing public information.

Another important instrument for ATI for a country with as low literacy rate as we are is introduction of some Adult Literacy Programme aimed at creating a sensitised citizenry able to access and use public information in exercising their democratic rights.

On fees to access the records
This is the norm in most jurisdictions though the point is that such fees should not inhibit access. In short, I do not see any reason why anyone should argue over this as though courts give people free services or even free photocopying.

On information being accessed online
This day and age it would be naïve of someone to claim they are not happy information will be accessed online. I thought people are moving away from the hard copy to online things? I do not see validity in anyone expressing worry over this. In fact, good ATI regime goes hand in hand with what we call E-Government where ICT is used to serve public interest through aiding in provision of goods and services to the people.

When the Government shows agitation over information, people should not get surprised; all governments live in fear of their acts falling into ‘wrong’ hands. Even the white, at Independence, showed us he can dread information falling into wrong hands. Lihoma quotes one white man, a District Commissioner, who confessed to receiving instructions from the seat of Government then, Zomba—advising all District Commissioners to destroy all government records under their custody days to Independence: The man, a former white colonial District Commissioner in the District of Nsanje had this to say in 2010:

We received instructions from the Secretariat in Zomba that we should destroy all the sensitive files to avoid the new government seeing them. You should have seen the bonfire behind the DC‘s office at the Boma – the files ere up in flames. I was personally there, the Police was there and other people gathered to see what was happening.

I think I should finish with making this observation clear—ATI is not a war between the people and their governments. The legislation serves many purposes as far as encouraging openness, transparency, accountability and citizen participation is concerned. It’s interesting the wide range of issues ATI addresses. The following court cases can testify to this:

In the CPIO, Supreme Court of India v Subhash Chandrah Agarwal and ANR (a 2009 High Court case), the Court held that asset declarations of Supreme Court judges should be disclosed if there is public interest in disclosure so long as there is an attempt to balance the interest in disclosure against privacy concerns.

It can also apply to cabinet ministers. In Centre for Media Studies and Peace Building (CEMESP) v Liberia Anti-Corruption Commission (LACC), the court held that asset declarations of cabinet members and their deputies shall be disclosed because public interest in the fight against corruption outweighs the harm the disclosure can cause to the individuals.

How about to Members of Parliament? Well, in Legal Defence and Assistance Project (GTE) Ltd v Clerk of the National Assembly of Nigeria, the Court held that salaries of MPs should be disclosed because that is not personal information.

Another interesting case is UK All Party Parliamentary Group on Extraordinary Rendition v Ministry of Defense [2011] UKUT 153 (AAC) where it was held the public had a right to access information concerning detention and interrogation policies because the people have to have assurances that detainees are not tortured.

The preserve of Access to Public Information is so huge, what the legislation provides is just a starting point. Most of the issues are as a result of court interpretation of issues or cases. The legislation covers even some negotiations between a public office and donors, information about public procurement, cabinet minutes if harm could not result after disclosure, et cetera. This is why I always insist that Malawians should not fear the so-called butchered Bill, let that Bill pass into law, for the proof of the pudding is in the eating.

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