Wednesday, 21 December 2016

Access to Public Information Legislation in Malawi: Time to negotiate for the final Legislative Rituals, time to mull seriously on Legislation Compliance



Thursday December 15, 2016 stands out as one of the most important dates in our history as far as efforts to create an open society in the country is concerned. On this date, somewhere about 8 pm, men and women entrusted with a constitutional mandate to make legislation on our behalf passed the Access to Information Bill, over a dozen years after it had been drafted.

Interestingly, most MPs from the governing Democratic Progressive Party—DPP—were absent, and attempts by the remnants therein to defer the debate to another date, proved futile and were thwarted outright. Eventually, the opposition used their numerical strength to carry the day, and so the Bill was passed. Truth be known here that not all MPs from the governing side had opposed to the passing of the Bill. In Malawi, a good rule of thumb when some MP is not in support of their party’s position on a particular Bill is to run away from commitment by not appearing on a day slated for debate. A similar thing happened one Thursday in 2002.

On that July 4, fifteen years ago, our Parliament went through some political litmus test. The event was to define whether we had indeed come of age to carry ourselves through the strenuous demands of democracy. This was during the reign of Bakili Muluzi (1994-2004). That Thursday (July 4, 2002) history was eventually made in the National Assembly when MPs defeated the Open Term Bill, a piece of legislation seeking to amend section 83(3) of the Republican Constitution to allow the President another term of office following the expiry of his ten-year tenure (two five-year consecutive terms) as provides the Constitution.

At the time, the governing UDF had 95 MPs and needed only 33 to have history turned in their favour, for with 33 they would make the two-thirds majority of 128 (i.e. 95 + 33) votes. A good 29 opposition MPs (19 from MCP, 10 from AFORD) and one independent MP voted pro-amendment, but a total of 59 opposition votes was enough to block it. If the governing UDF had extra 3 votes, it would have carried the day, and goodness knows what democracy would be like under such conditions. Today these three saving votes are proudly described as the three miraculous votes. I’m not sure where the three could have come from, but there was a total of 8 Members abstaining or absent. So, would the miraculous 3 come from the 3 MCP MPs who had abstained, or the 3 MCP MPs absent, or the 1 AFORD MP absent, or the 1 Independent MP absent? This is not to say our focus on the subject should solely be confined to the Members who had abstained or had absented themselves, for it is important to respect the 58 or 59 (36 from MCP, 19 from AFORD and 3 Independent) MPs who had actually voted against it. For a detailed discussion on this, see John Luwanda’s ‘Changes in Malawi’s Political Landscape between 1999 and 2004: Nkhope ya Agalatiya’ in Martin Ott, Bodo Immink, Bhatupe Mhango and Christian Peters-Berries (Editors): The Power of the Vote: Malawi’s 2004 Parliamentary and Presidential Elections, pp 49-86.

Well, remember I’m discussing the passing of the ATI Bill, and my focus is on a job that now remains unfulfilled on this legislation.

When the MPs passed it (ATI Bill), those in the opposition taunted those on the governing side, chanting Ailira! Ailira!, literary meaning ‘how that you mourn seeing it slipping through your fingers!’ It had been the same in 2002 when the Open Term Bid failed to go through—the news was greeted by wild celebrations. I remember one of our bosses in the newsroom then, Late Prescott Gonani, saying, “I hear there were wild celebrations there!”

Interestingly, after the Open Term Bill was rejected (that July 4), on October 7 that same year, the President dismissed Deputy Transport and Public Works Minister, Jan Sonke, after the law-maker had written the President, warning him they were wasting resources for nothing because the Third Term Bill (they wanted to reintroduce it as Third Term Bill) would never pass through in Parliament. Muluzi had all along hailed Sonke (a white Malawian national of Dutch descent) as mzungu wambeu, literally meaning the remaining white seed, but after that honest letter, Muluzi’s turned on him, making fun of his skin colour. It is said there are no permanent enemies in politics; well, there are no permanent friends either, and I’m speaking from experience.

And this week, only four days or so after the Members passed the ATI Bill, Malison Ndau, the Information Minister, has been dismissed. A Church Reverend, the man has sought solace in GOD, quoting Galatians 4:16: Have I therefore become your enemy because I tell you the truth?

Some say the dismissal has to do with his comments that he hoped the President would assent to the Bill in time. The man has since been replaced by Nicholas Dausi, the man who was heading the National Intelligence Bureau. I personally feel Dausi’s redeployment a piece of good news. I had lots of questions why Dausi was given that (NIB) post in the first place. Dausi once closely worked for Dr Banda, Malawi’s first head of state, and Dr Banda’s atrocities towards those deemed dissenting are well-documented. At the same time, I’m not happy Dausi has become the centre of the DPP’s communication machinery.

Access to public information legislation attempts to create an open society. I know this is a different era, but often the past is there to warn us about the future. According to Jack Mapanje, the MCP had subsisted on orality, despising the permanent form—written culture (see ‘Afterword’ in Harri Englund’s A Democracy of Chameleons: Politics and Culture in New the Malawi. In fact, Mapanje takes issue with this culture because it exonerates where it should convict. Access to public information is a system that believes in the power of documenting, managing, keeping and accessing information in accessible formats. Perhaps we should wait and see.

Many of the comments I have seen on the passing of the ATI Bill have tended to praise the opposition for not sleeping on their job. But it should be pointed out that the Bill was passed while most members from the governing Democratic Progressive Party were absent. Such absences could be genuine or just a mere ploy never to be seen belonging to those hindering progress. I have already discussed to some length how in 2002 a similar strategy had been used to foil the Open Term Bid.

Am I underrating the role the opposition played on this? No, not at all. But hailing the opposition for a policy instrument that is in DPP’s manifesto seems misplacing things somehow. At the same time, taunting the ruling party because it failed to frustrate the Bill is at best unsettling for me. This is because in terms of how a policy instrument (and legislation is a policy instrument) should be handled, this was a very bad manner of presentation. In public policy there is nothing more dangerous than introducing a policy devoid of substantial consensus. By portraying the passing of the Bill as largely the work of those in the opposition, we effectively deprived the whole thing of this important ingredient of consensus and ownership. This was not a war; this was simply us as Malawians taking responsibility and doing that which will make our democracy tick with newer level of energy.

All the same it was passed though the bigger hurdles lie ahead, that is to say, the question remains whether the President will straight away assent to it or withhold it. I pray he does assent to it because that will symbolize a great stride in the positive direction in our democracy. By doing that he will also win a lot of sympathy against those hoping to use the instrument for purely self-interest and political motive.

From now on, I will advance on a presumption that our President will assent to this Bill. In this regard, I want to look at what we should do to ensure timely and successful implementation of this policy instrument. I’m saying this with an understanding that ATI goes hand in hand with ancillary instruments and projects such as a vibrant body to oversee the implementation in terms of access and use; robust ICT system; comprehensive public document (record) management; robust adult literacy programmes and a clearly set-out compliance mechanism.

I can never discuss all the factors above; my interest is mostly on the last one—compliance.

Well, literature, history and daily events in life are full of examples of man’s failure to plan beyond the point of initial accomplishment. In Julius Caesar, a play by William Shakespeare, conspirators kill Julius Caesar. They think it’s mission accomplished. But as soon as Caesar falls, they realise they did not plan for life after the death of Caesar. As a result, there is no direction on who should give direction—Brutus says one thing, Cassius another. Their followers are not sure of direction either. What follows is chaos after victory, something Mark Antony seizes on to inflame the mob into a rebellion against those who had made Caesar bleed.

Southern Sudan, a nation that was fighting for independence from the north, fell into chaos soon after attaining independence when leaders began to fall on each other. Many times people tend to plan to some point and when eventualities come, they have nothing to fall back on. This happens even in criminal settings; there are times when people plan an evil and fail to plan what the setting would be like if that evil fails.

In The Republic v MacDonald Kumwembe, Pika Pascal Manondo and Raphael Kasambara, the Judge, Honourable Justice, Dr Michael Mtambo, when convicting the three said the following:

“The DPP (Director of Public Prosecutions) further observes that between 12.18 and 12.20, there were 9 SMS’s sent by the 3rd accused to the 2nd accused while he was supposed to be busy in a high level meeting in Salima. Between 12.24 and 12.29, there were 5 SMS’s exchanged between the 2nd and 3rd accused. This totals 14 SMS’s in a space of 11 minutes. The 3rd accused has admitted that there was indeed a flurry of SMS’s but suggested an explanation in cross examination to his co-accused. On the part of the state, this is indicative of something that seriously worried the accused, the shooting of Mr Mphwiyo. That he had survived to tell the story.” (Emphasis mine.)

What the Judge was saying was that the DPP was suggesting that after the shooter had administered the shots, they were all in the belief that there was no way the victim would survive to tell the tale, and that a flurry of SMS’s was indicative of a rude awakening of realities that Mphwiyo had indeed survived. One would equally suggest that perhaps they had not planned that there would be another phase to deal with after the shooting. But reality had presented them with something else, a task not planned for initially.

In short, in whatever situation or setting, people ought to plan thoroughly, and this is more so in the policy process. For your information, I like to discuss Bills in terms of policy rather than legislation. As far as I am concerned, the two are different and they focus on two different yet related results.

In public policy, policy analysts and planners (which include economists, et cetera) sit down to build a country’s future in terms of what it should achieve in individual sectors. This is based on various guiding documents such as strategic plans, a country’s vision or poverty reduction or alleviation documents. To achieve that goal, they set objectives. To achieve those objectives they seek an instrument to guide them to operate within the confines of the Constitution. This is where legislation comes in. When I am dealing with public policy, I do not consider law first, no, I consider it an instrument to help me achieve some goal.

Public administrators consider law an instrument to help run the public sector. Lawyers often consider it an instrument to punish those who fall outside its dictates. In public policy, when, through monitoring or evaluation or monitoring and evaluation you realize a policy instrument is failing, you go back to the drawing board to improve on it. Law is rigid; to do that you have to go back to Parliament or it should be declared invalid as per section 5 of the Constitution. The result is when it fails and you cannot go back to Parliament you keep quiet as though the law is still carrying its sting.

The greatest danger in Malawi is that instruments put in place to help run the public sector tend to be mistaken for the whip, i.e. law for punishment. I should give an example of the declaration of assets by public officers as provide sections 88A and 213 of the Constitution—of course, plus the Public Officers (Declaration of Assets, Liabilities and Business Interest) Act of 2013.

In Public administration or public policy, declaration of assets is an instrument to help create open, transparent and accountable civil service (including the people serving therein). It is not alone; it is complimentary to other equally important instruments such as access to public information. When the people were asked to declare their assets, the approach used was taking the law for a lash, where ‘threats’ form part of the trade. The danger with using ‘threats’ is that when the threat fails to work (because there is a limit to which law can work), the law becomes exposed. In Malawi, people were asked and many complied. The language that was coming was purely from ‘use of an instrument as a whip’—“If you don’t declare, you’ll lose this and that, et cetera.” What happened next? Big fish were caught in the net and they had ‘an explanation’. How on earth could we accept their explanation and refuse someone’s explanation simply because he has no name. That’s the danger when legislation is considered purely in terms on law. I personally prefer to consider a piece of legislation such as declaration of public assets and ATI in terms of instruments to run the public sector. If this was an approach, the DPP government would never feel apprehensive to pass this Bill into law, and until we work hard to convince them we do not intend to drive them into the sea, there is a risk of someone sabotaging the legislation.

What the MPs did soon after passing the Bill gave me the impression they believe this an instrument to catch someone, a kind of whip, sniffer dog, hound, an instrument of punishment. This is where we miss it all. And this is the very reason I laugh when people celebrate that ATI is in safe hands being under the Malawi Human Rights Commission. Those who say this have never taken time to analyse the MHRC and successes they have scored on the ground or where their mandates end. I do not care whether it has worked elsewhere; a policy will work depending on context. The moment you devise your instruments with eyes set elsewhere you risk producing an instrument that will be available in name only.

Malawi has some of the finest policy and legal instruments on the Continent yet compliance at the implementation stage remains a challenge. The result is that, working under an illusion that things work better with more and more policy documents as though solutions come from the documents per se, we keep churning more and more policy documents, some almost repeating what others are already addressing on the ground.

Let me take the example of section 32 of the Corrupt Practices Act which empowers the Anti-Corruption Bureau (ACB) to investigate any public officer where there are reasonable grounds to believe he or she maintains a standard of living that does not correspond with his or her earning, or has property or resources one cannot properly explain its past or even present source, et cetera. I personally consider section 32 of the Act one of the best gifts our Parliament gave this country yet nothing of this sort happens on the ground—there is little or no compliance on the ground. This is because when you take a piece of legislation purely as a whip, you encounter a power (often a politician) on whom the whips never work. With only s. 32 of the Act, we could stop any public thief right in his tracks and prevent a catastrophe of thievery as the one witnessed at Capitol Hill. Unfortunately, this has not been the case. So one can see the problem isn’t that we do not have some of the best legislation; it is that we focus on wrong things at implementation. I just read an article today where Henry Kachaje was expressing his surprise that the ACB still exists. The problem isn’t the ACB; it is the way we have accepted to implement our pieces of legislation.

People must learn to distinguish using an instrument as a regulatory and biting tool and using it as a facilitating mechanism. The best is to strike a balance and never to emphasise one at the expense of the other. This is the same problem that happened when the Office of the Ombudsman just came in. People who felt the courts were for the rich thought finally the law was coming to their side. They soon realized the Ombudsman cannot conduct trials and its judgment is subject to other review mechanisms.

The question I would ask the media is: Where would you have the power to demand something, at MHRC or at some other public office? In Malawi, whenever lawyers say something people tremble. This is because we have a very sick system where people do not bother to know the basic law. It’s pathetic that sometimes people give in even where they are in the right.

In other countries, even issues of contempt of court are challenged because the court too must have a limit to which they can impose something; the court is an independent referee and should not just do things arbitrarily, without justifiable reasons. Remember courts are human beings first. There can be times when they can be motivated by something else. If you think I’m telling a lie, read Attorney General for Hong Kong v Reid where the country’s Deputy Public Prosecutor and Acting Director of Public Prosecutions was receiving bribes to spare some criminals from prosecution.

What I am saying is that a country can have the best policies or legal instruments in form of Acts of Parliament but still be unable to achieve the goals intended (in terms of policy) or unable to address or heal the mischief intended (in terms of law or Act of Parliament). The legislation can still encounter another hurdle in the name of compliance.


According to Reducing the Risk of Policy Failure: Challenges for Regulatory Compliance, (OECD 2000: 7), there are three areas to consider when discussing the question of compliance or non-compliance of a policy instrument or a piece of legislation. The first area has to so with the degree to which the target group knows of and comprehends the rules; second, the degree to which the target group is willing to comply—either because of economic incentives, positive attitudes arising from a sense of good citizenship, acceptance of the policy goals, or pressure from enforcement activities. Lastly, it is the degree to which the target group is able to comply with the rules.

In short, organisations and individuals who fought hard to see the ATI Bill pass into Law now have a duty to ensure that, first, the people understand this legislation. Going by the various comments by contributors whenever issues ATI are under discussion, one can tell that our level of understanding of this legislation is far from perfect. Second, they work on help the people develop values to increase their level of willingness to comply.

Compliance does come from a number of factors: enforcement (i.e. lashing one into submission) and acceptance of the policy goals and a sense of good citizenship. Access to public information will be a success if the people believe in its good, and if, on their own, they can strive to be part of the openness revolution; it will not achieve its goals by beating people into submission. That has failed elsewhere in our laws though people do not want to learn that the best way to give a people a piece of legislation is to persuade them on its good, and on the responsibility they have to fight for a better environment or setting for their sake and that of the generations to come. Access to public information is not there because there was Cashgate at Capitol Hill (the spelling is intended because I do not believe Kamuzu meant ‘capital’).

In order for the people to know and comprehend the rules, there is a need to go back and inform them on why we have this legislation in the first place. Many think the legislation is there to catch those living on thievery; that is just part of it, but it is there because it will facilitate a form of governance that would mean little if implemented without this framework—ATI. Put simply, the form of governance now not only emphasizes improvement in the civil service as a structure, but also in the way the civil service relates with organisations and other stakeholders outside it. Because of this horizontal (organization-organization or organization-citizen) rather than vertical (change or improvements within the civil service), the need for information has become the centre of the partnership in order to breach the boundary.

Malawi should have done this right at the drafting stage, because the best time to do it is right at the policy drafting stage.

The importance of ATI in enhancing citizen participation is often associated with the benefits the citizens derive from the partnership with their government as though government does not derive any benefit from that relationship at all. It should be pointed out that government too does benefit substantially from the relationship enhanced by ATI. For example, government can learn on what the citizens desire. This can help it in initiating pro-people policies, which would very easily be accepted by the people. This can also reduce incidence of litigations and embarrassment on the side of Government. There have been occasions when the Government has embarked on some project only to get embarrassed when the people disown and challenge Government for bringing them a raw deal. In a context where Government is able to listen and discuss with the citizenry on important policy decisions, incidence of friction can be reduced. Above all, a government that implements a decision that has the people’s approval wins a vote of confidence of sorts.

I read an article ‘Nigerian FOI Law not effectively implemented’ (available at www.freedominfo.org) which I feel has something we can learn to avoid a repeat of similar mistakes. The article presents the situation on implementation of ATI in Nigeria. It says the country had adopted the legislation in 2011, but it is still experiencing problems at the implementation stage largely due to the entrenched culture of secrecy there as witnessed by the country’s Official Secrets Act, that the people do not make request for information because they believe the public officers in whose custody the information is are not willing to disclose the information, that most offices still do not have procedures, processes and facilities recommended for them to.

I expect Malawi to encounter similar problems and even more because our eyes were mostly on passing the Bill and not beyond that. I can also foresee the Official Secrets Act playing the hindering to access. However, I expect some new form of debate on the relevancy of taking the Official Secrets Act wholesale knowing that the legislation was passed way back before the First World War and the British were mostly using it to check against espionage (mostly by Germany agents). That threat not there today for a developing nation, its level of application ought to be reduced unless the situation justifies otherwise.

The Bill was passed, yes, but it is too early for a victory parade in a battle only half-won, for we have to negotiate for the final legislative rituals and of course, the biggest of all the hurdles—legislative compliance. Above all, the situation now requires sobriety from all sides so that we desist from portraying the issue as though it’s a trap, for ATI is never one and has never been one. Whenever it traps someone it is because they deliberately worked to flout that which all agree to keep holy.

According to sections 73 and 74 of the Constitution, the Bill passed will become law after the President has assented to it, and it is published in the Gazette. I am sure the President will do the needful, and I wish him the best of luck. Lastly, my advice to all is: avoid inflaming tempers; let us, for the love of our country, ensure the legislation will be for the benefit of the people through enhanced public goods and service delivery. No one loses when the beneficiaries are the public.

Cases
The Republic v MacDonald Kumwembe, Pika Pascal Manondo and Raphael Kasambara, Criminal Case No 65 of 2013

Attorney General of Hong Kong v Reid [1993] UKPC 36, [1994] 1 AC 324

References
Englund, Harri (Ed) (2002). A Democracy of Chameleons: Politics and Culture in the New Malawi. Claim (Blantyre) and Kachere (Zomba).

Luwanda, John, (2004) ‘Changes in Malawi’s Political Landscape between 1999 and 2004: Nkhope ya Agalatiya’ in Martin Ott, Bodo Immink, Bhatupe Mhango and Christian Peters-Berries (Editors): The Power of the Vote: Malawi’s 2004 Parliamentary and Presidential Elections, Zomba: Kachere Series.


Muula, Adamson S. and Chanika, Emmie T. (undated) Malawi’s Lost Decade: 1994-2004. Publishers and city not indicated.

‘Nigerian FOI Law not effectively implemented’. available at www.freedominfo.org accessed 20 December 2016.

OECD 2000 Reducing the Risk of Policy Failure: Challenges for Regulatory Compliance.

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