important and powerful political leaders of the Republic of Guyana. In this sense, Article 161(2), whilst clearly not a convention in the classical sense of the term, being a provision in a written Constitution not even adorned by an ouster clause, is patently in the nature of a convention or of a high political question. In these circumstances, the Court should be slow to impose constructs which exert Lilliputian constraints on the policy discourse undertaken by the Republic’s political giants unless and until such constructs and constraints cannot be constitutionally avoided. JUDGMENT OF THE HONOURABLE MME JUSTICE RAJNAUTH-LEE, JCCJ: Historical evolution of Article 161(2) [36] In the appeal of The Attorney General of Guyana v Cedric Richardson,13 Sir Dennis Byron, then President of the Court, accepted the Report of the Constitutional Reform Commission presented to the National Assembly of Guyana on 17 July 1999 as an authoritative source of the facts stated in it.14 The Report records the political turmoil and racial violence which have been features of Guyana’s political landscape.15 [37] In 1986, the Council of Freely Elected Heads of Government (“the Council”), was formed following a Consultation at The Carter Center of Emory University on “Reinforcing Democracy in the Americas”. From September 1990, the Council began working with the people and political leadership of Guyana to construct a democratic foundation for the country. One of the objectives of the Council project in Guyana was to ensure that the general elections of October 1992 were free and fair. The Council was headed by former President of the United States, Jimmy Carter, and included several distinguished leaders, in particular, Mr George Price, then Prime Minister of Belize. In its Report entitled “Observing Guyana’s Electoral Process 1990-1992” (commonly referred to as “the Carter Report” or “the Carter-Price Report”) several 13 [2018] CCJ 17 (AJ). Ibid, [31]. 15 Report of the Constitutional Reform Commission. 14