16
to some deficiencies on polling day. As at yesterday Sunday, 15th October,
2017 our two Call Centres received a total of 1086 incident reports. 784 of
these incidents were NEC related while 302 were security related. ... The NEC
related calls were on issues of identification of voters polling places (voters
who could not identify where they [are] supposed to vote), NEC changing
precinct locations, thereby confusing voters with large number of invalid votes
..., many of the polling precincts were in schools which were inaccessible to
the physically challenged and the elderly, the late arrival of ballot boxes and
voting materials in some"
14. It is rather strange, and unlawful that although the NEC is said to have
quarantined 14 ballot boxes, meaning that the ballots of many voters have not
yet been counted, the NEC has announced the final results of the Elections. In
addition to the other reasons herein stated, complainants also challenge the
results of the election on that basis.
The October 10 elections did not pass the minimum standards required for
free, fair, and transparent elections. These elections were characterized by
gross irregularities and fraud, which undermined the integrity of the elections
and deprived thousands of Liberians of their constitutional right to vote. The
violation of the Constitution and laws of Liberia, and the pervasiveness of the
fraud and gross irregularities throughout the electoral process warrant a rerun
of the Elections, and the complainants so pray.
WHEREFORE AND IN VIEW OF THE FOREGOING, complainants pray that the
results of the October 10, 2017 Elections be annulled, and a rerun be ordered,
in order to ensure that fair and transparent elections are held in accordance
with the Constitution, Elections, and other laws of Liberia, and that the Board
of Commissioners will stay the Second Round/Run-off, as announced by the
National Elections Commission, and grant unto complainants such other and
further reliefs, as may be provided in law and equity.
RESPECTFULLY SUBMITTED:
Complainants, by and thru his Legal Counsel,
Dated this 23rd day of October, A. D. 2017.”
The document quoted above constituted the complaint filed with the
NEC by Brumskine, Karnwea, the representative candidates fielded by Liberty
Party and Liberty Party itself. The thrust of the complaint, upon which the
complainants sought effectively the nullification of the October 10, 2017
elections and upon which they prayed the NEC to conduct a re-run of the said
elections, is three-fold: (a) that the electoral process and the acts of the NEC
and/or its representatives violated the constitutional and statutory rights of
voters and deprived them of the right to vote; (b) that there was massive
fraud perpetrated by the NEC and/or its representatives in the conduct of the
elections; and (c) that there were gross irregularities committed in the course
of the conduct of the elections. The contentions can be summarized as
follows: (a) With respect to the first contention that the electoral process and