Saturday, November 16, 2019

Presentation to FCO Team


Government’s Draft New Constitution for Anguilla of 10 November 2019
Presentation by Don Mitchell, CBE, QC, former chair of the Constitutional and Electoral Reform Committee, to the Foreign and Commonwealth Office Negotiating Team (“the FCO team”)
On 10 November 2019 the Government of Anguilla published on its website its proposals for a draft new Constitution for Anguilla.  This new draft drops several earlier Government proposals for amendment, and it introduces new ones.  At no time has any effort been made by Government to explain to the people of Anguilla the changes that are proposed.
The FCO team begins consultations with Anguillians on Monday 18 November 2019.  Few persons will have had an opportunity to study Government’s new draft Constitution prior to the start of negotiations.
It is regrettable that Government made no effort to constitute a national “negotiating team” until 14 November, four days before the meetings with the FCO team begin.  This is an impossible timetable for a disparate group of people to meet.
I therefore submit these preliminary observations for the assistance of persons who will engage in these negotiations.  I apologise in advance for any errors or omissions that may be discovered.  This is due in part to the hurried preparation of this presentation.
The framers of the 2017 Report to Government (“the 2017 Report”) attempted to reflect public concerns in the draft Constitution and supporting legislation they produced.  These concerns were that the Constitution and other legislation need to be updated to increase and improve accountability, transparency and integrity in the public affairs of Anguilla.  The two main public demands for constitutional and electoral reform were improving democracy and improving standards in public life.
Improving Democracy:  The Anguillian public is insistent that constitutional steps be taken to reduce the “democracy deficit” so evident in the constitutional and electoral laws and procedures in Anguilla.  These deficits are detailed in both the 2006 and the 2017 Reports of the Constitutional and Electoral Reform Commission and Constitutional and Electoral Reform Committee.  The 2017 Report contains dozens of proposals that, if enacted, will contribute to this end.
The recently enacted Elections Act, 2019 (the 2019 Act) omits three of the most sincerely desired and widely welcomed reforms to our election procedure originally included in the draft Constitution that formed part of the 2017 Report.  These omissions were:
(1) the revision of the Voters’ List, widely perceived to be stuffed with unqualified voters, by holding a new enumeration exercise,
(2) increasing the number of districts or constituencies from seven (7) to nine (9); and
(3) introducing campaign financing regulation.
Anguillians urge that the opportunity should be taken to restore them in any new Constitution for Anguilla.  The accompanying Elections Act 2019, passed recently and which omits these provisions, should be revised.  Government’s defective Anguillian Status Commission Bill, recently published on its website, must be properly re-drafted before it is enacted.
While some of the Government-proposed changes to the draft Constitution recommended by the Constitutional and Electoral Reform Committee contained in its 2017 Report are acceptable, others are more questionable.
Improving Standards:  The second main thrust of the 2017 Report was to insist on putting binding procedures in place to raise the perceived present low standard of integrity in public life.  The lack of any effective institution of good governance in Anguilla (besides the costly one of recourse to the Court) is felt to be a major contributor to our failure in past decades to develop high standards of governance in public life.  An important aspect of these proposed reforms is the strengthening of provisions for the management of public finances.

Any proposed new Anguilla Constitution that is negotiated with the FCO team must be submitted to the people for their acceptance before the draft is signed into law.  That is the only sure way to achieve a peaceful acceptance of what up to now has been a highly unsatisfactory and acrimonious process.  That acceptance or otherwise of the new Constitution can be easily shown by a yes/no referendum.
I now deal seriatim with the various sections in the Government’s draft Constitution which appear to be problematic in relation to both the democratisation process and the effort to improve public standards:
(1) Section 14A will expressly limit the right to marry to a man and a woman.  Same-sex marriage will be prohibited.  It is my opinion that such a limitation is morally wrong.  Concepts of fairness, equality and freedom from discrimination lean to affording the right to all of us, including our gays and lesbians.
(2) Section 35 now provides for a minimum of five (5) ministers of government.  There is no guarantee that the number will be increased to the recommended six (6).  The minimum should be six (6) with a transitional provision to cover the period before the Electoral Boundaries Commission does its work.  This has become necessary since the Amendment Order in Council and the Elections Act of earlier this year.
(3) The proposed alteration to section 42(1)(a) is in error in giving the Governor responsibility for foreign affairs “except for taxation and the regulation of finance and financial services”.  Taxation and the regulation of finance and financial services are not matters of external affairs.  They are intrinsically internal affairs.  In any event, the original draft did not give the Governor responsibility for finance or financial services.  All matters of public finance are governed by Chapter 10 which contains mandatory standards and procedures that must be followed by Government.  Financial services are to be the responsibility of the Financial Services Commission, a constitutional body with independence of both the Governor and the political directorate.  This is the preferred way to ensure independence of such important services.  Any attempt to bring financial services under ministerial control exposes Anguilla to the risk of corruption and mismanagement.
(4) Section 53 reduces the minimum number of elected members of the Assembly to eleven (11).  The minimum should be thirteen (13) with a transitional provision to cover the period before the proposed Electoral Boundaries Commission does its work.  This has become necessary since the Amendment Order in Council and the Elections Act of earlier this year.
(5) The proposed revision of section 54 removes the qualification (for election to the House of Assembly) of residence in Anguilla for three (3) years prior to nomination.  A majority of Anguillians thought this was an important qualification to ensure candidates are familiar with Anguillian society and rules.
(6) There is a concern that section 65, which deals with the “Right to vote at elections”, bears a note that it is “under consideration in relation to residence requirements”.  The original section was carefully drafted to ensure that only Anguillians ordinarily resident in Anguilla would be qualified to vote.  There are presently thousands of persons who have never been resident in Anguilla, or who have long emigrated from Anguilla, to be found on the Voters List.  Under present rules they can never be removed from the List until they have died.  A new Enumeration Year was proposed to clean up the List.  Government has without explanation removed from both the Constitution and the recent new Elections Act any provision relating to a new Enumeration Year.  The AUF Administration appears to be insisting on retaining the present fraudulent List.
(7) Section 66 of the original draft Constitution, which provides for laws as to elections, has been altered without explanation to remove a constitutional requirement for the regulation of campaign financing.  This is a retrograde proposal.  The newly passed Elections Act also excludes it.  Anguillians are agreed that the present system of unregulated spending on election campaigns is an encouragement to bad behaviour.  This reform is part of the effort to improve standards in public life.  Removing from the Constitution even the possibility of introducing constitutionally protected campaign financing regulation into our election laws is a retrograde step.  It is not in accordance with the thrust of the new Constitution to promote higher standards of public life than presently exist.  Without such constitutional protection, any stand-alone statute would be problematic.  The new Elections Act needs to be amended or replaced.
(8) One of the principal reforms originally proposed is that the House of Assembly should consist of nine (9) district representatives and four (4) members elected at large, resulting in a total of thirteen (13) elected members.  Not only would this increase in numbers encourage deeper debate on legislative proposals, it would ensure that with a Cabinet of six (6) members, the Assembly would not be dominated by members of the Executive.  Government now proposes to amend the original section 67 (Elected Members) to remove the provision for Anguilla to be divided into a minimum of nine (9) electoral districts.  It proposes to retain, at least for the present, the existing seven (7) as the minimum number.  While it is appreciated that the wording permits the future expansion of the Assembly, it is felt that it would be preferable for the wording to reflect the recommended minimum of nine (9) districts with a transitional provision.
(9) Chapter 9 concerns institutions protecting good governance.  This is the principal measure for ensuring high standards in public life.  The Chapter heading in the Government draft bears a note that “the number and types of commissions and commissioners have not yet been agreed.”  It would be regrettable if there was any reduction in the number and types of Commissions or Commissioners.  The original draft of the Constitution already gives flexibility in suitable cases for combinations to be made.
(10)     Section 111 (dealing with the need for disclosure to the Assembly of any proposal to dispose of or deal in public assets) bears a note that it is still “under review”.  This provision was viewed as important by many Anguillians, and it would be regrettable if it was limited in any way.
(11)     Chapter 10 deals with Public Finance.  It is a concern that the Chapter heading in the Government draft Constitution bears a note that the Chapter is still “under review”.  The Chapter was originally designed to be a principal tool for ensuring high standards in matters of public finance.  The Chapter is important in its entirety. The whole point of Chapter 10 is,
(i)           to improve standards of public life in the area of public finance;
(ii)         to take the present rules for the management of the public finances out of common legislation such as the Financial Administration and Audit Act, and the Fiscal Responsibility Act, and enshrine them in a Constitution.  The present Acts are, according to the Chief Auditor, routinely ignored, and
(12)     to introduce into the Constitution most of the provisions of the originally UK-proposed draft Anguilla Public Finance Order 2015.  As a result of negotiations between the FCO and Government, this was never brought into effect as an Order in Council.  Any attempt to weaken Chapter 10 is to be strenuously opposed.
It is much to be hoped that as part of this reform exercise, the FCO will ensure that the Acts and supporting regulations necessary for giving effect to the Chapter 9 watchdog institutions be prepared and put in place immediately after the new Constitution comes into effect.  This is essential if there is to be any improvement in standards of public life in Anguilla.  These include (a) an Integrity Commission Act, (b) a Freedom of Information Act; (c) a Public Service Commission Act; (d) an Appointments Commission Act; (e) a Complaints Commissioner Act (or Ombudsman Act); (f) an Act for the Remuneration of the Speaker and the Members of the House of Assembly; (g) an Anguillian Status Commission Act; an Electoral Boundaries Commission Act; and a new Elections Act.
These provisions in the Constitution depend for their efficacy on the related Acts and Regulations being passed into law.  Without them, no substantive reform will have been achieved either by merely mentioning them in the Constitution or by enacting inadequate versions.
14 November 2019