Ghana 2011

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Ghana 2011

Report on Laws and Regulations Governing Civil Society Organizations in Ghana

Prepared by: Victor Brobbey Research Fellow, CDD-Ghana



History and Context

Ghana has a long tradition of active civil society engagement. By 1897, civil society organizations (CSOs), such as the Aborigines Rights Protection Society, became some of the earliest advocates for the independence of Ghana (then called the “Gold Coast”) from British rule. In the post-World War II period, a number of volunteers, farmers, trade unions, religious groups and town improvement organizations and associations served as important organizations in the struggle for independence. The event that many believe precipitated the drive towards independence was the 1948 violent suppression of a demonstration conducted by the Gold Coast Ex-Service Men’s Union, a noted CSO. In addition, some of the major political parties that emerged when pre-independence colonial authorities opened the ‘democratic space’ began as civil society organizations.
Despite the number and range of CSOs that have existed historically in Ghana, their actual influence in society and on public discourse has often been a function of the amount of political space they have been given to operate. Since independence in 1957, Ghana’s record as an open, liberal democratic state has been mixed. The Independence Constitution of 1957, which created British-style parliamentary and legal institutions and processes, was replaced with the Republican Constitution in 1960, which designated the role of an executive president. Kwame Nkrumah, the country’s first president, worked quickly to amend the constitution to abolish opposition parties, and gave himself the power to override acts of Parliament and dismiss judges. Because of his actions, Ghana became a single-party state by 1964. A military coup in 1966 ultimately resulted in the abrogation of the 1960 Republican Constitution and the promulgation in 1969 of a new, more liberal democratic constitution with a Bill of Rights. However, the 1966 coup was the first in a succession of military coups and regimes punctuated by brief periods of constitutional multiparty government over the next several decades.[i]
Nonetheless, Ghana has managed to remain relatively stable since the promulgation of the 1992 constitution and the advent of the Fourth Republic. The transition to democracy in 1992 saw the metamorphosis of the Provisional National Defence Council (PNDC), the last military junta, into a political party, which was elected to office as the National Democratic Congress (NDC).
Ghana is a unitary state governed by common law. It has remained politically stable through five presidential and parliamentary elections (1992, 1996, 2000, 2004, and 2008), and each poll has generally been considered an improvement over the previous one. Ghana has also undergone two electoral transfers of power from one party to another (2000 and 2008), making it unique among African democracies. In addition to this, the 1992 constitution – the country’s longest lasting – created a very progressive rights regime for the protection of civil society. It guarantees freedom of speech, freedom of thought, conscience and belief, freedom of the press and other media, freedom of religion, freedom of assembly, freedom of association, freedom of information and freedom of movement[ii]. Arguably, the key freedoms concerning CSOs are listed under Article 21:
All persons shall have the right to:
  • freedom of speech and expression, which shall include freedom of the press and other media;
  • freedom of thought, conscience and belief, which shall include academic freedom;
  • freedom to practice any religion and to manifest such practice;
  • freedom of assembly including freedom to take part in processions and demonstrations;
  • freedom of association, which shall include freedom to form or join trade unions or other associations, national or international, for the protection of their interest;
  • information, subject to such qualifications and laws as are necessary in a democratic society; and
  • freedom of movement which means the right to move freely in Ghana, the right to leave and to enter Ghana and immunity from expulsion from Ghana.
Furthermore, Article 37 of the 1992 Constitution forces the state to enact appropriate laws to ensure “the enjoyment of rights of access to agencies and officials of the state” and “freedom to form organizations to engage in self-help and income generating projects; and the freedom to raise funds to support these activities.”
In spite of the clear wording of Article 37, no new laws have been enacted governing the CSO sector since the 1992 Constitution, though it is universally agreed that the legal regime governing the sector is antiquated.[iii] Currently, the law under which a vast majority of relevant organizations are governed is the Companies Code, Act 179 of 1963, Section 10, which allows for the establishment of Companies Limited by Guarantee (or “Guarantee Companies”) as non-profit companies. Other statutes that govern CSOs include the Trustees (Incorporation) Act, 1962 (Act 106), and the Professional Bodies Registration Decree (NRCD 143) of 1976. Organizations governed by these three statutes will be the primary focus of this report.
In addition, there are various other statutes, regulations and directives that impact the CSO sector directly or indirectly. While Ghana’s general human rights protection regime is relatively well appreciated by society,[iv] the laws governing the regulation of CSOs are less accessible, generally misunderstood by nearly everyone, including legal professionals.
Relations between CSOs and the government have evolved from being hostile and confrontational in the 1970’s and early 1980’s to increasing recognition of the role of the CSO sector as a potential partner. However, after political liberalization in 1993, the government of Ghana expressed concerns that Ghanaian CSOs, often operated without proper registration, tended to execute projects without consulting district and regional development planning authorities, did not submit required reports of their operations, and engaged in fraudulent practices regarding their tax exempt status. CSOs have a persistent fear that the GoG seek to curtail their autonomy and control the sector. As a result, the government instituted policies governing the sector without consulting CSO officials. The government has been generally uncooperative in providing assistance to support their activities. The current policies do not provide tax incentives for CSOs to adequately operate.
In 1993, CSOs opposed an attempt to enact laws that the government had envisioned for them. The opposition grew from the lack of collaboration between CSOs and government in creating the bill, and the fact that it contained provisions which threatened CSO independence. Among others, CSOs specifically objected to the creation of a National Council on NGOs headed by a Minister of State and dominated by government appointees with the power to steer CSOs and register or de-register CSOs who refused to cooperate with the government. The process of agreeing on an appropriate regulatory framework governing CSOs has been ongoing since 1993. Presently, the CSO community and the government do not appear to be close to agreement. The closest the parties have come to an agreement was in 2004, when government and civil society created the Draft National Policy for Strategic Partnership with NGOs. It was agreed that this draft policy document should form the basis for national CSO legislation. However, regime change and personnel adjustments at the relevant sector ministries stalled the agreement’s implementation. The most recent iteration of the CSO Bill departs from the agreed-upon framework in significant respects. 

The term “CSO” refers to a large number of organizations, including associations, societies, foundations, and non-profits. Most CSOs are registered as Guaranteed Companies under the Companies Code, voluntary associations under the Trustees Act, or as professional bodies under the Professional Bodies Decree[v]. Ghanaian CSOs work on a wide range of issues, including education, health, governance, and poverty alleviation.[vi] They have garnered a huge amount of development resources from both within and outside of Ghana, which supplement a wide range of public sector activities.[vii]  
Companies Limited by Guarantee are regulated by the Companies Code, Act 179 of 1963, Section 10. They are created by submitting registration forms with the Registrar-General’s Department (RGD) in Accra, and paying a filing fee of approximately US$100. This Department is empowered by law to register all private organizations in Ghana. A guarantee company is not registered with shares and is not permitted to create any shares. This type of company is therefore only suitable if no initial funds are required or those funds are obtained from other sources, such as donations and grants. The company is also not permitted to engage in trading. Moreover, guarantee companies are not permitted to pay dividends or return any assets to their members.
The Trustees (Incorporation) Act, 1962 (Act 106) provides that the “trustees of any unincorporated voluntary association of persons or body established for any religious, educational, literary, scientific, sports, social, or charitable purpose shall apply, in manner hereinafter mentioned, to the Minister for a certificate of registration as a corporate body.” Upon the grant of the certificate, the trustees shall become a body corporate by the name described in the certificate, have perpetual succession, an official seal, the power to sue and be sued in the corporate name as well as to hold and acquire property. The Act also provides that the income of organizations incorporated under this statute that are not derived from commercial activity should be tax-exempt. An application for registration under this enactment requires submission of documents that state the objects of the body or association, as well as its rules and regulations. 
A number of organizations are also registered under the Professional Bodies Registration Decree (NRCD 143) 1976.[viii]  An organization can register by submitting to the Registrar-General’s office the following:
  • (i) a copy of the body’s constitution;
  • (ii) a list of the body’s members with their qualifications and addresses at the date of application;
  • (iii) a statement of the body’s activities for twelve months immediately preceding the date of application, or a statement of its activities for the period during which it has been in existence (if it has existed for less than one year); and,
  • (iv) such other particulars as the Registrar may reasonably request. 
The constitution of professional bodies registered under this statute should include a statement of (a) the objects of that body, and (b) rules regulating discipline of members of the specific profession and the manner of enforcing such rules. 
Professional bodies registered under this statute can act as bodies corporate, and can sue and be sued, and hold and dispose of property. The statute allows for only one professional body per vocation. It also requires the professional body to have at least fifty members. The professional bodies, though not public agencies, therefore play an indirect gate-keeping role.[ix]
Though this statute permits the government to regulate and scrutinize registered bodies, there is in practice very little direct government involvement in the activities of professional bodies. It is unclear if such involvement would withstand constitutional inquiry.[x] The National Redemption Council, the military government that passed this decree in the 1970s, and subsequent military regimes placed a much higher value on involvement in the activities of these professional bodies than the current civilian administrations do.
All three kinds of organizations are treated similarly for tax purposes. The Internal Revenue Act of 2000 permits the exemption of income not derived from business activities.[xi] However, actually obtaining this exemption is a long and complex process. In 1997, the government suspended automatic tax exemptions for CSOs in response to suspected abuses and fraud in respect to the exemptions that were being received. Until then, the government had only taxed CSOs for staff income, and had exempted imports linked to CSO projects from customs duties. Today, tax-exempt status is granted on a case-by-case basis. Qualification as an exempt organization requires a fairly discretionary ruling from the Internal Revenue Commissioner. Thus, beyond the possibility of tax-exempt status, there is little advantage in incorporating under these organizational forms. 
One of the primary pieces of evidence required for tax-exempt status is a listing with the Department of Social Welfare (DSW) as a charity, interjecting another level of government bureaucracy. Registration with the DSW requires an exempt organization to show, for example, that it operates “within the framework of the National Development Policy.” In addition, the DSW requires a general account of the organization’s activities, as well as evidence that its members are able to manage and control it. Registration with the DSW also requires applicants to submit four copies of the Registrar-General’s Certification of Incorporation and four copies of the organization’s constitution and by-laws, as well as any brochure or newspaper reports on the activities of the organization.
There are relatively few barriers to the formation of CSOs.[xii] There are many single issue-based, unregistered advocacy groups that operate without any difficulties. There are no sanctions that exist merely for holding oneself as a ‘group’ or ‘organization’, and indeed, any such sanction would be a violation of the constitutional right to freedom of association. There are also very few barriers to the creation of non-profits. No initial capital outlay is required, beyond a filing fee of less than US$200 for Guarantee Companies. There are also no restrictions on the kind of persons that can be directors of CSOs.[xiii] However, there are some reports that bureaucratic barriers have been put in place to deny or to frustrate the creation of CSOs. It has been reported, for example, that an application for registration of a CSO to conduct research in national security and defense policy was turned down on the grounds that the subject matter was inappropriate for civilians. Also, it is widely believed that while the registration process itself may be relatively uncomplicated, the process of obtaining tax-exempt status is arbitrary and susceptible to negative political or pecuniary influences.[xiv] 

The internal regulations governing Guarantee Companies are liberal. No onerous reporting is required, beyond filing a yearly certificate with the RGD indicating that it has done nothing to compromise its status as a privately held entity by, for example, issuing shares. The Act provides that the Guarantee Companies shall be governed by their internal regulations, the contents of which are left almost entirely to the companies.[xv] 
Professional bodies registered under the Decree are more closely regulated. They are required to file yearly submissions, including a copy of their audited accounts, and an up-to-date list of their members. The Decree is particularly focused on the internal regulations of professional bodies having language allowing for errant members to be disciplined – a reflection of the fact that one of the primary motivations for passing the decree was to permit the ruling military junta, the National Redemption Council, to regulate and control professional bodies. The Decree also states that the educational and training criteria to qualify for membership into professional bodies shall be determined by the government, in consultation with the association.[xvi] 
The Trustees Act provides the most strictly controlled management of CSOs. Trustees can be chosen only if the government is satisfied that their appointments were procedurally proper. The Act also entitles the minister to require trusts to fill vacancies on their boards and even to appoint persons to boards via executive order. In keeping with the immovable property origins of this statute, there is also a requirement that an application for registration as a trust should contain “the date of, and parties to, every deed, will, or other instrument creating, constituting, or regulating the same, as well as a statement and short description of the land which at the date of application is possessed by, or belonging to, or held on behalf of the body or association.”[xvii] 
In order to obtain tax-exempt status, CSOs must file claims with the Department of Social Welfare (DSW). The DSW conducts annual inspections of the operations of CSOs, designated as "charities," by reviewing the annual reports they submit each March. However, the DSW lacks the capacity to conduct oversight. The requirement that CSOs submit annual reports of their activities and copies of their accounts is largely ignored. The capacity of the Registrar-General’s Department to enforce reporting requirements has improved in recent times, but is still weak. CSOs in Ghana have often been accused of lacking transparency and accountability, and not adhering to their non-profit objectives. There is some merit in these accusations. However, there have been few instances of CSOs being forced to wind up. 
CSOs have generally not spoken out if and when they have been subjected to government harassment.[xviii] However, successive governments have continuously expressed a strong interest in the sector’s activities, and have attempted to impact CSO discourse by co-opting existing civil society groups or by creating their own groups, Government-owned NGOs (GONGOs). An example of the latter is the extremely pro-government 31st December Women’s Movement, a gender-based NGO formed by a former first lady of Ghana. The 31st December Women’s Movement is an umbrella group of women’s organizations closely linked to the erstwhile military regime of the Provisional National Defence Council. While it has done some good work and has been instrumental in the passage of some important gender legislation, it has also had the effect of crowding out independent women’s organizations, starving them of funding and monopolizing key gender causes. State funds have been widely rumoured to have been made available to support the activities of the movement. Organizations such as the 31st December Women’s Movement, as well as the Confederation of Indigenous Business Associations, the Alliance for Change, the Alliance for Accountable Government, the Tertiary Education Networks of the various parties, and clubs representing various Nkrumaist groups – all represent various ways in which Ghana’s political establishment have attempted to use CSOs for political purposes. 

CSOs that are registered under the aforementioned statutes assume corporate status and engage in a wide range of activities, including property ownership and contract rights. CSOs are nearly unrestricted to criticize the government on a number of issues. There are a number of organizations that conduct advocacy on human rights and democracy issues. There are no laws restricting CSOs’ ability to participate in political or legislative activities. 
CSOs in Ghana have played an increasingly influential role in promoting national development and the public interest. Government policies, such as the Growth and Poverty Reduction Strategy I and II, understand the importance of CSOs to national development, peace, democracy, rule of law and human rights. Additionally, government policies identify the development of a credible legislative framework for strengthening and regulating the activities of CSOs as critical to development. 
In the early 1980s and 1990s, CSOs concentrated on delivering humanitarian relief services.[xix] The World Bank imposed structural adjustment programs that resulted in significant cutbacks in the government’s social service delivery capacity. CSOs attempted to fill the void, particularly at the community and district levels. Governance and rights-based research and advocacy think-tanks arose in the 1990s in response to increased political opportunity. Today, CSOs are strong participants in the public sector and the government regularly relies on their services in a wide range of areas. For example, the Domestic Violence Support Unit (DOVVSU) of the Ghana Police Service relies on the CSO Women’s Initiative for Self-Empowerment (WISE) to provide psychiatric counselling for victims of domestic violence, the International Federation of Women Lawyers (FIDA) to provide legal advice, and on various other CSOs to help provide victims with shelter and medical attention. Also, the legislative process often depends heavily on active participation of CSOs to conduct necessary research and review of pending bills.  Occasionally, CSOs initiate legislation, and the Attorney-General later takes over.[xx]
CSOs in Ghana often form issue-based coalitions. Recently, CSOs have collaborated on health care, the passage of a Right to Information Law, and “whistle blower” and disability statutes. The Ghana Association of Private Voluntary Organizations in Development (GAPVOD) is the largest umbrella organization for CSOs in Ghana, with 440 registered members as of 2005.[xxi]
Several CSOs in Ghana are affiliated with various international entities. The International Federation of Women Lawyers (FIDA) - Ghana, for example, is an affiliate member of the world body of women lawyers that was founded in Mexico in 1944. Ghana Integrity Initiative is a member of Transparency International. GAPVOD is also a member of the International Council on Social Welfare (ICSW). Indeed, most Ghanaian CSOs rely on foreign CSOs, foundations, and development agencies for their funding. CSOs are not required to seek permission from government agencies before they receive funding, or to deposit funds they receive in government owned banks. They are also permitted to bid for government contracts. In addition, the legal system does not place barriers against cross border financial inflows. Fund transfer regulations have recently become cumbersome and more strictly enforced, in order to address money-laundering concerns, rather than an effort to restrict the activities of CSOs.

Since 1993, the government and CSOs have had ongoing discussions to develop mutual understanding between them for an appropriate regulatory framework. It is important for the future growth of the sector that such framework at a minimum addresses the following priority areas: 
Establishing an Autonomous & Independent National Commission on CSOs
A commission providing oversight of the activities of CSOs is a necessity. The strategic and administrative functions of the Commission may include accrediting CSOs, maintaining a CSO registry, advocating for CSOs with regard to policy decisions, encouraging CSOs to fulfil their accountability and legal obligations, forwarding to the MMDE recommendations on tax-related exemptions, encouraging CSOs to develop a code of conduct for themselves, and generally supporting and strengthening CSOs. However, it is important that the Commission would be structured in a way that ensures CSO independence, while performing its administrative and policy functions. Though it is a public regulatory body, the Commission’s membership should primarily be drawn from CSOs. Government representation on the Commission should be kept to a minimum, and should include only government agencies whose activities bear directly on the operations of CSOs (e.g. the Department of Social Welfare and the Ghana Revenue Authority).
Granting Tax Exemptions to CSOs who Qualify under the Law
The regulatory regime shouldimprove the process of obtaining tax exemptions for CSOs, while preventing fraudulent abuse of tax relief and customs duties exemptions. A properly constituted NGO Commission would have the expertise and capacity to review CSO applications for tax exemptions and periodic reports. Such privileges would be granted in a transparent and accountable fashion.
Facilitating Collaboration Between CSOs & District Assemblies (DAs)
The state now realizes that CSOs are its potential allies. A new regulatory regime must necessarily increase the institutional arrangements that allow for greater collaboration between government and civil society. At the very least, structures should be put in place which require CSOs to inform local DAs that they are conducting activities within the District. CSOs and DAs are also encouraged to create a forum for regular dialogue, inform each other about their projects, and provide each other funding and technical assistance when possible. The 2004 Draft and National Policy for Strategic Partnership with NGOs also authorizes DAs to issue accreditation to NGOs on behalf of the Commission.
Addressing Internal Governance and Capacity Issues Faced by CSOs
An often made charge against CSOs is that they lack transparency in their internal operations. Because of this, a new legal regime should strengthen the internal regulation of NGOs. The weak oversight by the DSW, combined with relatively easy registration procedures at the RGD, have contributed to what is a vibrant but somewhat chaotic CSO environment. The charges of corruption and non-adherence to non-profit goals have harmed the image of the sector. It is also obvious that while CSOs are enthusiastic about participating in national decision-making and governance promotion, this enthusiasm is not always matched by an ability to source, analyze, and present objective evidence to back advocacy. The intellectual and technological resources available to CSOs are highly inadequate, relative to the number and range of issues that need research, monitoring, and policy advocacy in Ghana’s nascent democracy. 
Ghana needs CSOs to be effective development partners. Improved internal regulations and financial accountability will undoubtedly make Ghanaian CSOs attractive targets of support from both the international and local donor community and government agencies, and effective partners in the implementation of development policies and programs. 

*Statements and views expressed in this report are those of the author and do not necessarily reflect that of the World Movement for Democracy, the National Endowment for Democracy, or the International Center for Not-for-Profit Law.

[i] The military governments were the National Liberation Council (1966–69), the National Redemption Council (1971–75), Supreme Military Councils I and II (1975–79), the Armed Forces Revolutionary Council (June–September, 1979), and the Provisional National Defence Council (1981–93). The short-lived civilian administrations were led by Prime Minister Kofi Abrefa Busia of the Progress Party (1969–72) and President Hilla Limann of the People’s National Party (1979–81).
[ii] The only notable exception to the very impressive list of rights provided by the 1992 Constitution is freedom of sexual orientation. Article 12 (2) provides that “Every person in Ghana, whatever his race, place of origin, political opinion, colour, religion, creed or gender shall be entitled to the fundamental human rights and freedoms of the individual contained in this Chapter but subject to respect for the rights and freedoms of others and for the public interest.” This public interest exception is often cited as a potential loophole in Ghana’s rights regime. 
[iii] E. Gyimah-Boadi and M. Markovits “Civil Society and Governance” in Ghana: Governance in the Fourth Republic, ed. B. Agyeman-Duah (Accra: Digibooks, 2008), 215. There are ongoing efforts to put in place a new law governing the CSO sector. The contents of this law have been the subject matter of ongoing discussions between members of the CSO sector and the Government of Ghana (GoG). 
[iv] According to the 2008 Afrobarometer Survey, 78% of Ghanaians believe they are free to say what they think, and 87% believe they are free to join any political organization of their choosing. See Afrobarometer Round 4 Survey Summary of Results: Available at
[v] The exact number of organizations that are registered under the three statutes is uncertain. Officials at the Registrar-General’s Department informed the researcher that exact figures were not available. They were, however, willing to concede that the number of organizations registered as Guarantee Companies were “a lot,” while those registered under the other two statutes were “very few”. One recent study suggested that the total number of entities registered as Guarantee Companies exceeded 3000 – see Civil Society in A Changing Ghana: An Assessment Of The Current State Of Civil Society in Ghana - Akosua Darkwa, Nicholas Amponsah and Evans Gyampoh; available at
[vi] The African Peer Review Mechanism (APRM) report mentions the following activities of NGOs and CSOs: “promotion of non-formal education, development and welfare children and women, micro-financing, community development, youth and culture, social development, conflict resolution, water and sanitation, training and capacity building, rehabilitation of the aged, child survival development, environmental, health, small-scale enterprise development, rehabilitation of ex-convicts, human resource development, caring for the disabled, bee-keeping, agriculture and food security,… disaster relief, population, advocacy and media, reproductive health, HIV/AIDS programmes, building and renovation of schools, and rural and urban poverty alleviation.” CDD, “Democracy and Good Governance: Full Report on Findings” at 170, African Peer Review Mechanism Republic of Ghana Country Self-Assessment (Jan. 2005). 
[vii] Ibid.
[viii] E.g. the Ghana Bar Association, the Ghana Medical Association, the Ghana Registered Nurses Association, and the professional associations governing pharmacists, architects, engineers, surveyors, etc. 
[ix] Thus, while one is required to be registered with the Ghana Medical and Dental Council to practice as a doctor, advocacy for doctors, particularly public sector doctors, is conducted by the Ghana Medical Association. 
[x] This is also true of organizations registered under the Trustees Incorporation Act.
[xi] According to the definitions section of the Act, an “exempt organisation” means a person
(a) who or that is and functions as:
(i) a religious, charitable, or educational institution of a public character;
(ii) a body of persons formed for the purpose of promoting social or sporting amenities;.
(iii) a trade union registered under the Trade Unions Ordinance (Cap. 91);
(iv) an institution or trust of a public character established by an enactment solely for the purposes of scientific research; or
(v) registered sporting club;
(b) who or that has been issued with a written ruling by the Commissioner currently in force stating that it is an exempt organisation; and
(c) none of whose income or assets confers, or may confer, a private benefit, other than in pursuit of the organisation's function referred to in paragraph (a).
[xii] In a recent survey of the sector, a clear majority of respondents expressed the belief that registration as a CSO in Ghana was both inexpensive and uncomplicated – supra, Darkwah, note 7.
[xiii] The Companies Code bars undischarged bankrupts, felons and other related categories of persons from being directors of any kinds of organizations.
[xiv] CDD-Ghana Research Paper No. 7 Civil Society and Domestic Policy Environment in Ghana
September 2000 E. Gyimah-Boadi and Mike Oquaye.
[xv] The Companies Code requires Guarantee Companies to have at least two directors. They are also required to have language in their regulations stating that the income and property of the company shall be applied solely towards the promotion of its objects. On dissolution, companies are required to transfer all surplus assets another guarantee with similar objectives. 
[xvi] NRCD 143, Section 3.
[xvii] The Trustee’s Act Replaced The Land (Perpetual Succession) Southern Ghana and Ashanti Ordinance (Cap. 137), which permitted groups of families or other individuals to hold and alienate land collectively. See also Kuma & Another v Koi-Larbi (1991)1 GLR 537-549 .
[xviii] A. Darkwah, Civicus Report, Supra.
[xix] Information on the history of NGOs was compiled from the following sources: IDEG; APRM; E. Gyimah Boadi and Mike Oquaye, “Civil Society and Domestic Policy Environment in Ghana,” CDD-Ghana Research Paper 7 (Sept. 2000).
[xx] This was the case of the Domestic Violence Bill, Freedom of Information bill, the Whistleblowers Bill, and others.
[xxi] A. Darkwa et al, Civicus Report.