Ibrahim Barkindo

The Role of Traditional Rulers in Dispute Resolution:

An Islamic Law Perspective
A paper presented at the National ADR Summit for Traditional Rulers, held
between 6th and 7th October, 2009 at Asaa Pyramid Hotel, Kaduna. Organized
by the United Nations Office for Drugs and Crime in conjunction with the
European Union and the National Judicial Institute.

Ibrahim Barkindo & Co.

Justice Sector Consultants, Analysts and Researchers.
Post Office Building, Zaria, Kaduna State.
10/1/2009
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

The Role of Traditional Rulers in ADR: The Islamic Law Perspective

Introduction:
This paper seeks to introduce the Islamic system of ADR called Sulh and how it
operates; comparisons will be made between the conventional ADR and Sulh;
recommendations will be made at the end of the paper. The paper has a bias to
the Emirate system found in the North, because the system is an Islamic
political system.

1. Elementary Principles of Islamic Law:

Islamic Law is the law governing the conduct of Muslims. The law covers
religious obligations (ibadat) and inter human relations (mu’amalat). The law is
called Sharia or Fiqh. Fiqh is further sub-divided into substantive and
procedural (fiqh nazari and fiqh tatbiqi). Substantive law defines rights and
duties while procedural law lays down the rules and methods of obtaining and
enforcing the rights and duties. The law is also sub-divided into public and
private, into municipal and international and into civil and criminal.

There are many sources of Islamic Law, the major are the Qur’an, the Sunnah
(traditions of Prophet Muhammad SAW), Ijma’ or consensus of jurists and
Analogical deduction or Qiyas. The other sources mainly utilize juristic
reasoning or Ijtihad to expand and interpret the law. The one engaged in Ijtihad
is called Mujtahid. It is through Ijtihad that the dynamism of the law is
achieved.

There are various approaches in interpretation under Islamic Law, which make
up schools of law. There are eight Islamic Schools of Law that are living today;
they include the Maliki School, to which Muslims in Nigeria, West Africa and
North Africa ascribe. Legal principles in this write up will border on Maliki
School.

Islamic procedural laws provide for the establishment of the judiciary to look
into disputes as to rights and duties and award verdicts accordingly. It also
provides for other constitutional bodies with the powers to receive complaints
(either suo motu or upon a complaint) and treat them; these are the justice sector
agencies.

The judiciary (qada’), the Hisbah and the Mazalim institutions are all vested
with powers to hear and treat complaints and to award verdicts. Secondarily,
they are also enjoined to utilize Sulh in disputes. The use of Sulh in Islamic
procedural law is not an alternative; but the original principle. It is only when
Sulh fails that adversarial means are resorted to.
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

Not only government agencies, Muslims are addressed by the law to employ
Sulh in disputes whenever it emerges. This, the Muslim community observes, at
family, clan and community levels. The next level becomes political and not
social; the traditional authority, from the ward head (Mai Unguwa), to the
village head (Dagaci), to the district head (Hakimi) and up to the Emir (Sarki).
The various levels are enjoined to employ Sulh in resolution of disputes of
whatever sort, to the extent only that it does not legalize the unlawful and vice
versa.

2. ADR and Sulh compared:

Almost 25 years ago, Frank Sandler of the Harvard law School coined the
phrase Alternative Dispute Resolution at a conference in the United States of
America. This principle is now increasingly globalized. This phrase denotes
resolving disputes through alternatives to litigation.

Ways of dispute resolution vary; it involves litigation, jungle justice and others.
Jungle justice is illegal, as it is self-help; which is not allowed in a civilized
setting, because the government can settle disputes through formal ways.

Litigation is an adversarial means of settling disputes and strict legal rules or

formalities are followed in the process. Due to the technical nature of litigation,
the judge needs to be a legal personnel, so also legal representatives or counsel.
The procedure is cumbersome and even the language. In a conventional system,
litigation is the sanctioned process of dispute resolution, hence the word
alternative; because the alternative is not the conventional.

The alternatives to litigation take various ways; it may be a mediation,

conciliation or arbitration. Arbitration involves arbiters and the outcome has a
binding effect, it is closer to litigation in the alternative processes. Mediation
involves a neutral third party who should not ideally be close to either party.

Sulh is the term used in Islamic Law to refer to any form of settlement of
dispute other than through adversarial means. It connotes settlement,
negotiation, mediation, arbitration, conciliation or whatever word used for
settling disputes other than litigation.

Some levels of Sulh can be called mediation, like when an individual go in

between spouses to broker a deal over an impasse. It can be arbitration when
two arbiters are pooled from the two families of spouses to save a marriage,
their award is binding on the spouses; conciliation may come in where families
or communities are disputing or quarrelling.
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

3. The Law of Sulh:

Sulh is the act conceding by a party to a dispute of his right, partially or totally.
The concession may be of an actual dispute or an expected one.

The rationale of Sulh is to broker peace between the disputing parties, it also
saves time and cost. The most effective side of it is that it sustains good
relationship between the parties and to some extent, even to the families of the
disputants.

Authority for Sulh: Both the Qur’an and Sunnah provided that utilization of
Sulh should be preferred and that it should be utilized at all levels. An Ijma’ is
also reported on the desirability of Sulh. The Prophet SAW said “conciliation
between people is valid except that which legalizes the unlawful and vice
versa”.

Advice by Caliph Umar to Judges

“Use your own understanding and judgement when disputes are
placed before you…Let all men be equal in your sight, in your court
and in your judgement, so that the strong may not hope to sway you
into injustice, nor is the weak led to despair in your justice. The
burden of proof lies on the shoulders of the plaintiff and the oath is
upon the denying party. Compromise is permissible among
litigants unless it renders into halal (lawful) what is haram
(forbidden) or forbids what is lawful. And let not a judgement that
you rendered yesterday, and then upon reflection and reconsideration
you find that it was incorrect, deter you from returning to the truth.
For truth is timeless and returning to truth is better than continuing
in falsehood.”

Essentials of Sulh: Sulh is like contract therefore the rules of contract apply to
Sulh. There must be an offer and acceptance; there must be no withdrawal from
either party. Each party must have the legal capacity to engage in contract. The
subject matter must be allowed by the law and has to be valuable and must also
be ascertained. The parties conceding to the rights must be the owners of the
rights; rights of Allah are public rights and the government may concede to
certain rights. Hudud or fixed offences cannot be negotiated.

Classification of Sulh: there are three types of Sulh, where the respondent
accepts claim, where he denies the claim and where the respondent kept mute
and refuse to accept or deny liability. The majority of jurists agree on these
three.

a) Confessional Sulh (Sulhu iqrar): Where the respondent accepts liability.

In this case, if he concedes to the settlement it becomes binding, hence it
constitutes res-judicata and no relitigation is allowed in the case.
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

b) Refutational Sulh: (Sulhu inkar):

Where a party claims a right over the respondent and the respondent denies
liability and yet, either offered or accepted settlement. Majority of schools
including Mailiki School validate this type of Sulh upon the condition that the
respondent believes that he is not liable and that he is only conceding in order to
bring an end to the quarrel or litigation (khusumah) and that also the claimant
must believe that he has a right; none of them must believe that one party is
lying, otherwise, the settlement is invalid in substance and the claimant took
what is not lawful for him to take.

This type of Sulh had been held legal because the Qur’anic provisions used to
approve of Sulh can be extended to this type of Sulh, as the reason is that Sulh is
always the best (was-sulhu khair). Q4:128

Sulh is aimed at bringing an end to dispute or litigation, therefore if a

respondent elects to end same despite his denial, it is valid in law.

Some people fear or abhor litigation and as a result, they opt for settlement and
surrender or concede their rights, more especially if it will involve an oath,
Senior jurists among the companions of Prophet Muhammad SAW opted for
Sulh and conceded their rights in order to avoid litigation and the possibility of
subscribing to an oath.

Once a Sulh is concluded as such, it becomes binding and res-judicata

constituted over it; hence, no relitigation is allowed on it and the respondent will
not be asked to subscribe to an oath.

c) Silent Sulh: (Sulhu sukut):

If the respondent neither accepts nor denies liability but agrees to a settlement,
the jurists treat this settlement as a refutational Sulh, because one who is mute is
denying. It may be that he is admitting, but due to his silence, and because of
the presumption of freedom from liability, his silence is considered to be a
denial. Maliki school accepts the concession of a respondent who kept mute, as
he agrees to the negotiation.

4. Areas of Sulh
As there are innumerable areas where conflict emerge so also the areas where
Sulh is possible. Wherever there is a dispute, Sulh is allowed as a matter of
original rule in procedural law and not an alternative. Litigation is the last
resort.

The following only highlights the areas, with minor examples:

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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

a) Sulh in Property matters (commerce):

The area contemplated most where Sulh is possible is in commerce. Disputes
may emerge over property, be it tangible or intangible.

There may be a dispute over land or landed property; farmland, right of way or
grazing rights, hire or rent which are either corporeal or usufructuary rights. The
cases where Sulh appear most involve loans or credit.

In a claim of a loan of N1, 000, 000.00, the respondent may offer to pay N500,
000.00 (or more than that or less), the claimant may accept the offer and the
contract of Sulh is concluded and binding. The respondent may likewise agree
to use a farmland in place of the money. The substitute may be the same, less
than or even more than the actual right claimed for. Conceding to a right in a
settlement may make either the claimant or the respondent bend over and forgo
a right or part of it. The party conceding is not static.

b) Sulh in Family matters:

This include matrimonial issues as well as rights and obligations of parents and
children. In practice, traditional rulers receive matters where a parent is angry
with his child or vice versa, or where he is rejecting a suitor. Some of family
disputes are more of relationship matters rather than property matters and will
attract attitudinal change rather than surrendering rights or the like.

c) Sulh in Criminal Matters:

Islamic criminal law is in three categories; Hudud or fixed offences, Qisas or
the law of retaliation (lex talionis) and Ta’zir or discretionary punishment. The
last two categories are compoundable. The second one (Qisas) involves the
family of the victim most and negotiation, involving pardon is involved. The
law of retaliation involves retaliation, payment of diyyah or blood money and
forgiving. The victim or his family can exercise the options in a downward
approach and not vice versa; he who opts to forgive cannot be heard to change
his mind in favour of retaliation or acceptance of Diyyah.

A hypothetical case may be used here; a thief is caught and offered to pay some
money in order not to be handed over to the police for the purposes of
prosecution. This settlement is invalid in law for the reason of illegality.

Mr. A (who, despite of the way he leads his life of fun, refuses to undergo an
HIV test and) marries Miss B. After two months, A falls sick and was diagnosed
for HIV and was found positive. B was also diagnosed and found so; evidence
established that he infected her. In a homicide case brought by B’s family
against A’s family for unlawful killing (at whatever level), negotiation is
allowed and that retaliation is not feasible in this case; should they opt for
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

Diyyah rather than forgiving, A’s family may in a Sulh ask for the reduction of
the Diyyah value:
- From 100 camels to a lower number; even to two or one;
- From 200 cows to a lower number;
- From 1000 pieces of gold (Dinar) to a lesser amount
- From 12, 000 pieces of silver (Dirham) to a lesser one.

However, the Qur’an encourages the family of the victim to always forgive (Q5:
45). The point here is that the stated legal solution to the dispute is not a one
way traffic, not even two, but three; there are therefore alternatives.

d) Sulh in other disputes:

Disputes between neighbours which are outside property matters, certain family
disputes that are neither matrimonial nor rights and duties within a family,
communal disputes (which are rampant in Nigeria, and some are seasonal)
which may even be armed conflicts. “And if two factions among the believers
fight, then make settlement between the two...” (Q49:9) This verse mandates
policing authorities to explore avenues of peace and reconciliation before
engaging in armed control of disputing, armed or renegade groups.

In International law, during a conquest, settlement are made to avoid combat or

to secure the rights and privileges of certain persons or places; treaties
concluded during war mostly involve concessions of one right or the other; a
territory secured by Sulh and not military combat is called ard sulh. Every
chapter on international law of war in the Islamic legal literature contains a
chapter on Sulh.

5. Sulh in Practice:
In practice, Muslim families, communities and government institutions utilize
Sulh more than litigation; it may be the reason for the rate of litigation at least in
some areas in Muslim Northern Nigeria). The following describes the process
of Sulh in some areas:
a) Family mediation of marital disputes: usually, respected members of the
family broker a peace between disputing spouses, or even where the
dispute is expected as a preventional measure, a member, male or female
will go in between the parties or even talk to one in order to bring to an
end or avoid dispute. At this level, privacy, efficiency and reliability is
assured. At this level, Islamic mediation requires the mediator to be one
that is known to both parties and deeply involved in the family; in effect,
the family has a duty to mend sour relationship internally.
b) The spouses may themselves arrive at a settlement over a dispute “And if
a woman fears cruelty or desertion on her husband’s part, there is no sin
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

on them both if they make terms of peace [sulh] between themselves; and
sulh is best.” Qur’an 4: 128.
a) An outsider to the family may also go in between disputing members of
the family, be it matrimonial or otherwise. However, the family has a
duty to mediate.
b) Mediation in commercial matters: this happens a lot where third parties
engage in mediating between two disputing parties. In the local economy,
land disputes, loans, credits as well as sale disputes are negotiated and
some people often concede their rights than litigate over them.
c) Family arbitration over matrimonial disputes: this practice is seldom
resorted to by the family on its own motion. Usually, the judge in a
litigation matter calls on the parties to come along with their legal
guardians (waliy) on the next adjourned date. On that date, the judge will
ask them (the two waliys) to go and find a settlement for the matter. The
two waliys necessarily come from the families and are usually male
agnates of the spouses. The two waliys will then individually try to talk to
their wards and secure a concession that will work for the settlement and
thus saves the marriage. They will report to the judge and their settlement
is final (as far as Maliki School is concerned). Should the settlement fail,
the judge will then proceed to trial.

This process is called ba’thul-hakamain, in observance of Qur’anic

injunction in Q4: 35
“and if you fear dissention between the two (husband and wife),
then send and arbitrator from his people and an arbitrator
from her people. If they both desire reconciliation, Allah will
cause it between them. Indeed Allah is ever Knowing and
Acquainted [with all things]”.

This procedure is translated as matrimonial arbitration because arbitration

resembles litigation, an adversarial process and that awards resulting from
the process are binding.
d) Part of the reconciliatory efforts at the court is that where a wife deserts
her husband in protest (yaji in Hausa), the judge will grant him an
opportunity of going to her in order to appease her to restore marital
affairs. In practice, all matrimonial causes must include this process; on
Appeal, the Sharia court of appeal may refer the case back for retrial if
this process or option is not utilized or allowed by the judge.
e) A case was reported where a farm owner concedes to allow water to pass
to his neighbour even before his farm is saturated. The other farmer was
not happy and the settlement collapsed, the first farmer then retains water
till his farm saturates before he releases water to his neighbour’s farm.
f) Where cattle rearers dispute with farmers over cattle routes and
farmlands, traditional authorities usually involve Ministry of lands, urban
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

planning or forestry to ascertain the routes and naturally, either party has
to concede certain interests.
g) Inter-communal disputes, involving armed conflicts are also subjected to
Sulh where traditional rulers partner with the police and other security
agencies to bring together the disputing parties, communities or families
to table and broker a peace. In such cases, mediation or reconciliation is
the usual method employed.
h) In certain cases involving families, communities or where a public place
is involved, traditional rulers involve the judge, the police and sometimes
the local government.
i) Most of the Sulh carried out are done by members of the public and
hardly go to the government unless if there is a dispute. Some do refer
questions to Muftis (juriconsults) for legal opinion.

6. Entry points for the Traditional Authorities:

In Islamic Law, both the social and political nucleus is found in the family. An
extended family or a clan has a political relevance and has constitutional rights
and duties (Niqabah system). The ward head exercises control over families
within its jurisdiction; wards make up a village and the village head controls the
various ward heads under him. Villages make up a district and district heads are
answerable to the Emir.

The responsibilities of the traditional rulers include maintaining a harmonious

relationship within the areas they control, including amicably settling disputes.
Due to the constitutional arrangements 1903-date, the Emirate system became a
traditional system, but more than symbolic. Disputes of all sorts are resolved at
the various tiers of an Emirate, and some even go up to the Sultanate, at Sokoto.

While some disputes can be settled within a family, others yet through the
police and other government agencies, communal disputes and the like can only
be settled by the traditional rulers or involving them. Most family disputes,
some of which are non-justiciable are settled by the traditional institutions, like
where a parent buys low-class furniture or decors for his daughter who is
getting married; through Sulh, he can be persuaded to marry her out with
properties of her class. The writer witnessed many cases of such at the Hisbah
offices in Kano.

The reasons for the efficiency and effectiveness of their settlements of disputes
is that they are closer to the people, no costs are involved in their processes, it
always end in a win-win situation, no presence of any adversarial method and
confidentiality is maintained. There is both access to justice and quality of
justice.
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

The other justice agencies fail on the test of the rule of law indicators of
physical proximity to the public, the language of the forum, the simplicity of the
procedure, the absence of fear or phobia, the cheapness of obtaining justice, the
affability and friendly nature of the personnel and most importantly, the
acceptability of the system by the end-users.

It is as a result of that, various researches and surveys revealed that the

traditional institutions are more effective and more efficient than the formal
justice institutions.

Examples of documented Sulh cases from Jigawa State (taken from Access to
Justice Programme, Research Report- Resolution of Civil Disputes in Jigawa
State, Ahmed, Ali, et.al- June-Aug 2003) unpublished:
- Hajara’s husband went away for a long period of time. She waited
for six years before she finally gave up. During this period she tried
all she could and when she heard he was in Benin City, she tried to
no avail to contact him. The husband’s relatives were very
supportive of her psychologically and financially, and shared in her
anxiety. After notifying both parents of the parties, it was the imam
with assistance of Mai Unguwa that finally resolved the matter.
- Murtala v. Dije. Land Case. Emir involved with negotiation with
the successful party to maintain communal solidarity. Plaintiff was
the heir to a piece of land in Kazaure but he was ignorant of this fact
for a considerable length of time, believing as everybody else that the
possessor who was let in by the deceased father of plaintiff was the
actual owner. When he knew the facts he brought this case and the
court awarded him the house. However, the defendant had been in
possession for an unbroken period of over 30 years and the reliance
of the mistaken fact was so devastating to the community. He had so
many children and had nowhere else to move. A sulh process was
initiated with mediators including the new Alkali of the court that
awarded the judgement and the Emir of Kazaure. It was finally
resolved that equity was in the side of the plaintiff selling the house
at a price he agreed to the defendant since he had an alternative
house and had less attachment to the particular house. Plaintiff
agrees and the parties became closer after the settlement.

7. Problems and prospects:

The prospects of the traditional system are that it is well entrenched in the
socio-political system of this country; closer to the people and enjoy
government respect and patronage. Should their role be strengthened in terms of
implementation framework, they would deliver more good results which are
goal oriented. There is no need to establish committees, boards or the like; just
utilize the system for good governance. The system is already partnering with
the government on security matters, including inter-communal conflicts and day
to day local government administration. They are also closer to the people,
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

understands most the problems enjoy both charismatic and religious charisma
from the people.

The problems that militate against successful and better performance by the
traditional authorities of their roles in ADR include, but not limited to the
following:
a) The perception by some that it is not a justice institution;
b) Sometimes the police and the judiciary takes over matters before the
traditional authorities on the point that the cases are criminal cases or the
matter is sub-judice;
c) Some of the settlements reached are so fundamental that they need to be
documented, to serve as evidence for posterity and bar further dispute on
the matter;
d) The need for a judicial stamp of some important arbitral awards and
memoranda of understanding;
e) The capacity of the traditional institution is not built to document
fundamental issues settled through ADR, like drafting terms of agreement
or settlement, awards of arbitral matters and advisory notes regarding the
matters before them;
f) There is no institutional framework for the sustainability for the proper
documentation of certain proceedings and proper storage of records
within the traditional system even if it is institutionalized;
g) ADR at its various levels are utilized by the traditional institutions
without observing the necessary ethical conduct regarding each stage, like
confidentiality and involvement in mediation; which means that
techniques and ethics of ADR should be imbibed by the personnel of the
traditional institution involved in ADR;

8. Conclusion and Recommendations:

The Constitution of the Federal Republic of Nigeria, 1999 in chapter two
guarantees access to justice by every Nigerian at a cheap and affordable cost.
This cannot be achieved through the conventional system or the conventional
justice institutions. Access to justice entails the availability of the institution, its
physical proximity to the public, low costs paid for administrative purposes and
the short nature of the time for hearing and disposing of the grievance. The
other indicators include the disposition of the personnel of the justice
institutions who must be welcoming, serving and satisfying the end-users and
the ultimate result of the grievance, i.e. satisfaction of the end-user with the
institution which will determine the confidence the end-user has regarding the
institution.

It seems that the traditional institutions have these qualities more than the
formal justice institutions. The principles of spending are that more funds
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The Role of Traditional Rulers in Dispute Resolution: An Islamic Law Perspective

should be allocated to the agencies that perform better than those which perform
less. The following recommendations tend to suggest ways the institutions will
be strengthened to deliver more efficiently and more effectively.

a) The commitment of state governments should be secured regarding a

definite and widened role of traditional rulers, particularly regarding
ADR;
b) The judiciary; the Chief Judges, Grand Kadis and Presidents of the
Customary Courts of Appeal should issue Practice Directions regarding
the judicial processes to be followed in having the outcomes of
traditional ADR filed in courts to serve as res-judicata;
c) If need be, Traditional ADR fora should be established by the judiciary
with quasi-judicial powers to handle ADR thereby reducing the deluge of
cases in the courts and saving time and cost.
d) The Commissioner of Police in each state should make an Order
allowing traditional ADR to be concluded before matters be taken to the
police station, even if they are criminal matters, once the victims or those
interested in it can reach an amicable solution. This will help in
decongestion of prisons and utilization of non-custodial punishments.

REFERENCES:

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3. Al-Fasi, M.A. Sharh Mayyarah alat-Tuhfah. Darul ma’ rifah. Chapter on Sulh;
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1973) chapter one on Imamah or the contract of leadership, the chapter on Hisbah and that of
Wilayatul-Mazalim
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the definition of Hisbah;
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7. Keshavjee, M. “Alternative Dispute Resolution: Its Resonance in Muslim Thought and Future
Directions”. Speech given at the “Isma’ili Centre Lecture Series” April 2, 2002, London, available at
www.iis.ac.uk
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2006 m/1427 H
9. Abubakar, M.S. ADR Through Sulh: The Role of the Imam. Unpublished paper delivered at the
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11. The Rule of Law Index: Version 2.0. Developed by the World Justice Project. Available at
www.worldjusticeproject.org