An Appraisal on the Distinctions and Similarities between the Offences of Strict Liability and Vicarious Liability: Making a Case against the Recognition of Vicarious Liability in the Criminal Law of Sierra Leone
By: Farouk Sulaiman Taiwo Adedoyin
LLB HONS (USL), BL Candidate, Sierra Leone Law School.
Email: faroukadedoyin@gmail.com
Edited by: Edmondson Emmanuel Sawyerr ESQ
LLB HONS (USL), BL (Legal Practice) Sierra Leone Law School.
Email: edmonsonsawyerr0@gmail.com
And
Abubakarr Samuel Dumbuya ESQ
BA Political Science (USL), LLB HONS (USL),
BL (Legal Practice) Sierra Leone Law School.
Email: Abubakarrdumbuya@gmail.com
Distinctions and Similarities between the Offences of Strict Liability and Vicarious Liability
1. Introduction
To start with, there are a number of distinctions between vicarious liability and strict liability offences. Vicarious liability and strict liability offences are part of the offences criminalised under the criminal law of Sierra Leone. It is noteworthy that by virtue of Section 74 of the Courts Act, of the Republic of Sierra Leone, the Courts of Sierra Leone are allowed to use the common law of England, doctrines and principles of Equity, and Statutes of General Application in force in England before the 1st Day of January 1880. However, where such common law is used, it merely has persuasive authority as opposed to binding legal authority. This is primarily why this literature cited such authorities and such other case laws from jurisdictions with analogous common law legal systems like Sierra Leone.
For a critical assessment of the distinction between both offences, the first attempt that must be made herein is at defining both offences respectively. Under the doctrine of vicarious liability, an employer is criminally responsible/liable (guilty) for an employee's negligent actions if they were committed in the course or scope of the employee's employment or are closely connected with what the employee is authorised by the employer to do.
The essential elements of the offence of vicarious liability include:
a. An employee is acting within the framework of his/her employment.
b. He/she commits a crime or omission that leads to a crime attracting the culpability of the employer/licensee/superior.
c. It is not essential whether or not the employer or superior had knowledge of the crime committed by his subordinate.
A Strict Liability Offence, on the other hand, according to Black’s Law Dictionary is “an offense for which the action alone is enough to warrant a conviction, with no need to prove a mental state.”
The essential elements of the offence of strict liability include:
a. Being found in a position of the commission of a crime (the actus reus/guilty act) or omission that resulted in the guilty act.
b. Whether the accused person was knowledgeable or ignorant of him/her committing the alleged crime (guilty act), with or without intent, nor subjectively or objectively reckless, or negligent, is irrelevant.
2. The Distinction between Vicarious Liability and Strict Liability Offences
The House of Lords in Seaboard Offshore Ltd v. Secretary of State for Transport4 held that vicarious liability is by no means the same thing as strict liability. Notably, however, the first distinction between vicarious liability and strict liability offences hinges on their definitions (meanings).
As has been catalogued above, the doctrine of vicarious liability involves holding an employer liable for an employee's negligent actions if they were committed in the course or scope of the employee's employment or are closely connected with what the employee is authorised by the employer to do.5 It is a form of a strict, secondary liability that arises under the common law doctrine of agency, respondeat superior: the responsibility of the superior for the acts of their subordinate. A Strict Liability Offence, on the other hand, is “an offense for which the action alone is enough to warrant a conviction, with no need to prove a mental state.”
Furthermore, another distinction between the two offences is that a statute may require mens rea and yet also impose vicarious responsibility, whereas, for strict liability, liability is strict as the mental element (mens rea) is absent/not required. This is evident in the locus classicus decision between Sherras v De Rutzen,7 where supplying liquor to a constable on duty was an offence requiring mens rea, yet a licensee may be vicariously liable for his agent’s act in so doing, as has been affirmed in Mullins v. Collins.8 In the Sierra Leonean locus classicus decision between ELIAS v. JAFFA and SESAY, SUPREME COURT DECISION DELIVERED BY Beoku-Betts, J. on March 31st, 1953, the Supreme Court (now High Court) considered whether the second defendant was negligent; whether his negligence, if proved, caused the injury to the plaintiff; and whether the first defendant could be held vicariously liable for the second defendant's action in the circumstances of the case.
Similarly, in a more recent Sierra Leonean Court of Appeal decision between MARY HARDING v. MRS. NABA OSAIO KHANU & ORS, JUDGMENT DELIVERED IN OCTOBER, 2017, presided upon by HON. MR. JUSTICE M.F. DEEN TARAWALLY (J.A.) [as he then was], HON. MR. JUSTICE R.S. FYNN (J.A.), and HON. MR. JUSTICE A.B.T. HALLOWAY (J.A.) [as he then was], the Court of Appeal of Sierra Leone held that the Plaintiff shall be held vicariously liable for the exercise of all relatives and or friends on the premises, and similarly, the Attorney of Mr. Khanu shall be held vicariously liable for the excesses of all occupants who are family member of Mr. Khanu and /or friends on the premises.10 On the other hand, Ormerod, in Smith and Hogan’s Criminal Law (11th Edition), has argued that it is clearly possible for a statute to create strict liability without imposing vicarious responsibility.11 Once a statute has been held to impose a duty with strict liability on a particular person, it is likely to be held that the person is liable for the acts of anyone through whom he performs that duty. Obiter dicta to this effect that an offence of strict liability necessarily imposes vicarious responsibility are not difficult to find. One such case law is Bradshaw v. Ewart-James.Whereas the duty with strict liability is not imposed on particular persons but on the public, vicarious liability on the other hand is inappropriate. For instance, the offence of causing death by dangerous driving was held to be an offence of strict liability, but it is surely inconceivable that vicarious liability would have been imposed. In a similar perspective, Amadu has averred that under Sierra Leonean Law of Evidence, in accident cases, there is a presumption that a driver is the owner or is the owner’s agent where the identity of the owner is in issue [especially where such a situation makes it extremely difficult to secure a remedy against the owner who ought to have been held vicariously liable for the actions of his/her employee].This position has been affirmed in the celebrated Sierra Leonean case of Gombui v Hill.
Moreover, a notable distinction between the two offences involves the fact that whereas vicarious liability offences often stem from judicial decisions (common law), strict liability offences are creatures of statutes. For instance, strict liability offences as creatures of statutes have been so upheld in the following celebrated cases and circumstances in Gammon (Hong Kong) Ltd v Attorney-General of Hong Kong [1985] for Dangerous building, and for Pollution, the case of Alphacell v Woodward, among others.
In addition, a further distinction between the two concepts hinges on the fact that whereas there may be defences available to the employer who is charged vicariously under the criminal law of Sierra Leone, the offence of strict liability does not carry defences available to an offender. The offence is strict and may be so provided by the common law, or statutory laws of Sierra Leone. Also, another difference between the two offences is that Whereas Strict Liability Offences do not hold sacrosanct the doctrine of presumption of innocence as was seen in Salabiaku v. France,16 and in R v. Lambert;17 Vicarious Liability Offences on the other hand, maintains that the person allegedly held to have been vicariously liable is presumed innocent until proven guilty in accordance with the cardinal principle of Sierra Leone’s Criminal Law of presumption of innocence, laid down in Section 23(4) of the Constitution of Sierra Leone,18 which encapsulates that:
“Every person who is charged with a criminal offence shall be presumed to be innocent until he is proved, or has pleaded guilty.” Additionally, the principle of delegation is the most essential in stating a distinction between the offences of vicarious liability and strict liability, as the delegation principle is manifestly associated with vicarious liability offences.19 It applies where there is a master/servant relationship but not exclusive to it. A good application of the delegation principle may be found in the case of Allen v. Whitehead;20 under Section 44 of the Metropolitan Police Act 1839, wherein it was an offence to:
“knowingly permit…prostitutes or persons of notoriously bad character to meet together and remain in a place where refreshments are sold and consumed”.
On the other hand, the delegation principle is inapplicable to strict liability offences, save for where an employer is vicariously found guilty of a criminal offence committed by his/her employee. According to Lord Parker in WINSON [1969],21 the delegation principle comes into play only in the case of offences requiring mens rea. Where liability is strict,
‘the person on whom liability is thrown is responsible whether he has delegated or whether he has acted through a servant’.
In addition, a further distinction between the two offences which can be inferred from the decision in Gammon (Hong Kong) Ltd v Attorney-General of Hong Kong includes the fact that Strict liability offences are regulatory in nature, as opposed to being true crimes; they are of social concern; the offence would usually carry a small penalty; and the wording of the Act/Statute indicates a strict liability offence by the absence of the mental element to be proven upon the commission of the offence. Offences of vicarious liability, on the other hand, are justified by the principle of the loss distribution, compelling the risk creator to pay. It is often geared towards securing compensation to victims, inter alia.
A further pointer to distinguish between the two offences involves the fact that whereas vicarious liability may generally arise from varying situations under the common law (the courts’ decisions), strict liability offences, on the other hand, are mostly restrictive to issues promoting and protecting the public (public interest). An example relates to the offence of driving with excess alcohol, contrary to the protection of public safety as a cardinal theme of the Road Traffic Act, which was stated in DPP v. H, not to require proof of mens rea. These circumstances would also involve the protection of the environment from pollution, food safety regulations, road traffic offences, drug prevention-related offences, and such other offences known to the criminal law of Sierra Leone. They are laws often statutorily enacted to improve the health and safety of everyone in society (Sierra Leone herein).
In the much-celebrated Sierra Leonean case law authority between COMPTROLLER OF CUSTOMS v. BASMA, Webber C.J. opined that:
Modern legislation dealing with municipal law and public health has been framed in such terms as to make an act criminal without any mens rea. By-laws which impose regulations in the interest of health and convenience of the public are generally so conceived and the mere breach is sufficient to constitute an offence.
Some of these statutes that expressly provide for strict liability offences, in force in Sierra Leone today, include The Environment Protection Agency Act,26 The Pharmacy and Drugs Act,27 and The Road Traffic Act.28
❖ The Environment Protection Agency Act, Act No. 11 of 2008
Section 58 subsections 3, 4, 5, and 6 of the aforementioned Act creates strict liability offences herein and excludes proof of mens rea (the mental element/guilty mind) or is silent on whether the mens rea must be proven.
❖ The Pharmacy and Drugs Act, Act No. 12 of 2001
Section 41(2) of this Act provides a strict liability offence. The provision enshrines that:
“No person shall manufacture opium or Indian hemp in a state prepared for smoking.”
Also, Section 49 of the same Act prohibits the smoking of opium or Indian hemp in Sierra Leone, and the offence negates the mental element (mens rea), thereby constituting a strict liability offence.
❖ The Road Traffic Act, Act No. 5 of 2007
The Road Traffic Act of 2007 is one of the Acts that carry numerous strict liability offences, obviously in order to protect the public (as has been earlier discussed in the preceding paragraphs). Some of the provisions in the Act that provide for strict liability offences include Sections 45, 46, 99, 103, 111 (Use of seat belts), 114 (Use of protective crash helmets), and 131 (Intoxicated cyclist).
3. Similarities between Vicarious Liability and Strict Liability Offences
Having discussed the major distinctions (differences) between the two offences above, there is the need to also discuss some of the similarities between them with some perspectives from Sierra Leone’s criminal law, in order to better appreciate their operations and highlight the nexus or relationships between them.
To start with, a similarity between strict liability and vicarious liability offences hinges on the fact that they are both offences incurring liability expressly in tort but also to a much lesser and more controversial extent in the criminal justice system of Sierra Leone. On a separate note, whereas strict liability offences are recognised in Sierra Leonean statutes, Justice Bankole Thompson (of Blessed Memory) in his book, The Criminal Law of Sierra Leone,29 has in the same way recognised Strict Liability Torts.
Another similarity between a strict liability offence and an offence of vicarious liability is that vicarious liability would usually arise where there is the ‘attributed act’ principle.30 In similar respects, this principle usually applies to strict liability offences where the actus reus of the employee, etc is attributed to the defendant (owner/boss/licensee, as the case may be) as established in the English case of COPPEN v. MOORE (No 2.)31
Finally, another fundamental similarity between the two offences applies where Parliament has so pronounced a provision in a Statute to be tantamount to statutory vicarious liability (as opposed to the general position earlier raised above that vicarious liability offences often stem from the common law [court decisions]).
Making a Case Against the Recognition of Vicarious Liability in the Criminal Law of Sierra Leone
1. Introduction
Vicarious liability is designed to keep individuals and larger parties accountable, making sure that someone or some entity is held responsible for harm caused to the innocent.33 For instance, under the State Proceedings Act of 2000,34 the Parliament of Sierra Leone has legislated the need for private citizens to be able to bring legal claims against the State, and State Corporations, Ministries, Departments, and Agencies (hereinafter referred to as MDAs). This is also constitutionally provided for in Section 132 of the Constitution of Sierra Leone,35 where the constitution mandates the High Court of Sierra Leone to have original jurisdiction on claims against the government. In this regard, it can be juristically inferred that these State MDAs in the Republic of Sierra Leone may be held vicariously liable for the actions, omissions, and neglects of their employees, while in the exercise of their employing institutions’ activities.36
However, notwithstanding the above, it is submitted herein that the offence of vicarious liability is not necessary and should not be recognised in the criminal law of Sierra Leone.
2. Arguments Illustrating That Offences of Vicarious Liability Are Not Necessary for Sierra Leone
The first point to illuminate herein is that the offence of vicarious liability can be seen to be unjust in that someone who is not at fault can be held liable. Because of this, recent statute law enacted by the current Parliament of Sierra Leone, herein being the Consumer Protection Act,37 has recognised the need to negate the applicability of vicarious liability in Sierra Leone, pursuant to Section 56(paragraph i) thereto, where the Act provides that:
Without prejudice to section 55, in determining whether a term of a consumer contract is unfair, the High Court may take into account whether the term has the object or effect of- limiting the supplier’s vicarious liability for its agents.”
Furthermore, those in support of the position that vicarious liability is necessary under the criminal law of Sierra Leone, often submit arguments claiming that the operation and existence of vicarious liability increase judicial activism, and would enrich the criminal law jurisprudence of Commonwealth Nations. Ormerod has shared this similar view as he opined that the development of vicarious liability is the work of the courts rather than of parliament.
However, this literature does not subscribe to this position. From a strict constructionist, this literature argues against this notion of leaving offences of vicarious liability to the whims and caprices of judges, thereby making these offences creatures of the Courts as opposed to being creatures of Statutes and creatures of Parliament. Doing so would undermine the cardinal rule of law doctrines of Separation of Powers, Parliamentary Supremacy, and respect for the rule of law in a democratic state like Sierra Leone. It should be the sole duty of Parliament to legislate provisions in statutes that would expressly provide for laws on vicarious liability, as Parliament is the exclusive body vested with the power to make law in Sierra Leone.39 It needs no Judicial Notice to allude to the fact that the Judiciary is vested with the constitutional mandate to interpret the law.40 Hence, the argument herein speaks to the issue that with the current state of much of the law on vicarious liability, being a creature of the Courts of England, and such other Commonwealth jurisdictions, there is a growing need to legislate these offences into statutory vicarious liability offences, if ever they will one day be made applicable, and necessary in the Sierra Leonean Criminal Justice context.
In addition, it is often argued that imposing strict liability will lead to people taking more care and will serve as a deterrence to others. On the flip side, the application of the offence of vicarious liability imposes an injustice to a superior (employer), thereby, does not expressly serve the purpose of deterrence on the superior even where he has taken every reasonable step to avert the crime committed by his/her employee.
The SPECIAL COURT FOR SIERRA LEONE (SCSL), TRIAL CHAMBER I, on the 2nd of March 2009 in the case of the PROSECUTOR Against ISSA HASSAN SESAY, MORRIS KALLON, & AUGUSTINE GBAO, at paragraphs 308 to 309, presided upon by Hon. Justice Pierre Boutet, Presiding Judge Hon. Justice Benjamin Mutanga Itoe, and Hon. Justice Bankole Thompson (of Blessed Memory) when addressing the issue of vicarious liability and the extent to its applicability and necessity in Sierra Leone [and by all necessary implications to International Criminal Law], noted in paragraphs 308 and 309 that: “308. In order to hold a superior responsible under Article 6(3) of the Statute for crimes committed by a subordinate, the Chamber is of the opinion that the Prosecution must prove that the superior knew or had reason to know that his subordinate was about to commit or had committed such crimes. Responsibility under Article 6(3) of the Statute is not a form of strict liability. 309. The actual knowledge of the superior, that is, that he knew that his subordinate was about to commit or had committed the crime, may not be presumed and may be established by direct evidence or through circumstantial evidence from which it may be inferred that the Commander had in fact acquired such knowledge.”
From the above position of the SCSL, it is glaring that the Court attempted at emphasising the need for proof of the superior’s knowledge of the commission or omission that led to the crime perpetrated by his subordinate. In doing so, direct evidence to prove this knowledge must be submitted. It is thus asserted herein that the SCSL gave this direction in the aforementioned locus classicus decision in order to provide a standard that seeks to remedy the injustice perpetrated by ordinarily convicting a superior official for actions done by his/her subordinate even where he/she as the superior official had no knowledge of the actions of the subordinate [which in the general application is usually the effect of the offence of vicarious liability].42 In this light, it is noteworthy to add that the SCSL by this direction in the above Decision, impliedly illuminated the position that the offence of vicarious liability is not necessary under the criminal law of Sierra Leone, or alternatively must be subject to Knowledge on the path of the Superior official.
Thompson noted that:
“Most of Sierra Leone’s substantive criminal law is in statutory form, either local or inherited.”
However, unlike Britain and the United States, Sierra Leone has shown little or no interest in the rational development of criminal law or the future directions of this major branch of the nation’s public law despite the existence of the country’s Law Reform Commission.44 The same can be said herein of the little enactments done with regard to the non-recognition of the offence of vicarious liability, among other offences. Notwithstanding mentions made to the Consumer Protection Act above, much of the law on vicarious liability in Sierra Leone is found in the common law (judge-made decisions), and those statutes and decisions of courts in force in England before the 1st Day of January 1880.45 This limits predictability as to what constitutes vicarious liability in Sierra Leone, given that the law on the offence has not been expressly codified in a statute or a number of statutes, and it is merely scattered in the wilderness of judge-made laws/judgements from England, which in any case are not binding and may only be of persuasive weight before Sierra Leonean courts.46 This lacuna could possibly promote arbitrariness under the Sierra Leonean Legal System, as the law or laws on vicarious liability are not easily accessible by the ordinary Sierra Leonean, and courts may go on to borrow a leaf from jurisprudences of other Commonwealth Nations in applying the said doctrine (offence). Thus, for this reason, it is safe to say that the continued existence of the doctrine of vicarious liability in Sierra Leone is not necessary, and as such, it should not be in operation.
Professor Joko Smart, while remarking generally on the criminal law of Sierra Leone, has shared a similar view to some of the assertions above, in his Foreword to The Criminal Law of Sierra Leone, where he argued that:
“The criminal law of the country continues to be scattered in a wilderness of legislation [and by extension, the common law] substantially imported from England as either statutes of general application in force in that country on the 1st day of January 1880 or as Imperial statutes after that date.”
From the foregoing, in any society whose values and structures are changing, there is a pressing need for a constant and continuing process of adjustment, adaptation, and reformation of the law. This is the more reason why it is of essence that because of the unpredictable and un-uniformed approach of the law on vicarious liability in Sierra Leone, it is not necessary for the criminal justice system of the country, or otherwise, should be made to meet social standards, and codified in a manner that does not defeat the ends of justice or cause any injustice.
It is for this reason, the case is made herein sufficiently strongly that vicarious liability is not necessary or better still, should be reformed through legislative interventions if ever it is to be recognised under Sierra Leonean law. Thompson has gone further to discuss the social science perspectives on the origins and nature of criminal law, which is important to the analysis herein. He touched on major theories that would aid a person’s perspective in assessing the administration of the criminal justice sector of Sierra Leone.
Firstly, he noted the legal theory that crime rests on the notion of legality, one of whose key features is that only an act specifically prohibited by law is a crime. From the foregoing, vicarious liability offences have not been expressly recognised in Sierra Leone. Thus, this first theory asserted by Thompson above addresses the fact that the current state of the offence of vicarious liability in Sierra Leone is not in consonance with the notion of legality in that it has not been specifically provided for by or under the laws of Sierra Leone (nor to any extent codified).
The next theory put forth by Thompson is that no punishment is lawful unless declared by law to be so, embodied in the Latin maxim nulla poena sine lege. In this instance, it can be argued that vicarious liability is not a creature of statute and is hardly a creature of the common law (Courts) of Sierra Leone. The third theory the learned Justice postulated is that no person shall be convicted or punished for an act which was not a crime at the time it was done. In effect, ex post facto or retroactive laws are invalid. This is a position also embodied today in Section 23(7) of the Constitution of Sierra Leone.This argument also justifies why it should be considered that vicarious liability should not be part of the laws of Sierra Leone as it is unnecessary, given that the criminal law of Sierra Leone is not wholly clear when an attempt is made to access written laws and case laws on the offence. An alternative recommendation for it to satisfy the necessity test is for these offences to be codified into statutes by Parliament.
Furthermore, the modern justification of vicarious liability, put forward by its proponents, is that it is justified by the principle of the loss distribution, compelling the risk creator to pay. However, under the criminal laws of Sierra Leone, it must be mentioned that the goal of Sierra Leone’s criminal law is Punishment, which can be meted out through custodial sentences or by administering fines (pecuniary sentences). It would constitute a grave injustice if an accused employer/superior/licensee who is innocent of the crime committed by his/her subordinate and has no knowledge of the commission of the crime is punished through custodial or pecuniary sanctions, especially where an attempt to appreciate the principle of loss distribution involves long term jail sentence or exorbitant fines or both. In similar situations, what if the employer is unable to afford the fine, this would lead to him suffering from an action which is not of his own making. Thus, it shows that a person may be liable where they are not at fault and have exercised all reasonable care. This is why the offence of vicarious liability is not necessary under the criminal laws of Sierra Leone.
It is hereby conclusive that recognising and applying the offence of vicarious liability in the Sierra Leonean setting could cause an increase in the conviction of innocent citizens which usually creates stigmatisation often created after an employer or superior authority has been convicted for the guilty acts of his/her subordinate.50 Any criminal offence (vicarious liability offences included), carries with it a stigma and it is usual practice that job applicants are required to take out Police Clearance to ascertain their criminal record as is customarily requested by employers. Hence, a recognition of the offence of Vicarious Liability may cause immense damage to a citizen's reputation.
Bibliography
• BOOKS
1. B Thompson, The Criminal Law of Sierra Leone, Copyrights 1999.
2. D Ormerod, Smith and Hogan’s Criminal Law (11th Edition).
• CASE LAWS
1. Seaboard Offshore Ltd v. Secretary of State for Transport [1993] Crim LR 611. 2. Sherras v De Rutzen [1895-9] All ER Rep 1167. 3. Mullins v. Collins [1874] LR 9 QB 292. 4. Bradshaw v. Ewart-James [1983] 1 AER 12 at 14. 5. Callow v Tillstone. 6. Alphacell v Woodward. 7. R v Howells. 8. Gammon (Hong Kong) Ltd v Attorney-General of Hong Kong [1985].
9. Sweet v. Parsley (1970).
10. Salabiaku v. France (1988).
11. R v. Lambert (2001).
12. Allen v. Whitehead. 13. WINSON [1969] 1 QB 371 at 382. 14. DPP V H [1997] 1 WLR 1406.
15. Elias V. Jaffa and Sesay, Supreme Court Decision Delivered by Beoku-Betts, J. On March 31st, 1953, Civil Case No. 206/52.
16. Mary Harding V. Mrs Naba Osaio Khanu & Ors, Judgment Delivered in October 2017 CIV.APP.11/14 51/215.
17. Coppen V. Moore (No 2) [1898] 2 QB 306.
18. Mousel Brothers Ltd v London and North-Western Railway Co [1917] 2KB 836 at 845.
19. PROSECUTOR Against ISSA HASSAN SESAY, MORRIS KALLON, & AUGUSTINE GBAO, Case No. SCSL-04-15-T.
20. Gombui v Hill 1963, SLLR 61.
21. Comptroller of Customs V. Basma, 1920-36 ALR SL 428.
• DICTIONARY 1. Black’s Law Dictionary 9th Edition.
• INTERNET SOURCES
1. https://legalknowledgebase.com/what-is-the-difference-between-vicarious-and-tortious-liability#:~:text=What%20is%20the%20difference%20between%20vicarious%20liability%20and,for%20X%27s%20sale%20to%20Y%20imposes%20vicarious%20liability.
• JOURNAL ARTICLES
1. P. J. Pace, ‘Delegation – A Doctrine in Search of a Definition’ [1982] Crim LR 627.
2. Sykes, Alan O. (January 1988). "The Boundaries of Vicarious Liability: An Economic Analysis of the Scope of Employment Rule and Related Legal Doctrines" Harvard Law Review. 101 (3): 563–609.
• ACTS/STATUTES OF PARLIAMENT
1. Constitution of Sierra Leone, Act No. 6 of 1991.
2. Consumer Protection Act, Act No. 7 of 2020.
3. The Environment Protection Agency Act, Act No. 11 of 2008.
4. The Pharmacy and Drugs Act, Act No. 12 of 2001.
5. The Road Traffic Act, Act No. 5 of 2007.
6. Courts Act, Act No. 31 of 1965.
