The National Resistance Movement (NRM) electoral tribunal has nullified the election of Collins Tanga as Chairperson of the party’s Youth League, citing widespread irregularities, procedural violations, and a serious conflict of interest involving his father, Dr. Tanga Odoi, the NRM Electoral Commission Chairperson.
The contentious election, held at Kololo Independence Grounds from August 26–27, 2028, faced opposition from three candidates, Brenda Kiconco, Wilson Otto, and Mackline Natukwasa, who filed petitions citing manipulation, conflict of interest and unlawful exclusion from the process.
In its verdict, the tribunal identified critical flaws in the electoral exercise, including voter disenfranchisement and non-compliance with party guidelines.
It also deemed Dr. Tanga Odoi’s direct involvement in overseeing an election featuring his son as a candidate a clear conflict of interest that compromised the integrity of the proceedings.
During the hearing, Kiconco was represented by legal counsel Emmanuel Ekima, Sulaiman Mayanja, and Phillip Aryatuha. Collins Tanga was defended by counsel Caleb Alaka and Joseph Kabonge, while Dr. Tanga Odoi engaged Moses Kabega as his legal representative.
Meanwhile, Wilson Otto and Mackline Natukwasa presented their cases without the aid of lawyers.
The tribunal’s panel, chaired by John Musiime, supported by Diana Kasabiiti and Esau Isingoma, heard arguments that included claims by Kiconco that she had actually received 1,355 votes compared to Tanga’s 1,167. She alleged that 400 votes were unlawfully added to Tanga’s tally, inflating it to 1,567 and wrongly securing his victory as Chairperson.
Kiconco further criticized the election process for being compromised by the conflict of interest posed by Dr. Tanga Odoi overseeing an election in which his biological son was a candidate.
She argued that such a scenario not only created grounds for perceived collusion but also undermined the impartiality and legitimacy of the entire electoral process.
A central issue raised by Kiconco was age eligibility. She relied on the National Youth Council Act, which defines a youth as a person aged between 18 and 30 years, and argued that this statutory definition ought to govern eligibility for leadership in the NRM Youth League, a body she asserts represents a constitutionally recognized special interest group under Article 32 of the Constitution. According to her, Tanga, who was 31 at the time of nomination, was ineligible, and the failure by Dr. Odoi to enforce this age ceiling facilitated his son’s candidacy unlawfully.
In support of her petition, Kiconco tendered an audio recording, which she alleged captured the vote count halting at 1,167 for the First Respondent.
Additionally, she presented seven video clips purportedly depicting Dr. Odoi whispering to the Presiding Officer, Ambassador James Kinobe, during the tallying process.
She further criticized Dr. Odoi for appending his signature to both the Final Declaration of Results Form and the Detailed Results Form, in contravention of the regulations that require such forms to be signed only by the designated Presiding Officer.
Her case was corroborated by the sworn statements of several delegates, namely Ndiyo Jackson, Byaruhanga Augustine, Kabasinguzi Shamim, Abiriga Yusuf, and Metaloro Godfrey, who testified that Kiconco’s line held the majority but that the tally sheets were manipulated to favour the First Respondent.
She prayed that the Tribunal declare her the duly elected Chairperson or, in the alternative, annul the election and order a fresh poll in accordance with the NRM Constitution, the National Youth Council Act, and the relevant electoral regulations.
Wilson Otto, another Petitioner, also challenged the integrity of the election. He alleged that 292 councillors unlawfully participated in the poll, contrary to established regulations that restrict such councillors to voting in Youth MP elections only.
He further claimed that agents for four candidates, himself, Jacob Eyeru, Hillary, and Mackline Natukwasa, were from the lining-up process, thereby denying them the right to oversee the election.
Otto reiterated concerns regarding the conflict of interest stemming from Dr. Odoi’s continued role in the election despite calls for his recusal due to his familial ties with a candidate.
Additionally, Otto accused the Commission of failing to properly verify delegates, which allegedly allowed non-delegates to vote, some of whom, he claimed, were later arrested.
He also objected to the voting and counting process occurring at night, asserting that this contributed to voter fatigue, irregular participation, and a chaotic tally.
He prayed that the Tribunal annul the results and order a new election conducted in line with NRM electoral procedures.
Mackline Natukwasa, in her petition, contended that she was unlawfully excluded from the election. She asserted that her name was omitted from the final candidate list and that the Commission, through Dr. Odoi, falsely announced her withdrawal during a meeting at State House—an announcement she categorically denied.
She maintained that this misrepresentation humiliated her, misled her supporters, and irreparably tainted the electoral process. She also pointed out an error on the Declaration of Results Form, which erroneously described Tanga as Vice Chairperson rather than Chairperson.
Natukwasa further faulted the Commission for delaying the election by over 37 hours, which she said led many supporters to abandon the process.
She alleged that the lax verification of delegates permitted unauthorized individuals to vote and that conducting the election late at night created confusion and fatigue.
Like the other petitioners, she emphasized the conflict of interest surrounding Dr. Odoi’s involvement, despite repeated warnings about the appearance of bias.
Her petition was supported by affidavits from her agents and delegates, Mbabazi Davis, Odongo Deogracious, Rukundo Thomas, and Twinamatsiko Nicholas, who confirmed she had not withdrawn and was improperly excluded. She sought nullification of the results and requested that a new election be held with Dr. Odoi recused.
In response, the First Respondent, Collins Tanga, maintained that he was lawfully nominated, duly elected, and properly declared as Chairperson. He categorically denied all allegations of fraud, procedural irregularities, and collusion, characterizing the petitions as grievances by losing candidates.
On the question of vote inflation, Tanga relied on the official Declaration of Results forms signed by Ambassador Kinobe, which recorded his tally at 1,567 against Kiconco’s 1,355. He argued that these official forms constitute the legally binding record of the election and outweigh unverified audio and selectively recorded video clips.
He emphasized that the counting was done publicly, over a microphone, and in the presence of candidates’ agents and voting delegates.
Addressing the age eligibility issue, Tanga admitted to being 31 years old at the time of nomination but argued that the NRM Constitution and Election Regulations define youth for party purposes as persons aged 18 to 35.
He submitted that the narrower definition under the National Youth Council Act applies only to state-regulated positions, such as Youth Members of Parliament, and not to internal party structures.
Regarding the alleged conflict of interest, Tanga acknowledged that Dr. Odoi is his father but insisted this did not compromise the integrity of the process.
He noted that the Electoral Commission is comprised of seven members and that the presiding duties were undertaken by Ambassador Kinobe.
According to him, Dr. Odoi’s role was largely ceremonial and limited to announcing results, while operational responsibilities such as verification, lining-up, and tallying were handled by other commissioners.
In reference to Natukwasa, Tanga claimed that she voluntarily withdrew in favour of Ms. Kiconco and that her denial of withdrawal was merely an afterthought.
As to Otto’s claims, he contended that the participation of councillors was consistent with internal party arrangements and that agent representation, delegate verification, and the conduct of the vote were all properly handled.
He attributed the late-night voting to a heavy schedule, rather than intentional manipulation.
He dismissed the audio-visual materials tendered by the Petitioners as unauthenticated and of no probative value and maintained that the forms bore the Presiding Officer’s signature, with Dr. Odoi’s signature being merely an administrative addition.
He prayed that the Tribunal uphold his election, dismiss all three petitions with costs, and affirm his mandate as Chairperson of the NRM Youth League.
The Second Respondent, Dr. Odoi, in his defence, denied all allegations of bias, impropriety, or conflict of interest. While admitting that the First Respondent is his son, he asserted that this relationship did not influence the conduct of the election.
He emphasized that the Electoral Commission operates as a collegiate body of seven commissioners, each with defined roles.
He submitted that Ambassador Kinobe was the Presiding Officer and that Commissioner Juliana Auma handled voter verification.
Dr. Odoi maintained that his role was limited to the formal announcement of results and that he did not influence the process or communicate instructions to Kinobe during tallying, dismissing the video evidence as misconstrued.
On the question of age, Dr. Odoi argued that the nomination process was governed by the NRM’s internal regulations, which define youth as persons aged between 18 and 35. He acknowledged the statutory definition under the National Youth Council Act but submitted that it does not apply to internal party offices. He further clarified that the results forms were validly signed by Ambassador Kinobe, and that his own signature, where present, did not affect the legality or validity of the documents.
His defence was supported by affidavits from fellow commissioners. Ambassador Kinobe affirmed that he personally presided over the vote counting, announced the results publicly, and recorded them accurately on the official forms without interference.
Commissioner Eliab Abaho corroborated this account, describing the election as transparent and the allegations of interference as baseless. Dr. Odoi concluded by denying any form of collusion or misconduct and prayed that all petitions be dismissed with costs.
Tribunal analysis/conclusion
The Tribunal noted the opinion of the Party’s Director of Legal Services, dated 14 April 2025, as a reflection of the considered internal legal position of the NRM.
However, while persuasive, the Tribunal emphasized that such internal legal advice is not binding.
The Tribunal’s mandate remains the interpretation of the Constitution of the Republic of Uganda, national legislation, and the governing Regulations of the NRM.
It was accepted that a divergence exists between the statutory framework, principally the National Youth Council Act and related instruments, which fixes the upper age limit for youth participation at 30 years, and the Party’s internal rules, which extend eligibility to 35 years.
The Tribunal found that, applying the literal rule of interpretation, the NRM Election Regulations of 2025 unambiguously provide for a youth age range of 18 to 35 for purposes of internal Party elections.
In applying a purposive interpretation, the Tribunal found no constitutional conflict. Article 71 of the Constitution affirms the autonomy of political parties to organize and regulate their internal affairs, provided they do not act contrary to national law.
The position of Chairperson of the NRM Youth League is not a statutory office under either the National Youth Council Act or the Parliamentary Elections Act but an internal leadership position within the Party.
Accordingly, the Party’s broader age bracket falls within its constitutional discretion.
The Tribunal further observed that all candidates, including the Petitioners, were nominated and participated in the election under these known Regulations. None raised objections at the point of nomination concerning age eligibility.
To challenge a candidate’s eligibility only after the outcome is known is inconsistent with principles of procedural fairness and the maxim that a party cannot approbate and reprobate.
The Tribunal relied on the Court of Appeal’s guidance in Hon. Tumuramye Genensio v. Tayebwa Herbert Musasize and Another (EPA), which held that objections regarding pre-election matters should be raised in the proper forum before polling takes place.
In this case, Regulation 24(k) vests jurisdiction over nomination disputes in the NRM Electoral Commission.
No such objections were filed against the First Respondent’s nomination at the material time, and the belated challenge attracts an adverse inference.
If the effect of the current internal framework is to exclude persons within the statutory youth age range of 18–30 from leadership at the Central Executive Committee level, the Tribunal held that such concerns should be addressed by the appropriate Party organs through amendment.
The Tribunal cannot revise clear internal rules by judicial fiat.
It was not disputed that Mr. Collins Tanga was 31 years old at the time of the election. While he would not qualify under the National Youth Council Act to contest for statutory youth positions, he fell within the 18–35 bracket stipulated by the NRM Constitution and its Election Regulations.
The Tribunal, therefore, found that he was validly nominated and eligible to contest for the position of Chairperson of the NRM Youth League. This issue was answered in the affirmative.
The Tribunal, however, recommended that the Central Executive Committee (CEC) of the Party consider amending the relevant Regulations to harmonize internal definitions of “youth” with the national statutory framework for future coherence and transparency.
On the second issue, whether the conduct, tallying, and declaration of results in the NRM Youth League election complied with the Constitution, Election Regulations, Polling Guidelines, and principles of free and fair elections, the Tribunal reviewed the evidentiary materials presented.
The Petitioners relied in part on an audio recording said to capture the tallying process stopping at 1,167 votes for the First Respondent, and on short video clips allegedly showing Dr. Tanga Odoi influencing the Presiding Officer, Ambassador James Kinobe, during the counting.
The Tribunal found that these audio recordings were partial excerpts, sourced from partisan actors, and lacked any technical basis, chain of custody, or certification of integrity.
In the absence of authentication, the Tribunal ruled that it was unsafe to rely on them and accorded them no probative value.
The same reasoning was applied to the video evidence. Although the videos appeared to show interaction between Dr. Odoi and Ambassador Kinobe, they were fragmentary, brief, and lacked authentication.
In the absence of corroborating testimony, the Tribunal declined to infer manipulation from such limited material.
The Tribunal therefore held that Ms. Kiconco had not discharged the evidential burden of proving that the official Declaration of Results Form was falsified or that the First Respondent’s tally was unlawfully inflated. Accordingly, the allegation of vote inflation was found to be unproven and failed.
However, on the matter of candidate exclusion, the Tribunal noted credible affidavits indicating that Ms. Natukwasa was omitted from the line-up and publicly declared to have withdrawn, and that Mr. Otto’s candidacy was effectively disregarded.
Regulation 32 of the Election Regulations requires that any withdrawal be in writing, signed by the candidate, and witnessed by two registered voters.
No such documentary evidence was produced to substantiate the alleged withdrawals.
The Tribunal therefore found that the exclusion of these candidates was irregular and unsupported by proper procedure.
Regarding the conduct and timing of polling, the Tribunal noted that the election, originally scheduled for 25 August 2025 at 2:00 p.m., was not conducted until approximately 4:00 a.m. on 27 August, following a 37-hour delay.
This significant postponement, in the Tribunal’s view, led to confusion, voter fatigue, and attrition of participants, thereby undermining the transparency and credibility of the electoral process.
The Tribunal took judicial notice that, unlike other NRM Leagues which successfully completed all elections, the Youth League was only able to elect one position before the exercise collapsed.
On the critical issue of conflict of interest, the Tribunal considered whether Dr. Tanga Odoi, as Chairperson of the NRM Electoral Commission, acted impartially in presiding over an election in which his biological son was a candidate. Citing Article 28 of the Constitution, Regulation 45 of the NRM Election Regulations, the Leadership Code Act, and Section 2 of the Anti-Corruption Act, the Tribunal emphasized that both actual bias and the appearance of bias are fatal to fair decision-making.
Dr. Odoi maintained that he did not “participate” in the conduct of the election, contending that verification and tallying were managed by other commissioners, and that he only announced the results. The Tribunal rejected this characterization.
The evidence on record clearly established that Dr. Odoi chaired the proceedings, controlled the public address system, announced alleged candidate withdrawals (notably Ms. Natukwasa’s), and ultimately declared his son the winner.
These acts were not ceremonial—they constituted the substance of presiding over an election.
While the video clips tendered by the Petitioners were insufficient to establish vote manipulation, the Tribunal found that they did corroborate, to a limited but significant extent, Dr. Odoi’s active role in the proceedings.
Furthermore, the Tribunal observed that Dr. Odoi signed both the “Details of Results Form” and the “Final Declaration of Results Form,” which are the principal legal instruments confirming an election. By affixing his signature, he formally authenticated his son’s election.
The Tribunal further noted that the Electoral Commission is a collegiate body of seven commissioners and is capable of functioning in the absence of any one member.
There was therefore no institutional necessity for Dr. Odoi to chair the session or sign instruments in an election where his son was a candidate.
His continued involvement was a matter of personal choice.
The affidavits from Commissioners Kinobe and Abaho, tendered to suggest that Dr. Odoi’s role was minimal, were found to be largely defensive in nature and could not outweigh the objective evidence of his involvement.
Moreover, the Tribunal observed that neither Dr. Odoi nor his counsel specifically addressed the allegations of conflict of interest or improper announcements during the hearing. This silence further fortified the Petitioners’ case.
In conclusion, the Tribunal found that Dr. Odoi’s involvement in presiding, announcing, signing, and ultimately declaring his son as the winner constituted a serious conflict of interest that irreparably compromised the impartiality, credibility, and legality of the election.
A prudent electoral officer in such circumstances would have recused himself entirely and delegated authority to another commissioner. Dr. Odoi failed to do so.
Although the Tribunal could not substitute an alternative winner due to the unreliability of the record and the unresolved exclusion of candidates, it found that the unlawful exclusions, excessive delays, and the Chairperson’s conflict of interest cumulatively and fatally compromised the electoral process.
Accordingly, the Tribunal held that the election of Chairperson, NRM Youth League, was not conducted in compliance with the NRM Constitution, Election Regulations, or Polling Guidelines. This issue was answered in the negative.
Given the tainted process and unreliable record, the Tribunal ruled that no Petitioner could be declared duly elected.
The appropriate remedy, therefore, was the nullification of the election and the ordering of a fresh poll for Chairperson of the NRM Youth League, to be conducted in strict compliance with the Constitution, Regulations, and Guidelines.
To safeguard the integrity of the repeat election and restore public confidence, the Tribunal directed that Dr. Tanga Odoi shall take no part in the conduct of the fresh election. It noted that the Electoral Commission, as a collegiate body, retains full capacity to function and conduct elections without him.
Ruling
The tribunal nullified Collin’s victory and directed the NRM Electoral Commission to organize a new election for the position of Youth League Chairperson.
However, the tribunal barred Odoi from overseeing or participating in any capacity in the fresh election.
“The other commissioners in the Electoral Commission shall conduct the election of the Youth League Chairperson,” the ruling ordered.
