2011–12 Papua New Guinean constitutional crisis

More information on this topic can be found in the equivalent article in the French Wikipedia.

Peter O'Neill (left) and Michael Somare (right)

2011–2012 Papua New Guinean constitutional crisis was a dispute between Sir Michael Somare and Peter O’Neill. Both claimed to be Prime Minister of Papua New Guinea.

O’Neill had been elected by parliament as prime minister on 2 August 2011[1] and Sir Michael Somare claimed the post on the basis of a Supreme Court ruling on 12 December 2011.[2] Article 142(2) of the Constitution provides that the Prime Minister is appointed "by the Head of State, acting in accordance with a decision of the Parliament." The Queen’s role is executed by the Governor General.[3] The Governor General had therefore to decide on the actual wish of parliament: the opinion identified by O’Neill or the wish as defined by the Supreme Court.

The situation raised important constitutional issues. The actual crisis cannot be understood as a question of law in the first place. It was part of a longer standing power struggle between opposition and government. O’Neill won that struggle and remained the facto in power after the court ruling. It laid the foundation for his dominance in the PNG political arena. Somare did not admit defeat. The 2012 election, however, gave a clear victory to O’Neill. Somare accepted the outcome and he even supported the election of O’Neill as prime minister.[4] The conflict flared up again during the O’Neill/Dion government period from 2012 to 2017.

Prelude: An end to the Somare era?

The government of Michael Somare was already challenged before the constitutional crisis.[5] The opposition had tried to mount a motion of no confidence since 2009.[6] This was blocked by the speaker, Geoffrey Nape, through adjourning parliament before the motion could be tabled.[7] Somare’s reputation was also dented by a leadership tribunal in 2009.[8] That tribunal, however, treated him lightly.[9] During the tribunal he appointed Sam Abal as acting Prime Minister. Abal was again acting Prime Minister when Somare was hospitalized in Singapore in March 2011. The position of Prime Minister became particularly opaque when Arthur Somare, a son of Michael Somare and an MP as well, announced in June 2011 on behalf of the family that Somare had spent three weeks in intensive care and could not be expected to resume work as prime minister.[10] Arthur Somare positioned himself in this way for the post. The legality and validity of this statement was challenged immediately as Michael Somare had not been heard himself.[11]

In this uncertain situation the opposition mounted another motion of no confidence. The success of such a motion was not certain at all.[12] The government of Michael Somare had been established with the support of a large majority in parliament (86 out of 109 votes).[13] Somare had already lost the support of some MPs when the Supreme Court loosened the restrictions on MPs to change sides. A previous attempt to mount a vote of no confidence by breakaway ministers and MPs led by Puka Temu had been unsuccessful. Somare's majority could only be confidently challenged if there was a revolt in his party, the National Alliance (NA). It was also vital that the Speaker would change sides, as he had obstructed previous attempts. When the speaker did so and allowed an open vote for a new government, the parties supporting the Somare government split. NA divided in a breakaway group itself under the leadership of DonPolye (21 MPs), opposed to a group that remained loyal to Sam Abal and Michael Somare (20 MPs).[14][15]

The revolt proved successful. Peter O’Neill became the new Prime Minister with the support of 70MPs out of a 109-member parliament. However, O’Neill's People’s National Congress (PNC) had only six seats in parliament. PNC had supported the Somare government since 2007. Belden Namah and Mekere Morauta of the main opposition PNG party led the revolt, but they did not become prime minister. Namah, the leader of the opposition, became deputy Prime Minister. He had also been part of the Somare government. Don Polye, who had led the revolt in NA, became the Minister for Finance and the Treasury. He had been strongly tipped for the post of Prime Minister.[16][17] It was thus to a large extent a revolt from within.

Mekere Morauta on the contrary had been the prime opponent of the Somare government. He did not become involved in the ensuing struggles surrounding the legality of the first O’Neill government. Instead, he used this position to fight a vigorous cleanup campaign of public enterprises in which he attacked especially the heritage of his predecessor, Arthur Somare.[18]

The government of Somare/Abal was not defeated by a motion of no confidence. In that case the position of O’Neill would have been unequivocally covered by law. It is puzzling that instead, the Speaker had allowed a motion to declare the post of Prime Minister vacant because of illness. That possibility was covered in the Constitution in section 142(5,c) on the grounds: "that two medical practitioners appointed by the National Authority responsible for the registration or licensing of medical practitioners have jointly reported in accordance with an Act of the Parliament that, in their professional opinions, the Prime Minister is unfit, by reason of physical or mental incapacity, to carry out the duties of his office."[3] Parliament had approached the Papua New Guinea Medical Board for such a mission to Singapore at the beginning of Somare’s hospitalization.[19] Nothing came of that.

The next possibility envisioned concerned the absence of a Member of Parliament, and because the PM is an MP in a Westminster parliamentary system, this is therefore applicable to the Prime Minister. The relevant section 104 (d) of the Constitution reads: "if he is absent, without leave of the Parliament, during the whole of three consecutive meetings of the Parliament unless Parliament decides to waive this rule upon satisfactory reasons being given".[3]

Somare had been absent since March but his reasons were accepted by parliament and he was granted leave until May 2012. Parliament then withdrew this leave. However, in early September Somare returned to PNG and declared that he was willing and able to finish his term of prime minister. On 6 September he made a brief appearance in the chamber and therefore the rule of missing three consecutive meetings no longer applied.[20] On 9 December, Parliament amended the law to state that an absence of ninety days would make a parliamentary seat vacant.[21] The Supreme Court would give a judgment on the legality of the O’Neill government on 12 December 2011.

The Supreme Court came unequivocally down on the side of Somare. There was no legal vacancy in the office of Prime Minister when O’Neill was elected. The Speaker’s decision to declare a vacancy in Somare’s parliamentary seat in East Sepik was similarly unconstitutional and void. Somare should have been reinstated as Prime Minister.[22]

The factual situation did not change: O’Neill remained in charge. The Supreme Court heard the case again in May 2012 and came again down in favor of O’Neill. The deputy speaker accepted the Supreme court ruling, but declared the seat again immediately vacant on the ground that Somare had been absent for 90 days. He referred to the change in law that parliament had passed on 9 December just before the Supreme Court's decision. O’Neill was therefore again elected as Prime Minister.[23]

The Supreme Court ignored the change of law of 9 December 2011. It was also not valid on 12 December, as the Speaker of Parliament still had to certify the change of law. This brought to the fore the issue of constitutional law. The Constitution stresses separation of powers. According to those on the side of O’Neill, this implies that the Court cannot exercise executive decision making. The constitutional court can only judge on the constitutionality of a law or general measure. In this case, they were seen to encroach on the power of parliament. The legal battle was a conflict on the sovereignty of parliament.[24]

The political battle

The essence of the PNG constitutional crisis in 2011-2012 was thus whether parliament was supreme or whether the separation of powers implied that parliament was under control of the judiciary. This was not in the first place a legal battle, but a political one. It was a struggle for political support. The O’Neill/Namah government obtained that support immediately in August 2011. The PM and cabinet were recognized by the Crown through the Governor-General, Michael Ogio. It also immediately gained international recognition, and the approval of Australia was especially vital.[25]

There remained some pockets that were loyal to Michael Somare. For example, the court case challenging the legality of the O’Neill/Namah government was opened by the Provincial government of East Sepik, the home base of the Somare family.[26] Nevertheless, the O’Neill/Namah government seemed safe. The judgment of the Supreme Court on 12 December 2011 was therefore a shock.

Somare immediately announced a new cabinet and had his cabinet sworn in by the Governor General. Somare himself did in his opinion not need to be sworn in, as that had happened already when he became PM again in 2007. Parliament protested strongly against this. Ogio was suspended and the speaker of parliament, Jeffrey Nape, became acting Governor General. Nape then swore in O’Neill and his cabinet. Civil society organisations, especially churches, offered to mediate.[27] O’Neill refused on the ground that it is up to parliament to form the government and not forces outside the chamber.

Somare did not come into parliament and was with his cabinet in an Ela Beach hotel. He had the support of about 20 MPs.

Ogio was therefore supporting a government that did not have a majority on parliament and his position became thus untenable. He changed his mind and supported the O’Neill government. Parliament ended his suspension.[28][29]

The dispute was about the power of parliament, but this does not mean that the conflict was fought with parliamentary procedures. For example, MPs stormed the house of the Governor-General when he supported Somare. It is thus not surprising that control over the police was one of the main issues during the stalemate. Somare immediately appointed Fred Yakasa as police commander. Yakasa controlled the armed response unit of the police. That unit had remained loyal to Somare and had prevented O’Neill from entering the Governor-General’s office (government house). O’Neill relied on his own appointment: Thomas Kulunga. Yakasa turned to the courts and got a restraining order that he was not to be harassed. The threat of arrest was no longer there, but Kulunga disarmed Yakasa’s unit a few days later.[30][31]

O’Neill had control over parliament, the public service, the police and the army. Nevertheless, Somare did not accept his defeat. At the end of January he walked into parliament showing the court order and demanding a seat. O’Neill replied with a threat of arrest.[32]

The control over the army was challenged towards the end of January. A retired army officer, Colonel Yaura Sasa, claimed to have been appointed as army commander by Somare. He stormed the main barracks in Port Moresby with a group of soldiers, and took the army commander Frances Agwi hostage. Sasa presented his intervention as an attempt to mediation: he wanted to force both parties to return to parliament and forge a consensus. Vice president Belden Namah, a former ex army officer, announced the arrest of 15 of the 30 soldiers involved as well as the arrest of Sasa.[33][34]

The fight to control the judiciary was the most bitter fight of the O’Neill government. It was originally fought on grounds that were not germane to the issue of legitimacy of the O’Neill government. The National Executive Council has no power over the appointment of judges; that is a prerogative of the Legal and Judicial Services Commission. The NEC (Cabinet), however, has the power of appointment over the Chief Justice and it used these powers during the constitutional crisis.

Chief Sir Injia Salamo was dismissed in early November on various grounds of personal misbehaviour. The main claim was stealing from the estate of a deceased judge entrusted to the courts. This was one month before the Supreme Court had to rule over the constitutionality of the O’Neill/Nama government.[35] The Supreme Court reacted with a charge of contempt of court for the attorney general Alan Marat and the deputy PM Belden Namah. The police commander followed this up and detained them briefly.[36] The move against Injia Salamo was made under the leadership of the deputy Prime minister, Belden Namah.

O’Neill was at the time out of the country and declared himself not in sympathy, but he assuaged the situation by declaring that under the consititution the Chief Justice could continue to sit ion the bench despite disciplinary procedures against him. The NEC withdrew the charges.[37]

The Supreme Court comprising all five judges met on 12 December 2011 and decided that the seat of PM as well as of MP in East Sepik were not vacant and O’Neill’s position was unlawful. The court came down in the case against O’Neill with a three to two majority.[37]

The Governor General proceeded to recognise the Somare government while parliament continued to support O’Neill. The court decision was ignored by the O’Neil government and ultimately the Governor General also gave in. The government was not satisfied and pursued the conflict with the Supreme Court further. In February there was another attempt to suspend the Chief Justice on grounds of personal misbehaviour, and a panel of judges was mentioned to look at misconduct by Injia Salomo. This charge was stayed shortly thereafter by the National Court. Despite this, Salomo was forcibly arrested on 6 March and charged. The National Court met on 13 March on the case and permanently stayed the charges, as these were flawed.[38]

Thereafter the government tried a new tack to get rid of the Supreme Court judges, and announced a Judicial Conduct Bill that brought disciplining the judiciary effectively under political control instead of under the control of the Judicial Service Commission. Very soon after enacting the law two Supreme Court judges, Injia and Nicholas Kiriwom, were mentioned for disciplinary action to the Governor-General. Kiriwom had organised a protest meeting against the treatment of Injia. This led to widespread protests in the country, such as a massive student protest march.[39]

The Supreme Court proceeded to hear the case again as to whether O’Neill was the lawful prime minister. The government asked Injia and another justice to recuse themselves from the case because of personal interests in the case. That, similar to the arrest under the Judicial Conduct Bill, would have reduced the votes against O’Neill to a single one.

At the end of May 2012 the Supreme Court decided and came down again in favour of Somare, this time with three out of five judges while two withheld judgment. Belden Namah, the deputy PM, stormed the court and took Injia Solomon and Nichlas Kirwonto in detention. The government charged them with sedition on the accusation that they had created chaos in the country.[40]

In the meantime elections were looming and these would be the definite determinant who would rule PNG. That line was strongly taken by the new Australian Minister of Foreign Affairs, Bob Carr.[41] There were strong forces to postpone the elections. Parliament of PNG even voted for a delay of six months. However, the decision to hold elections was in the hands of the Electoral Commission. There was widespread protest against this proposal.[42][43] The plan to postpone was shelved. By the time the second Supreme Court decision was taken, parliament was dissolved and electioneering was in full swing.[44]

Conclusion: the long-term effects

Peter O’Neill’s party obtained most seats in the 2002 and 2007 elections and therefore he had the right to form a government. A clear majority coalition in parliament elected him as prime minister in both cases. He faced many legal challenges on governance grounds, which he successfully deflected. The only case where the executive was defeated was over the challenge over the Manus Island detention centre, which the courts declared unconstitutional.[45]

However, that did not challenge the right of O’Neill to his position. The power structure established during the constitutional crisis of 2011-2012 proved to be enduring: a politician who has the support of a clear majority in parliament can dominate over the whole government apparatus, including the courts.[46]

O’Neill has dominated the political competition since 2011 and the other protagonists in the constitutional crisis have been overshadowed.

Somare's National Alliance Party was truncated from 20 to 6 seats in 2012. It was a surprise that he supported the coalition behind O’Neill despite his great enmity with O’Neill before the election.[47] Somare never did really accept his defeat in 2011. He reached an out of court settlement of one million Australian dollars as indemnity for his illegal removal from office in 2011.[48]

In November 2014 Somare withdrew his support for the ruling coalition. He advocated that Peter O’Neill should face a leadership tribunal because of his handling of the controversial UBS loan to acquire equity in the Oil Search company.[49] In November 2016 he resigned from the National Alliance Party.[50] Almost immediately after that he proclaimed jointly with his old foe Mekere Morauta the need for investigation of O’Neill’s handling of the UBS loan by international and local agencies because of the alleged fraudulent nature of the deal.[51]

Somare decided no longer to stand for office in the 2017 election and retired from politics. His most prominent son Arthur had lost his Sepik seat in 2012 and did not run in 2017. Dulianan Somare Brash, his youngest daughter, contested the West Sepik regional seat that had been secure for Michael Somare in his whole career; she lost. The constitutional crisis led to a decline of the Somare clan that may be final.

The National Alliance Party (NA) survived the split in 2011.[52] It still gains most of its seats in the highlands, but it became a very different entity. It survived the departure of the Somare family, and in the 2017 elections they were the second largest party.

The loyalists to Somare succeeded in the expulsion of Don Polye and his friends. Polye founded the True Heritage Empowerment Rural Party (THE). THE party was second in the 2012 elections, with 12 seats. Polye became treasury minister but fell foul of O’Neill. O’Neill bypassed him when Polye objected to the UBS loan.[53] He was more kicked out of government than that he resigned.[54] In the 2017 elections Polye lost his seat and THE party gained only three seats.

Belden Namah, the deputy prime minister, was relegated to the opposition after 2012. He has since been the accused in several court cases and tribunals.[55]

Mekere Morauta resigned from politics in 2012, but came back to challenge O'Neill.[56][57] He won his seat,[58] but the grand coalition against O’Neill did not come off.[59]

References

  1. ↑ Prime Minister Peter O’Neill. Available at: http://www.pm.gov.pg/about/about-2/ No date on posting. Accessed on 1 July 2018
  2. ↑ Staff and agencies (14 December 2011). "Papua New Guinea in Crisis as two claim to be prime minister". Retrieved 2 September 2018.
  3. 1 2 3 Constitution of the Independent State of Papua New Guinea http://www.parliament.gov.pg/constitution-of-the-independent-state-of-papua-new-guinea No date on posting. Accessed on:1 July 2018
  4. ↑ Sean Dorney, Papua New Guinea’s democracy at work http://www.abc.net.au/news/2012-08-07/an-sean-png-election-feature/4182648 Posted on: 7 August 2012 Accessed on: 1 July 2018
  5. ↑ R.J. May, Sir Michael Somare and PNG politics. Available at: http://www.devpolicy.org/sir-michael-somare-and-png-politics20110520/ Posted on: 20 May 2011 Accessed on: 1 July 2018
  6. ↑ Opposition withdraws no confidence motion. Available at: http://asopa.typepad.com/asopa_people/2009/10/opposition-withdraws-no-confidence-motion.html Posted on: 23/10/2009 Accessed 1 July 2018
  7. ↑ Liam Fox: PNG parliament chaos as Somare dodges no confidence vote Avasilable at: http://www.abc.net.au/pm/content/2010/s2960384.htm Posted on: 21 July 2010 Accessed on: 1 July 2018
  8. ↑ Papua New guinea PM steps down for tribunal. Available at: https://www.bbc.com/news/world-asia-pacific-11990157 Posted on: 14/12/2010 Accessed on: 1 July 2018
  9. ↑ Sir Michael Suspended. Available at: https://www.thenational.com.pg/sir-michael-suspended/ Posted on: 25 March 2011 Accessed on: 1 July 2018
  10. ↑ Ailing PNG leader Somare retiring: family. Available at: http://www.abc.net.au/news/2011-06-28/ailing-png-leader-somare-retiring-family/2775212 Posted on 28 June 2011 Accessed on: 1 July 2018
  11. ↑ Family urges Sir Michael Somare to quit as PNG leader but PM’s office denies resignation. Available at: https://www.theaustralian.com.au/news/world/sir-michael-somare-quits-as-png-leader/news-story/302839d1a7acbe13740393dac8fbbb61?sv=a8aceb9611d7522f45299c4a246083f8 Posted on 28 June 2011
  12. ↑ Bill Standish: When the Grand chief is away Papua New guinea’s big man politics. http://www.eastasiaforum.org/2011/06/27/when-the-grand-chief-is-away-papua-new-guinea-s-big-man-politics/ Posted on: 27 June 2011
  13. ↑ Papua New Guinea PM reelected- Michael Somare wins Second consecutive term in an uncontested vote. https://www.aljazeera.com/news/asia-pacific/2007/08/200852514415744579.html Posted on: 13 August 2007 Accessed on: 1 July 2018
  14. ↑ PNG National Alliance party suspends Abal http://www.pireport.org/articles/2011/07/26/png-national-alliance-party-suspends-abal Posted on 26 July 2011 Accessed 1 July 2018
  15. ↑ More ructions in PNG’s National Alliance. Available at: https://www.radionz.co.nz/international/pacific-news/198668/more-ructions-in-png%27s-national-alliance Posted on 1 August 2018 Accessed 1 July 2018
  16. ↑ Bill Standish PNG’s new prime minister: Peter O’Neill. Available at: http://www.eastasiaforum.org/2011/08/11/pngs-new-prime-minister-peter-o-neill/ Posted on 11 August 2011 Accessed on 7 July 2017
  17. ↑ Ron May, Papua New Guinea’s "Political Coup": The Ousting of sir Michael Somare. Available at: https://openresearch-repository.anu.edu.au/bitstream/1885/141449/1/BriefNote_2011_1_May_0.pdfPosted on: 1 November 2011 Accessed on: 1 July 2018
  18. ↑ IPBC: Unfinished Business, Speech by Rt Hon Mekere Morauta KCMG MPMinister for Public Enterprises, Dinner hosted by IPBC, 12 July 2012. Available at: http://www.kch.com.pg/unfinished-business/ Accessed on: 6 November 2017
  19. ↑ R.J. May, Papua New Guinea’s "Political Coup" The Ousting of Michael Somare Briefing note 1/2011 from State, Society and Governance in Melanesia /Australian National University p.3. Available as pdf through: http://dpa.bellschool.anu.edu.au/ssgm-research-communication/discussion-paper-series Accessed: 7 July 2018
  20. ↑ R.J. May, Papua New Guinea’s "Political Coup" The Ousting of Michael Somare Briefing note 1/2011 from State, Society and Governance in Melanesia /Australian National University p.4. Available as pdf through: http://dpa.bellschool.anu.edu.au/ssgm-research-communication/discussion-paper-series Accessed: 7 July 2018
  21. ↑ Peter Donigi, Constitutional Technicalities: Why is O’Neill is PNG’s Prime Minister. Available at: https://garamut.wordpress.com/2011/12/28/constitutional-technacalities-why-oneill-is-pngs-prime-minister/ Posted on 28/12/2011Accessed on: 7 July 2018
  22. ↑ Anthony Latimer, PNG constitutional crisis. Available at: http://www.nortonrosefulbright.com/knowledge/publications/61068/png-constitutional-crisis Posted on: December 2011. Accessed on: 7 July 2018
  23. ↑ Nick Perkins, Judicial Independence around the world. Available at: https://constitution-unit.com/2012/06/08/judicial-independence-across-the-world-papua-new-guinea/ Posted on 8 June 2012
  24. ↑ Peter Donigi, Constitutional Technicalities: Why is O’Neill is PNG’s Prime Minister. Available at: https://garamut.wordpress.com/2011/12/28/constitutional-technacalities-why-oneill-is-pngs-prime-minister/ Posted on 28/12/2011Accessed on: 7 July 2018
  25. ↑ Gregory B. Poling: Constitutional crisis erupts in Papua New Guinea. Available at: https://www.csis.org/analysis/constitutional-crisis-erupts-papua-new-guinea Posted on: 16/12/2011 Accessed on 18 July 201
  26. ↑ Bill Standish: Crises compounded; Papua New Guinea politics in November 2011 Available. at: http://www.devpolicy.org/crises-compounded-papua-new-guinea-politics-in-november-2011-20111114/ Posted on: 14 November 2011 Accessed on 18 July 2018
  27. ↑ Churches, civil societies seek a collaborative route out of PNG political impasse. Available at: https://www.radionz.co.nz/international/pacific-news/201521/churches,-civil-society-seek-collaborative-route-out-of-png-political-impasse Posted on: 16/12/2011 Accessed on 18 July 2018
  28. ↑ "Governor-General Michael Ogio suspended for backing Michael Somare". Available at: http://www.theaustralian.com.au/news /world/governor-general-michael-ogio-suspended-for-backing-michael-somare/story-e6frg6so-1226222379427 The Australian, 15 December 2011 Accessed: 16 July 2015
  29. ↑ "End of PNG GGs suspension". Available at: http://www.radionz.co.nz/international/pacific-news/201598/end-of-png's-gg-suspension-weakens-somare-bid-for-power Radio New Zealand Inernational 19/12/2011 Accessed on: 17 July 2018
  30. ↑ Rowan Callick, Judge to protect police chief after claims his actions "border on treason". Available at: https://www.theaustralian.com.au/news/world/somare-appointee-found-legal-commissioner/news-story/9262b1f8cce983f71af0fa4ddb533b92?sv=65e1eae05ab3be92442532a86972b4e6 Posted on:18/12/2011 Accessed on: 17 July 2011
  31. ↑ Kulunge asserts his position. Available at: http://www.pireport.org/articles/2011/12/20/kulunga-asserts-his-position-png-police-commissioner Posted on 20/12/2011 Accessed on: 17 July 2011
  32. ↑ Liam Fox: Rowdy scenes as Somare returns to parliament. Available at: http://www.abc.net.au/news/2012-01-18/somare-could-be-arrested/3781442 Posted on: 18 January 2011 Accessed on: 17 July 2011
  33. ↑ Liam Fox: Rebel soldiers stage mutiny in PNG. Available at: http://www.abc.net.au/news/2012-01-26/military-mutiny-underway-in-png/3794314 Posted on 26 January 2012 Accessed on: 17 July 2011
  34. ↑ Liam Fox: PNG leader claims end to mutiny. Available at: http://www.abc.net.au/news/2012-01-26/png-story/3795348 Posted on: 26 January 2012 accessed on: 17 July 2011
  35. ↑ Bill Standish: Crises compounded; Papua New Guinea politics in November 2011 Available at: http://www.devpolicy.org/crises-compounded-papua-new-guinea-politics-in-november-2011-20111114/ Posted on: 14 November 2011 Accessed on 18 July 2018
  36. ↑ PNG court orders arrests of two MPS. Available at: http://www.abc.net.au/news/2011-11-11/court-orders-arrest-of-png-mps/3660584PNG Posted on: 11 November 2011 Accessed on: 18 July 2018
  37. 1 2 Liam Fox: PNG stand by decision to suspend top judge. Available at: http://www.abc.net.au/news/2011-11-13/png-stands-by-decision-to-suspend-top-judge/3663198 Posted on: 13 November 2011 Accessed on: 18 July 2018
  38. ↑ Justice Logan: A year in the life of an Australian member of the PNG Judiciary. Available at: http://www.fedcourt.gov.au/digital-law-library/judges-speeches/justice-logan/logan-j-20130415 Posted on: 15 April 2013 Accessed on 18 July 2018
  39. ↑ Tarvurvur: Why the judicial conduct Act 2012 is dangerous. Available at https://garamut.wordpress.com/2012/03/29/why-the-judicial-conduct-act-2012-is-dangerous/ Posted on 29 March 2012 Accessed on 18 July 2018
  40. ↑ Nick Perkins, Judicial Independence around the world: Papua New Guinea. Available at: https://constitution-unit.com/2012/06/08/judicial-independence-across-the-world-papua-new-guinea/ Posted on: 8 June 2012 Accessed on: 12 July 2018
  41. ↑ Daniel Flitton: Carr threatens to hit PNG with sanctions. Available at: https://www.smh.com.au/politics/federal/carr-threatens-to-hit-png-with-sanctions-20120315-1v3zs.html Posted on: 15 March 2011 Accessed on: 12 July 2018
  42. ↑ AAP: PNG defied Carr to postpone vote. Available at: https://www.news.com.au/world/png-defies-carr-to-postpone-vote/news-story/a4d2655af51c998e1f5f057ed10e0152 Posted on: 5 April 2011
  43. ↑ Liam Fox, PNG pressured over election date. Available at: http://www.abc.net.au/news/2012-04-23/png-pressured-over-election-date/3965708 Posted on: 23 April 2012
  44. ↑ Liam Fox, PNG court ordered Somare to be reinstated, Posted on 22 May 2012. Available at: http://www.abc.net.au/am/content/2012/s3507867.htm Posted on: 22 May 2012 Accessed on: 12 July 2018
  45. ↑ Madeline Geeson: PNG court decision forces Australia to act on Manus Island detainees. Available at: https://theconversation.com/png-court-decision-forces-australia-to-act-on-manus-island-detainees-58439 Posted on: 27 April 2016 Accessed on: 12 July 2018
  46. ↑ Papua New Guinea under the O’Neill government. Has there been a shift in political style. Available at: http://ssgm.bellschool.anu.edu.au/sites/default/files/publications/attachments/2017-08/dp_2017_6_may.pdf Posted on: 16 July 2017 Accessed on: 12 July 2018
  47. ↑ PNG leaders Somare and O’Neill form joint Government. Available at: https://www.bbc.com/news/world-asia-18979412 Posted on: 25 July 2012 Accessed on: 12 July 2018
  48. ↑ Liam Cochrane: PNG ‘s ousted prime minister paid almost $ one million for "illegal removal". Available at: http://www.abc.net.au/news/2015-08-12/png-ousted-prime-minister-paid-1-million-for-ilegal-removal/6690936 Posted on: 13 August 2015 Accessed on: 12 July 2018
  49. ↑ Sir Michael Somare MP, Why I moved to the middle bench http://www.pngblogs.com/2014/11/why-i-moved-to-middle-bench.html Posted on: 25 November 2014. Accessed on: 12 July 2018
  50. ↑ Girish Sawiani, Michael Somare resigns from the Papua New Guinea Party he founded. Available at: http://www.abc.net.au/news/2015-10-12/michael-somare-resigns-from-papua-new-guinea-party-he-founded/6848060 Posted on:7 February 2016 Accessed on: 12 July 2018
  51. ↑ Helen Davidson: Papua New Guinea prime minister must resign say former leaders. Available: https://www.theguardian.com/world/2016/jul/20/papua-new-guinea-prime-minister-peter-oneill-must-resign-say-three-former-leaders Posted on:20 July 2016 Accessed on: 12 July 2018
  52. ↑ Blair Price: NA splits after Somare dismissal. Available at: https://www.pngindustrynews.net/government/news/1102868/na-splits-after-somare-dismissal?source=pngindustrynews Posted on:9 September 2011. Accessed on: 12 July 2018
  53. ↑ Prime Minister pushes through controversial loan. Available at: http://country.eiu.com/article.aspx?articleid=1061683290 Posted on: 1 April 2014 Accessed on: 12 July 2018
  54. ↑ Liam Cochrane. PNG Prime minister O’Neill sacks treasurer for causing instability. Available at: http://www.abc.net.au/news/2014-03-11/an-png-pm-sacks-treasurer-polye/5311526 Posted on 10 March 2014 Accessed on: 12 July 2018
  55. ↑ Bonnie Kaiyo: Belden Namah: Tribunal- the development and drama. Available at: http://news.pngfacts.com/2017/11/belden-namah-tribunal-developments-and.html No date for posting Accessed on: 12 July 2018
  56. ↑ ‘PNG’s Morauta slams O’Neill on the economy’ Radio New Zealand 04/24/2016. Available at: http://www.radionz.co.nz/international/pacific-news/304690/png%27s-morauta-slams-o%27neill-on-the-economy Accessed 31 July 2017
  57. ↑ ‘Sir Mekere announces nomination’ Posted on 04/25/2017 on https://www.mekeremorauta.net/single-post/2017/04/25/Sir-Mekere-announces-nomination Accessed on: 31 July 2017
  58. ↑ Eric Haurupma Sir Mekere Morauta officially declared member elect for Port Moresby North West. Available at: http://www.emtv.com.pg/news/2017/07/sir-mekere-morauta-officially-declared-member-elect-for-moresby-north-west/Posted on: 07/27/2017 Accessed on: 31 July 2017
  59. ↑ Move by Basil is disappointing. Available at: https://www.mekeremorauta.net/single-post/2017/09/12/Move-by-Basil-is-disappointing-Sir-Mekere Posted on: 2 September 2017 Accessed on: 31 July 2017
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