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Judicial Salaries and Allowances: A Needful Upgrade
The issue of the purported increase in salaries and allowances of political office holders, has generated a lot of public discussion over the past week. The overwhelming sentiment of most Nigerians, is against the proposed increase. Many understandably, see any increase as insensitive to current realities, especially given the effect of the removal of petrol subsidy on living conditions. There is certainly an urgent need for a national conversation on the state of wages for all workers in Nigeria, including political office holders. The daily increasing high cost of living, in many ways challenges the Tinubu Administration to find a robust, practical and affordable solution, taking into consideration the unsatisfactory state of our economy. It is however, important to stress that, RMAFC’s proposals for salary increment is what it says it is. It is simply a body of recommendations, for the consideration of the Federal and State Government. It is not true that any approval has been given, either by Mr President or the National Assembly.
In the midst of all the hullabaloo, the matter of judicial officers salaries and allowances seems to have been mixed up, especially with that of political office holders. Judicial Officers are not, and should not be placed in the same category as political office holders. It is to avoid this mix up, and in recognition of the independence and uniqueness of the Judiciary, that the Nigerian Bar Association (NBA), in its memorandum to RMAFC, recommended that Judicial Officers should be remunerated according to an independent salary scale, to be known as the Judicial Service Pay Scale (JSPS). This will further enable judicial salaries to be subject to regular reviews, that are distinct from those carried out in respect of political and other public office holders. They also proposed a separate legislative scheme for salaries, allowances, conditions of service and retirement benefits for Judicial Officers. Including a ‘Judicial Office Holders Entitlements Bill’ to create a Judicial Office Holders Entitlements Panel, to replace RMAFC as it relates to the determination of salaries and allowances of Judicial Officers. This Day Lawyer has been in the forefront of the campaign, for an urgent review of Judicial Salaries and Allowances. As we have stated on multiple occasions, appointment to the Bench should not be an invitation to penury. It is unacceptable that Judicial Officers in Nigeria, have remained on the same salary for about 15 years. Penny-pinching should have no place, in the way we administer justice in Nigeria. RMAFC’s recommendations on the review of judicial remuneration, are undoubtedly well thought out. It is however, our respectful view that the recommendations fall short of expectations. Having waited for close to two decades for this review, it goes without saying that the recommendations must be groundbreaking in every sense of the word. In this special edition, Olawale Fapohunda, SAN, Alternate Chairman of the NBA Working Committee on Judicial Remuneration and Conditions of Service and This Day Lawyer, re-emphasise the urgent need for the upward review of judicial remuneration. We compare and contrast the RMAFC Recommendations on the reviewed remuneration package for Judicial Officers, with that of the NBA proposals for the review of remuneration of Judicial Officers. We have highlighted additional areas that require further attention. In all, it must be said that the Tinubu administration should avoid being enmeshed in unhelpful debates, on whether or not the time is appropriate for a review of judicial remuneration. The inability of successive governments to make progress on the issue of fair and reasonable judicial remuneration, has dampened the morale of the Judiciary. Judicial Officers across Nigeria are struggling with everyday challenges, brought about by poor conditions of service. This state of affairs is not good for the administration of justice, and the sustainability of our democracy
About Revenue Mobilisation Allocation and Fiscal Commission (RMAFC)
The Revenue Mobilisation Allocation and Fiscal Commission (RMAFC), is one of the 14 Executive bodies established by Section 153(1) of the 1999 Constitution of the Federal Republic of Nigeria (as amended). The mandate of the Commission as outlined in paragraph 32(d), Part 1 third schedule of the Constitution, among others is to determine the remuneration appropriate for political office holders, including the President, Vice President, Governors, Deputy Governor, Minister, Commissioners, Special Advisers, Legislators and Judiciary. It was in exercise of its powers, that the RMAFC invited Justice Sector Stakeholders to propose recommendations for the review of judicial remuneration.
NBA Recommendations for Review of Judicial Salaries and Allowances
The Nigerian Bar Association (NBA), a key justice sector stakeholder, presented a memorandum to RMAFC identifying a basket of factors in determining appropriate judicial remuneration. These are –
(a) the need to protect judicial independence;
(b) the current state of judicial remuneration;
(c) the responsibility, working condi tions and workload of Judges;
(d) recruitment into the Judiciary;
(e) retirement benefits of Judges;
(f) benefit and allowances enjoyed by Judges;
(g) overseas remuneration arrangements.
The NBA made the following recommendations on judicial salaries and allowances, for the consideration of RMAFC
Annual Basic Salary
Judicial officers have been on the same salary structure, for more than a decade. Nigeria is lagging behind on the issue of judicial remuneration when compared with a number of African Countries, including Ghana and South Africa. For these reasons and the need to achieve the recruitment of exceptionally qualified persons, and ensure the attractiveness of the Judiciary as a career for potential applicants, an increase of 200% was proposed across the board for all judicial officers.
Allowances and Fringe Benefits
The NBA observed the need to revisit current judicial allowances, recognising that the package of benefits and allowances is an integral part of judicial remuneration. These can help enhance the living conditions of judicial officers.
(a) Medical Allowance: For reasons relating to the workload and complexity of judicial work including its effect on the health of judicial officers, 40% of the basic salary was proposed as Medical Allowance for minor ailments that do not require hospitalisation, while other medical needs including overseas medical treatment and in-patient medical treatment in local medical institutions, should continue to be subject to necessary approvals that obtain currently.
(b) Accommodation Allowance. In view of the nature of judicial work, which among others, places a burden on judicial officers to be selective in their place of abode, and given the high cost of accommodation in highbrow areas, 100% of annual basic salary was proposed across board for all judicial officers.
(c) Leave Allowance: 10% of the basic salary, is currently paid as leave allowance for judicial officers. This amount is however, inadequate for judicial officers going on a short vacation within Nigeria or outside Nigeria. An increase of 100% of annual basic salary paid once a year, was proposed for all judicial officers.
(d) Hardship Allowance: The present allowance is 50% of the basic salary, for all category of judicial officers. We recommended an upward review of the percentage to 100% annual basic salary for judicial officers, in view of the increasingly difficult work environment
New Allowances
The NBA also proposed new allowances in recognition of the peculiar demands of the judicial office that deserve compensation, but are not presently included in allowances available to judicial officers:
(a)Restrictive Lifestyle Allowance. This was proposed in recognition of the limitations on lifestyle of judicial officers, imposed by the Judicial Code of Conduct. A lifestyle allowance of 100% of annual basic salary, was proposed for all categories of judicial officers.
(b)Dual Responsibility Allowance. This was proposed, in recognition of the peculiar burden inherent in the offices of the heads of courts. 20% of annual basic salary was proposed, as dual responsibility allowance for all heads of court.
(c) Disruptive Burden Allowance. This was proposed specially for Justices of the Court of Appeal, Judges of the Federal High Court and the National Industrial Court, in view of the frequency of their transfers partly to mitigate the financial burden of maintaining two homes – the permanent residence, and the frequently changing work residence. 50% Annual Basic Salary disruptive burden allowance was proposed, for these category of judicial officers. There is the need to recognise this work feature, and provide for appropriate compensation.
(d)Long Service Allowance. This was proposed in recognition of the unfairness of newly appointed judicial officers, earning the same salary and allowances as serving judicial officers. 10% of annual basic salary was proposed to be paid monthly as Long Service Allowance, payable to judicial officers who have served on the Bench for a minimum of 5 years.
(e)Legal Researchers Allowance. This was proposed in appreciation of the increasing workload of judicial officers, specifically with a view to achieving the delivery of well researched decisions. 70% of annual basic salary, to be paid monthly was proposed as legal research allowance for Justices of the Supreme Court, Justices of the Court of Appeal and other head of courts.
Independent Salary Scale for Judicial Officers
The NBA also recommended the separation of Judicial Remuneration from Public Sector Pay. De-linking judicial remuneration from that of the civil service will not only strengthen the perception of judicial independence, but will also provide the necessary safeguard and reassurance to Judges. In addition, in recognition of the independence and uniqueness of the Judiciary, the NBA recommended that Judges should be remunerated according to an independent salary scale to be known as the Judicial Service Pay Scale (JSPS). This will further enable judicial salaries to be subject to regular reviews, that are distinct from those carried out in respect of the civil service. Furthermore, the NBA proposed a separate legislative scheme for salaries, allowances, conditions of service and retirement benefits for judicial officers. Including a ‘Judicial Office Holders Entitlements Bill’ to create a Judicial Office Holders Entitlements Panel to replace the Revenue Mobilisation Allocation and Fiscal Commission as it relates to the determination of salaries and allowances of Judicial officers.
RMAFC’s Recommendations for Review of Judicial Salaries and Allowances
RMAFC, in its report, stated that the remuneration packages of judicial officers were reviewed last in 2007, despite socio- economic indices in Nigeria. It further stated that its review was intended to ensure that the remuneration packages for judicial officers reflect current economic conditions, and are in alignment with global remuneration practices.
RMAFC was guided by the following principles, in determining the appropriate remuneration for judicial officers:
1/ Equity and Fairness. All judicial officers should receive justifiable and equitable remuneration, in accordance with there respective responsibilities. The Commission applied equal treatment and uniformity of salaries, allowances and benefits for positions adjudged to entail equal input. Also, the remuneration package should not be such that rewards a newly appointed office holder, higher than an older colleague in similar position.
2/ Risk and Responsibility. The remuneration of judicial office holders, should be commensurate with the risk and respective responsibilities attached to each office. It must fit the purpose, responsibilities and powers attached to that position.
3/ National Order of Precedence. The remuneration of public office holders must be properly aligned, to the relative status of the job. It should reflect the hierarchical order, as stipulated in the National Order of Precedence Act. For example, an appointee of the President is not expected to earn more than the President. The remuneration of the President should be the overall anchor, for the remuneration package of all public office holders in Nigeria.
4/ Motivation. The Remuneration of Judicial office holders should be designed in a manner that it is capable of attracting and retaining the right calibre of manpower, as well as encourage them to lead and live a honest life.
5/ Tenure of Office. The remuneration of public office holders, should take into consideration tenure of office and length of service. For instance, unlike the members of the Executive and the Legislature, judicial officers enjoy longevity of tenure as they are appointed until retirement.
6/ Reasonableness and Ability to Pay. In relation to political, public and judicial office holders at the Federal, State and Local Government levels, different levels of remuneration must be reasonable and affordable, in the context of available State resources and within the means of the government treasury.
In furtherance of these principles, RMAFC made the following proposals:
Annual Basic Salary
RMAFC recommends a 114% increase of current annual basic salary, for all judicial officers.
Allowances and Fringe benefits
RMAFC recommends that the existing allowances be maintained at current levels, since that will translate to higher provisions in actual amounts when applied on the reviewed annual basic salary. Accordingly, the following allowances subsist:
(a)Accommodation. This Allowance should be retained at the maximum of 200% of ABS, minimum of 45% of ABS and maintained according to the following groups (A, B, C, D, E, F, G) as shown in Table 1.
Table 1: RMAFC Schedule of Accommodation Rates for Different Cities/Towns
S/N Group City/Town Percentage of Basic Salary (%)
A Abuja/AMAC 200
B FCT Area Council 100
C Lagos and Port
Harcourt 150
D Benin City, Calabar,
Enugu, Ibadan, Kano,
Jos, Kaduna,
Maiduguri, Makurdi,
Owerri, Sokoto,
Umuahia and Yola 75
E Abakaliki, Abeokuta,
Ado Ekiti, Akure,
Asaba, Awka, Bauchi,
Birnin-Kebbi, Damaturu,
Dutse, Gombe, Gusau,
Ilorin, Jalingo, Katsina, Lafia,
Lokoja, Minna, Osogbo, Uyo,
and Yenagoa 70
F Local Governments in State
Capitals 65
G Other Local Government
Headquarters outside State Capitals 45
This recommendation has taken into consideration the peculiar cases of different areas like Abuja, State Capitals, as well as Local Government Headquarters outside State Capitals.
(b) Motor Vehicle Loan. RMAFC recommends that the motor vehicle loan be retained at 400% of the annual basic salary for judicial office holders, except for the judicial officers to be provided with official vehicles listed in Table 2. Accordingly, all officers provided with official vehicles such as the Chief Justice of Nigeria, Chief Judge of a State, Government may consider selling the vehicles to the users at prices not less than the book value of the vehicles, when they retire from service. This will be done in consideration of the estimated useful life of the vehicles, such that their subsequent maintenance cost shall not constitute a burden to the Government.
(c) Provision of Official Vehicle. RMAFC recommends that official vehicles should be provided to the following Judicial Office holders as shown in Table 2:
Table 2 Schedule of Motor Vehicles for Judicial Officers
S/N Category Number of Cars to be Assigned
Chief Justice of Nigeria As the Judiciary could afford
President of the Court
of Appeal As may be deemed by the Judiciary
Chief Judge of the Federal
High Court As may be deemed by the Judiciary
Chief Judge of the State
FCT 2 (Official and back up)
Grand Kadi of the
Shari’ah Court of Appeal
of the State/FCT 1 Official
President of the Customary
Court of Appeal of the
State/FCT 1 Official
(d) Motor Vehicle Maintenance. RMAFC recommends that this allowance be retained at 75% of the reviewed annual basic salary.
(e) Medical Allowance. Medical Allowance for all Public, Political and Judicial Office Holders should continue to be provided in kind by Government.
(f) News Papers/Periodicals. This allowance should be retained at 15% of the annual basic salary, which can at least cater for the provision of about three dailies and one weekly periodical.
(g) Special Assistant. One (1) Special Assistant can be appointed from within or outside the civil service, and is expected to exit with the office holder that made the appointment. If within the service, he/she should be chosen among officers on GL 16. In this case, civil servants who are offered and accept appointment as Special Assistants are required to apply to Head of the Civil Service of the State for leave of absence, if they intend to return to the Service at the end of the assignment.
(h) Personal Assistant. RMAFC recommends that 25% of annual basic salary be retained, as allowance for Personal Assistant.
(i) Furniture Allowance. Furniture Allowance is paid once every four (4) years, and recommended to be retained at the current level of 300% of the annual basic salary for all Judicial Office Holders.
(j) Domestic Staff Allowance. Domestic Staff Allowance is to be retained at 75% of annual basic salary, payable on a monthly basis to affected officers to cater for four domestic staff (namely Cook, Gardener, Housekeeper and Steward). However, for officers occupying government quarters, domestic staff should be provided by the Government.
(k) Entertainment Allowance. The 45% entertainment allowance payable on monthly basis to judicial officers, should be retained. However, for the officers in government quarters, government is to be responsible for their official entertainment expenses.
(l) Utilities Allowance. Utilities Allowance is applicable to Electricity, Water, Gas, Telephone and Refuse Collection charges. The allowance is made payable on a monthly basis to all categories of officers, except those in government quarters. The 30% of the annual salary, should be retained.
(m) Leave/Recess Allowance. The 10% of the annual basic salary payable once in a year should be provided as allowance to all categories of executive officers, at the point of commencement of the annual leave or recess.
(n) Security. This is to be provided to all categories of officers in kind. The relevant government agencies (Police, Department of Security Service, Nigerian Civil Defence and Service Corp), are expected to provide security services to the officers concerned.
(o) Hardship Allowance.This allowance is retained at 50% of annual basic salary, for all category of Judicial Officers in the country.
(p) Severance Allowance. This allowance is to take care of compulsory redundancy that may be brought about, as a result of the expiration of the tenure of office of the office holder. The allowance is enjoyable by all Political, Public and Judicial Office Holders at the Executive, Legislature and the Judiciary after the successful completion of each tenure, provided that the affected officers disengaged honourably. In other words, cessation of service must not be due to impeachment, dismissal or termination of appointment due to proven case of impropriety and/or related offences. The 300% of the annual basic salary should be retained for all categories of Office Holders except the President, the Vice President, Senate President, Deputy Senate President, Speaker House of Representatives, Deputy Speaker House of Representatives, Chief Justice of Nigeria, Governors, Deputy Governors, Speaker State House of Assembly, Deputy Speaker State House of Assembly and Chief Judges of the States/FCT, who shall be paid 600% of their annual basic salary. Any officer who has served a minimum of two years of the period of tenure would be deemed due for the payment of severance gratuity, on a pro-rata basis. For the purposes of the provision of this allowance, non-career Ambassadors are hereby included.
(q) Duty Tour Allowance/Estacode Allowance. The provision of this allowance is paid to officers on a field work/assignment, and clearly stated according to the category of each Judicial Office Holder. The Commission recommends a retention of the rates as revised in June, 2022 and provided in Table 3
Table 3 Schedule of Duty Tour Allowance/Estacode
S/N CATEGORY DTA RATE ESTACODE (N) RATE ($)
Chief Justice
of Nigeria 142,500 2,000
Justice of the
Supreme Court 100,000 1,300
President of
Court of Appeal 100,000 1,300
Judges of the
Court of Appeal 85,500 1,100
Judges of Federal
High Court/Others 57,000 600
New Allowances
(r)Professional Development Assistant. Provision of Professional Development Assistance for the Judicial Officers to enable them engage two Law Clerks for each Hon. Judge, on GL 9 and GL 10, both of whom should be provided with the relevant computer/electronic materials for their official service and remunerated by the NJC.
(s) Long Service Allowance. This allowance is proposed, in recognition of seniority between serving and newly appointed Judicial Officers in the Judiciary. In this regard, 10% of annual basic salary annually as long service allowance, is to be paid to the judicial officers who have served on the Bench for a minimum of 5 years.
(t) Restricted or Forced Lifestyle. 20% of annual basic salary, is to be paid monthly to all Judicial Officers.
Comparative Review of Current Annual Basic Salaries of Judicial Office Holders and Recommendations by RMAFC and NBA
Categories of Judicial Officers | Current Annual Basic Salary | NBARecommendation | RMAFCRecommendation |
Federal | |||
Chief Justice of Nigeria | 3,363,972.50 | 10,091,917.50 | 7,198,901.15 |
Justice, Supreme Court | 2,477,110.00 | 7,431,330.00 | 5,301,15.40 |
President, Court of Appeal | 2,477,110.00 | 7,431,330.00 | 5,301,154.40 |
Justice, Court of Appeal | 1,995,430.18 | 5,986,290.54 | 4,270,220.20 |
Chief Judge, Federal High Court | 1,995,430.18 | 5,986,290.54 | 4,270,220.20 |
President, National Industrial Court | 1,995,430.18 | 5,986,290.54 | 4,270,220.20 |
Judge, Federal High Court | 1,804,740.00 | 5,414,220.00 | 3,862,143.60 |
Chief Judge, FCT | 1,995,430.18 | 5,986,290.54 | 4,270,220.20 |
Judge, National Industrial Court | 1,804,740.00 | 5,414,220.00 | 3,862,143.60 |
Judge, FCT High Court | 1,804,740.00 | 5,414,220.00 | 3,862,143.60 |
Grand Kadi, FCT Sharia Court of Appeal | 1,995,430.18 | 5,986,290.54 | 4,270,220.20 |
President, FCT Customary Court of Appeal | 1,995,430.18 | 5,986,290.54 | 4,270,220.20 |
Kadi, Sharia Court of Appeal FCT | 1,804,740.00 | 5,414,220.00 | 4,270,220.20 |
Judge, FCT Customary Court of Appeal | 1,804,740.00 | 5,414,220.00 | 3,862,143.60 |
STATE | |||
Chief Judge of State | 1,995,430.18 | 5,986,290.54 | 4,270,220.20 |
Judge, State High Court | 1,804,740.00 | 5,414,220.00 | 3,862,143.60 |
Grand Kadi, State Sharia Court of Appeal | 1,995,430.18 | 5,986,290.54 | 4,270,220.20 |
President, State Customary Court of Appeal | 1,995,430.18 | 5,986,290.54 | 4,270,220.20 |
Kadi, State Sharia Court of Appeal | 1,804,740.00 | 5,414,220.00 | 3,862,143.60 |
Judge, State Customary Court of Appeal | 1,804,740.00 | 5,414,220.00 | 3,862,143.60 |
Comparative Salaries of Chief Justices in African Countries
Country | Currency | Current Annual Salary | USD Equivalent @ 25/6/23 |
Chief Justice of Nigeria | Naira | 6,727.944.99 | 8,852.56 |
Chief Justice of Ghana | Ghanian Cedi | 431,018.00 | 35,193.36 |
Chief Justice of Kenya | Kenyan Shillings | 15,600,000.00 | 111,190.30 |
Chief Justice of Ethiopia | Ethiopian Birr | 2,980,986.00 | 54,666.90 |
Chief Justice of South Africa | South African Rand | 2,896,187.00 | 155,291.53 |
Source: RMAFC and Online Research
Next Steps
The recommendations of NBA and RMAFC, provide an important framework for a better appreciation of the complex nature of judicial remuneration. It is gratifying that extensive consultations were made before the finalisation of both reports. There is therefore, no need for the Tinubu administration to embark on another consultative process, except that which is aimed at harmonising both reports into an actionable, costed and time-bound proposal for the consideration of and implementation by relevant Federal and State institutions, including the National Assembly and State Houses of Assembly. We particularly support the NBA recommendations for a separate legislative scheme for salaries, allowances, conditions of service and retirement benefits of judicial officers. It is inappropriate to lump judicial officers and political office holders together, under one remuneration regulatory regime. Furthermore, it is important that deliberate efforts are made to shield the Judiciary from the political debates on judicial remuneration. We should avoid the absurdity of placing the Judiciary in a situation, where it is asked to show cause for a review of its remuneration. In all, we have had too many political speeches on this matter. It is now time to implement.
Overview of Recommendations by NBA & RMAFC
Overview of Recommendations by NBA & RMAFC
Headings | RecommendationsNBA | RecommendationsRMAFC | Comments |
BASIC SALARY | An increase of 200% of current annual Basic Salary (ABS) across board for all judicial officers | An increase of 114% of current annual Basic Salary across board for all judicial officers | |
ALLOWANCES & FRINGE BENEFITS | Existing allowances outdated need for upward review as well as introduction of new allowances necessary for a judicial office | Existing Allowances be maintained at current levels given the increase in ABS. | Both agree that allowances are an integral part of judicial remuneration |
Accommodation | 100% of proposed ABS across board | Retained at maximum 200% ABS and 45% ABS Minimum subject to place of assignment | |
Medical Allowance | 40% of proposed ABS to cater for non-serious ailments. Medical support for serious ailments should be provided by Government | Should be provided by Government | |
Hardship Allowance | 100% of proposed ABS for all judicial officers | Retained at 50% reviewed ABS | |
Leave Allowance | 100% of proposed ABS for all judicial officers payable once a year | Retained at 10% of reviewed ABS payable once a year | |
Motor Vehicle | All judicial officers must be provided official vehicles which becomes theirs when they retire from service | Motor Vehicle maintenance be retained at 75% of reviewed ABS.Motor vehicle loan be retained at 400% of ABS for judicial officers except all heads of court entitled to official vehicles as may be provided by the Judiciary | |
Personal Staff Allowance | Same position as RMAFC | Allowances for personal and domestic staff be retained at current levels | RMAFC recommended that one Special Assistant be appointed from within or outside the service |
1/Furniture2/Utilities3/Newspaper/ Periodicals4/ EntertainmentAllowances | Same position with RMAFC providewd in the case of periodicals, law reports & other publications it is recommended that each court enables a separate budget heading in response to needs | Be retained at at current levels of the reviewed ABS | |
Severance Allowance | Same position as RMAFC | Current levels and modalities be retained | |
Duty Tour Allowance | Rates revised in 2022 no longer relevant to current realities. Proposed an upward review | Retention of the rates revised in June 2022 | |
Restrictive Life style allowance | 100% of proposed ABS payable monthly for all judicial officers | 20% of ABS payable monthly for all judicial officers | This is a new allowance |
Long Service Allowance | 10% of proposed ABS payable annually for judicial officers who have served on the bench for a minimum of 5 years | Same position as NBA | This is a new allowance |
Professional Development | Recommended 70% of ABS payable monthly under a Legal Researchers Allowance heading | Recommended the provision of Professional Development Assistants for all judicial officers | This is a new allowance |
Disruptive Burden Allowance | Recommended 50% of ABS for Justices of the Court of Appeal, Federal High Court & National Industrial Court in recognition of the frequency of their transfers | No Recommendation | This is a new allowance |
Dual Responsibility Allowance | Recommended 20% of ABS in recognition of the dual roles of heads of court | No Recommendation | This is a new allowance |
OTHER RECOMMENDATIONS | |||
A New Judicial Salary Pay Scale | Recommended an independent salary scale for judicial officers to be known as the Judicial Service Pay Scale (JSPS) | No Recommendation | This will enable judicial salaries to be subject to regular reviews that are distinct from that carried out in respect of political or public service office holders |
Separate Legislative Scheme for Judicial Officers | Recommended the creation of a Judicial Office Holders Entitlements Panel to replace RMAFC as it relates to oversight of judicial remuneration | No Recommendation | This will require Constitutional Amendment |