Dr. Paul Chiy is a multi-qualified legal professional with decades of experience as a Barrister, Solicitor-Advocate, Arbitrator, Chartered Legal Executive, and Academic. He holds full rights of audience in England, Wales, France, and Central Africa, and is a Fellow of both the Chartered Institute of Arbitrators and the Chartered Institute of Legal Executives. A former Magistrate, he advises government departments, regulators, and private clients across public, regulatory, and commercial sectors
The Presidential Election of 12 October 2025 in the Republic of Cameroon, as proclaimed by the Constitutional Council through Décision n°54/C/CS/CRER du 27 octobre 2025, requires assessment not merely as a political event but as a matter of constitutional legality and democratic compliance. The function of such an assessment is to determine whether the process, in both its conduct and proclamation, conformed to the letter and spirit of the Constitution, the Electoral Code (Law No. 2012/001 of 19 April 2012), and the international instruments to which Cameroon is a State Party.
The official declaration confirmed the re-election of His Excellency President Paul Biya, who obtained 2,474,179 votes, representing 53.66% of valid ballots. His closest contender, Mr Issa Tchiroma Bakary of the FSNC, secured 1,632,334 votes (35.41%). The remaining ten candidates collectively amassed 504,313 votes (10.94%), from a total of 4,610,826 valid votes, with turnout recorded at 57.76%.
As a preliminary matter, the arithmetic of the results is clear and legally conclusive. Even if all opposition votes, including those of Mr Tchiroma and the other ten candidates, were combined into a single aggregate, President Biya would still retain an overall majority. On a purely mathematical analysis, he would lead by approximately 53.66% to 46.34%. The legal effect of this observation is that the proclamation of the Constitutional Council, under Article 48(3) of the Constitution, stands unimpeached in form.
However, the constitutional analysis of an election is not confined to numerical totals. The test of legality must encompass procedural regularity, equality of suffrage, and the effective enjoyment of political rights. In this regard, the 2025 election reveals material regional and divisional disparities that, while not invalidating the result, expose a degree of asymmetry inconsistent with the principles of equal participation embedded in Article 2(1) of the Constitution and Article 25(b) of the International Covenant on Civil and Political Rights (ICCPR).
- Regional Disparities and Equality of Suffrage
The South Region recorded a turnout of 89.47%, with President Biya receiving in excess of 88% of all votes cast. By contrast, the North-West Region, where insecurity and displacement restricted movement, registered a turnout of 47.43%, while the South-West Region recorded 49.35%. Despite these constraints, both regions returned comfortable majorities for the incumbent, exceeding 55%.
In the Centre and East Regions, turnout exceeded 69% and 78% respectively, with the incumbent receiving roughly 80% of votes cast. Conversely, in the Littoral (56.78%) and West (53.10%) regions — Cameroon’s principal urban and commercially active zones — participation was considerably lower, and the opposition’s showing was correspondingly modest. The North and Far North Regions presented the only partial counterbalance, where Mr Tchiroma achieved regional majorities of 61.7% and 58.9%, respectively, on turnouts above 60%.
At the divisional level, the disparities become even more pronounced. In Dja-et-Lobo Division (South), President Biya was credited with over 95% of the vote, on participation exceeding 92%, results more typical of a plebiscite than a competitive election. In Fako Division (South-West) and Mezam Division (North-West) — both historically pluralist — turnout fell below 50%, yet the incumbent’s share increased relative to previous elections. In Wouri Division (Littoral), encompassing the city of Douala, participation did not reach 48%, and yet the ruling party was reported to have won roughly two-thirds of the votes cast.
Taken together, these data points indicate territorial overrepresentation of loyalist regions and functional disenfranchisement of regions affected by insecurity or opposition sympathies. The cumulative result is an electoral map that is legally unitary but constitutionally uneven. Such disparities, absent a transparent explanation by the Constitutional Council, suggest unequal access to the ballot and administrative imbalance in electoral management.
- Procedural Irregularity in the Inclusion of a Withdrawn Candidate
The presence of 10,252 votes attributed to Mr Akere Muna, despite his formal withdrawal eleven days before polling day, constitutes a procedural anomaly contrary to Article 123(3) of the Electoral Code, which provides that a candidate who withdraws lawfully prior to the poll shall be excluded from the ballot. The counting of such votes, while immaterial to the overall outcome, nevertheless contravenes the principle of administrative legality and calls into question the diligence of the electoral authority.
- Role of the Constitutional Council
Under Article 48(1) of the Constitution, the Constitutional Council is the final authority for proclaiming results. However, Article 139(2) of the Electoral Code requires the inclusion of certified procès-verbaux from regional commissions as annexes to its decision. These annexes were not published in the Council’s ruling. The omission does not nullify the election but undermines the transparency and verifiability that are indispensable to judicial credibility. The Council fulfilled the letter of its mandate, but not its spirit.
- Comparative Context and Historical Continuity
Mr Issa Tchiroma’s 35.41% performance, while substantial, must be read within the broader historical frame. The figure closely approximates Ni John Fru Ndi’s 36% in the 1992 presidential election — the highest opposition result in Cameroon’s multiparty era. Yet, where Fru Ndi’s result symbolised the emergence of political plurality, Tchiroma’s largely reflected the consolidation of power within the established political class. The numerical symmetry conceals a constitutional regression: from genuine multiparty contestation to regulated continuity within the same structural orbit.
- Constitutional Evaluation
The constitutional inquiry thus divides into two propositions:
(a) whether the election was lawful in its execution; and
(b) whether it was democratic in its effect.
On the first proposition, the election meets the standard of formal legality. It was held under the proper statutory framework, results were duly proclaimed by the competent organ, and the President achieved an absolute majority of valid votes.
On the second, however, the deficiencies in equality of access, the disparities in turnout, and the concentration of administrative power in the hands of the incumbent combine to render the process deficient in substantive legitimacy. Under Article 2(1), sovereignty resides in the people, and under Article 17(1) of the African Charter on Democracy, the State is obligated to guarantee impartial electoral administration. A process that delivers different practical rights to voters depending on geography or security environment fails to meet this threshold.
- Findings and Legal Consequence
From the totality of evidence, the following conclusions arise:
- The 2025 presidential election was legally valid under Cameroonian law and binding upon all institutions.
- The procedural irregularity in the inclusion of a withdrawn candidate and the lack of regional transparency constitute breaches of statutory obligation.
- The regional and divisional disparities in participation demonstrate a departure from the principle of equality of suffrage.
- The Constitutional Council, though acting within its formal jurisdiction, did not ensure a process of adequate transparency or reasoning in its proclamation.
- The election, while legally enforceable, does not wholly satisfy Cameroon’s constitutional and international obligation to conduct elections that are both free and genuinely competitive.
- Recommendations
To restore equilibrium between legality and legitimacy, it is recommended that:
- The Electoral Code be amended to mandate the automatic exclusion of any lawfully withdrawn candidate.
- ELECAM be reconstituted to ensure independence of composition and operation, with civil society participation in its appointments.
- The Constitutional Council be required to publish all regional procès-verbaux and provide reasoned judgments for each proclamation.
- An independent post-election audit be undertaken to assess turnout disparities and recommend equitable measures for future polls.
Conclusion
In conclusion, the 2025 Presidential Election was conducted in conformity with the formal requisites of law, but in substance it illustrates the continuing tension between legality and legitimacy in Cameroon’s constitutional democracy. The victory of President Biya is unassailable in arithmetic terms; even a complete aggregation of opposition votes would not have changed the outcome. Yet, the conditions under which participation occurred — marked by unequal turnout, administrative centralisation, and institutional opacity — detract from the ideal of sovereignty exercised in equal measure by all citizens.
The law has thus prevailed in form, but the spirit of democracy, which the law exists to protect, remains to be fulfilled. The restoration of that balance will depend on reforms that ensure that every Cameroonian vote carries the same constitutional weight — irrespective of region, circumstance, or political alignment.
Opinion Rendered by:
Dr Paul Chiy, LLB, LLM, PhD, FCIArb, FCILEx
Barrister-at-Law
Fellow, Chartered Institute of Arbitrators
Fellow, Chartered Institute of Legal Executives
