A Legal Analysis of The Role of Bar Associations Towards Access To Justice For The Poor: A Case Study of Cameroon

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International Journal of Trend in Scientific Research and Development (IJTSRD)

Volume 4 Issue 1, December 2019 Available Online: www.ijtsrd.com e-ISSN: 2456 – 6470

A Legal Analysis of the Role of Bar Associations towards


Access to Justice for the Poor: A Case Study of Cameroon
Akama Samuel Penda1, Ngatchou Toto Carles2
1Senior
Lecturer, 2Assistant Lecturer,
1,2Department of English Law, Faculty of Laws and Political Science, University of Maroua, Cameroon

ABSTRACT How to cite this paper: Akama Samuel


On the basis of unequal access to justice in Cameroon characterized by an Penda | Ngatchou Toto Carles "A Legal
imbalance between the rich and poor, it is the aim of this paper to suggest that Analysis of the Role of Bar Associations
the main principles of the rule of law should be improved for the poor, in towards Access to Justice for the Poor: A
order to ensure equity in every society. Considering that legal representation Case Study of Cameroon" Published in
constitutes the core of access to justice, the present paper attempts to International Journal
critically analyse the contribution of the Cameroon Bar Association towards of Trend in Scientific
access to justice for the poor, focusing on Cameroon, with the objective of Research and
promoting good governance and reducing poverty. The challenges that Development (ijtsrd),
emerged from this study are to enable lawyers to reconcile their professional ISSN: 2456-6470,
interests and those of their clients, to replace the business aspect of the legal Volume-4 | Issue-1,
profession with the traditionally altruistic role of lawyers, and by so doing, December 2019, IJTSRD29794
provide equal justice to the poor. The paper concludes that in Cameroon, as in pp.1109-1118, URL:
other places, the Bar helps more than it hinders access to justice. In order to www.ijtsrd.com/papers/ijtsrd29794.pdf
strengthen the role of the Bar in promoting access to justice, the establishment
of CARPA is recommended here, whose additional advantage, apart from that Copyright © 2019 by author(s) and
of promoting good handling of clients’ money, is promoting good governance International Journal of Trend in Scientific
within the bar, may be to provide through bank interest, funds to finance legal Research and Development Journal. This
aid. is an Open Access article distributed
under the terms of
KEYWORDS: Access, Justice, Poor, Bar, Lawyers the Creative
Commons Attribution
License (CC BY 4.0)
(http://creativecommons.org/licenses/by
/4.0)
1. INRODUCTION
These days the concept of ‘justice for all’ is one of the most a fundamental right of every person’2. On the basis that there
fundamental and widely articulated principles of our is unequal access to justice among people in many societies
modern societies. As political claims for Human Rights, characterised by an imbalance between the poor and rich,
Democracy, Equality, and Justice are made, researchers and and to ensure equality in every society, one of the most
scholars believe it is necessary to investigate these notions1. prominent principles of the rule of law and democracy,
By so doing, much has been said and written on access to access to justice should be improved for the poor3. In
justice. In so much as it returns to this well-trodden ground, concrete terms, development of access to justice for the poor
some justification for this paper is therefore required. Early is likely to help poverty reduction4. Particularly, the present
writers on access to justice for the poor focused on the role paper suggests a contribution to the achievement of the
of institutions such as the judiciary rather than Bar Millennium Development Goals (MDGs) in Cameroon, and
associations, although it is generally agreed that the basis of more generally in other developing countries, in improving
access to justice is legal representation and counsel which access to justice –rule of law not necessarily being a specific
lawyers are committed to ensure. The contribution of Bar goal in itself, but part of the global environment that has to
associations is of significant importance with regard to
access to justice, so we thought it wise to contribute to filling
2Statement by participants from 20 different commonwealth
this gap, while at the same time attempting in general to
contribute to knowledge on access to justice as an important countries in the Caribbean and South Pacific regions and
factor to good governance and poverty reduction. from a wide range of legal and non-legal professionals in
Kingston, at the conclusion of a workshop organised by the
This paper insist on the fact that access to justice is a Commonwealth Secretariat.
3Available at: https://iproject.com.ng/sociology/poverty-
necessity and not a luxury for our society: ‘access to justice is
and-access-to-justice/index.html. Accessed on 12 October
2019
4DFID, Justice and Poverty Reduction. London: DFID issues,
1B. R Njupouen, Access to Justice for the Poor What Role For 2000. And UNDP, Access to Justice – Democratic
Bar Associations? The Case of Cameroon, Master of Science Governance,’ Access to Justice Practice Note’ -December
In Governance And Development Management, University Of 2004, accessed on the internet on 20 06 2018 at
Birmingham, 2005. http://www.undp.org/governance/justice.htm.

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be addressed in view of achieving the 8 MDGs5. It is also the A. The right to appear in court
aim of this paper to show that legal institutions have a The narrowest conception of “access to justice” has its
valuable role to play in that aim. Among those institutions origins in liberal 18th and 19th century states, and refers to an
are Bar Associations or, in other words, lawyers. individual’s formal right to litigate or defend11. It
encompasses the right to “have your day in court”12. While
After considering Bar Associations in developed countries, access to justice was considered a “natural right”,
this paper draws lessons for the Cameroon Bar, such as that governments did not feel a positive obligation to protect this
ethics in the legal profession is a condition to good right through affirmative action programmes13 .
governance at the bar. In practical terms, our goal is to
highlight issues, provoke discussion and thus approach B. Advocacy for those who cannot afford it
possible solutions, rather than evaluate the profession or Starting in the 1960s, definitions of access to justice focussed
reach ‘pat’ solutions6. This is in view of the greater concern on “practising law for poor people”. The goal was to provide
for poverty reduction and good governance, and restoration legal representation to impoverished individuals who could
of the classical notion of lawyer that has more to do with not otherwise afford legal advice. It aimed to counteract the
altruism and dignity7 than business. However, this article cost, delay and complexity of the legal system14. This concept
subsequently suggests that the Bar Association is an of access to justice forms the foundation for today’s legal aid
independent expert body that is likely to efficiently promote and poverty law clinics.
access to justice and can be trusted by the state and
international agencies, as well as being given greater means In more recent times, the legal aid movement has been
to carrying out access to justice related projects. Additionally expanded to include access to legal advice for the middle-
it should be considered that lawyers have professional class. This is the current position of the Canadian Bar
interests and that few are found in certain developing Association’s National Access to justice committee, which
countries8. It is suggested that paralegals help in providing frames access to justice as “the ability of low and middle
basic legal guidance before lawyers are approached in filing class families to get the legal help or information they
cases to Courts9. need”15. While the CBA acknowledges the existence of some
vectors of marginalization such as disability and
2. Understanding the meaning of access to justice aboriginality, they are only considered as additional factors
Access to justice means different things to different people. which can complicate matters if they happen to coincide
In its narrowest sense, it represents only the formal ability to with a low or middle-income situation16.
appear in court. Broadly speaking, it engages the wider
social context of our court system, and the systematic C. Reforming the justice system
barriers faced by different members of the community. A slightly broader definition of access to justice encompasses
Unfortunately, research papers and discussions often do not the need to advocate for people who cannot afford lawyers,
clearly set out what view of “access to justice” they are but also focusses on the inadequacies and limitations of the
taking. This not only makes it challenging to understand the legal aid system. This approach builds on the “legal aid”
goals being sought, but it also makes it difficult to translate model by calling for reforms of the justice system by
these goals into practical plans and programmes10. The simplifying procedural and formal requirements and
following paragraphs describe various approaches to access implementing mechanisms for group and third-party
to justice from narrow to broad. claims17. Generally, reforms in this conception of access to
justice focus on the civil justice process.
5 D. Zelmira and N. Bolivar, ‘The Wider Institutional Context’

in Reaching the Millenium Development goals in Paraguay : D. Equality of outcomes


How is the government of Paraguay facing up the With the advent of the Canadian Charter of rights and
challenge?(Abente et al).Report of Study visit to Paraguay of freedoms in 1985, the idea of equality resulted in a shift
the Memmbers of the masters Programme in Governance towards a broader conception of access to justice18. This
and Development Management.Birmingham: University of approach looks beyond equality of opportunity for
Birmingham, 2005.
st
6 G. P. Richard, Positive Approaches to 21 Century Access to 11 Available at: https://quizlet.com/403949678/rule-of-law-

Justice, 1999. Accessed on the 20 July 2018 at flash-cards/ . Accessed on 12 October 2019.
www.wsba.org/media/publications/barnews/archives. 12 M. Cappelletti and B. Garth, eds, Access to justice Volume
7 A. Richard L, The Legal Profession in England and Wales. 1: A World Survey, Book 1 (Aphenaandenrijn: Sijthoff and
Oxford: Basil Blackwell 1998 and D. Pannick, Noordhoff, 1978) [Cappelletti and Garth] at 6-7.
Advocates,Oxford: Oxford University Press, 1992. 13 Ibid.
8 M. Anderson, Access to Justice and Legal Process: Making 14 Ibid.

Legal Institutions Responsive to Poor People in LDCs, 15 M. Dempster, “Justice for all”, Canadian Bar Association

comment paper on access to justice and legal process, 2003. National: Legal insights and practice trends 22:2, March
Paper for discussion at WDR Meeting, 16-17 August 2013, available online at CBA National Magazine,
1999.Accessed on 25 July 2018 at www.penalreform.org- http://nationalmagazine.ca//, accessed on 20/06/2018
download/commentonthediagramsofproblems. 16Available at: http://www.aclrc.com/what-is-access-to-
9Available at : justice , Accessed on 8 October 2019
https://www.ibanet.org/Document/Default.aspx%3FDocum 17 R. A. Macdonald, “access to justice in Canada today” in Julia

entUid%3D8F020FA1-D13A-4429-BF51-F9C08672D255 . Bass, WA Bogart and F. H. Zemans, eds, Access to justice for a


Accessed on 12 October 2019 new century: the way forward, Toronto: Law Society of
10 Available at: http://www.aclrc.com/what-is-access-to- Upper Canada. 2005, [Macdonald] at 19.
justice. Accessed on 12 October 2019. 18 Ibid.

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underprivileged or underrepresented litigants. Instead, it school has the effect of forcing young lawyers to avoid
aims to achieve equality of outcomes by addressing the opportunities to advocate for marginalized peoples because
barriers faced by those trying to access the judicial system19. of pressures to find high-paying jobs to pay down their
Remedies include reforming and streamlining many areas of education debt29.
the legal system, as well as reforming other social
institutions with the goal of creating a more holistic model of 2.1. Barriers blocking access to justice for the poor
service. We have developed four key barriers blocking access to
justice,
This broader approaches argues that true access to justice
must be considered in light of social variables which have 2.1.1. Funding for Legal Aid Services
historically has a negative impact on the ability of certain This will be examined below when we shall be discussing on
individuals or groups’ ability to access justice20. Such the Cameroonian legal aid system.
variables include Aboriginality, racialization, gender,
disability, class and sexual identity21. There is also an 2.1.2. High Cost for legal action
increased focus on providing resources towards serving the Though the court system is often the only way to resolve
public at the early stages of a problem22. personal conflicts and obtain justice in civil circumstances,
the court fees and costs of representation that come with
This approach encompasses elements from other legal action add up. For too many citizens, that cost is
approaches, including the use of simplified court procedures, prohibitive and justice sits on the backburner. Legal aid is
alternative dispute resolution and other preventative available for the poorest citizens, but is often lacking for
measures in an effort to solve legal problems before they get those who exceed the poverty line yet don’t have the budget
to a litigation stage23. These views have also been echoed to accommodate these costs30.
very recently in four working group reports of the Action
Committee on Access to Justice in Civil and Family matters We feel like the court fees are structured such that working
published in 2012-201324. class people are discouraged from solving disputes via the
legal system. We help people with no money, and people
E. The Future of Access to Justice with a tiny amount of money, but we don’t have help for
Where is the concept of “access to justice” headed next? people who make more but live pay check to pay check.
Critics of current access to justice initiatives have called for
societal change beyond the legal realm, by encouraging the Despite this sad reality, the poorest people are often
justice system to develop partnerships with communities defendants and not plaintiffs, so generally no fees are
and governments to develop more holistic solutions to legal involved. But lower income people should be able to assert
problems25. their rights by bringing cases proactively, as well; they
shouldn’t be limited.
Some commentary points to the need to move away from
court-centric and lawyer-centric approaches which focuses 2.1.3. Lack of automatic right to counsel in Common
on solving the problems of community members in their legal circumstances
daily lives26. This requires access to justice research to shift Anyone familiar with the name “Dick Wolf, Producer” should
its focus away from asking how lawyers can provide more know their Miranda rights by heart, and those include a right
services to the public, towards reaching a better to counsel. But the civil system doesn’t work the same way. A
understanding of what the law means and does not mean in surprising number of common matters, including housing,
the context of problems in everyday peoples live27. custody, and debts proceedings, guarantee no legal counsel
at all31.
Other critics argue that individuals should be allowed to
have a say in what kind of justice they wish to have (e.g.
It’s a problem because the average citizen likely can’t
restorative justice)28 and that the high cost of attending law
advocate for their case as effectively as possible without the
expertise of a legal professional to back them up. There is a
19 Ibid. shocking data for this subject: from a study I carried out here
20 Ab Currie, “The legal Problems of Everyday Life: The in Maroua, Only 1% of cases have a lawyer on both sides.
nature, extent and consequences of justiciable problems Many of these cases are debt collection, eviction – so one
experienced by canadians”, Ottawa: Department of justice theory is that there isn’t any defence anyway.
Canada, 2007.
21 Available at: http://www.aclrc.com/what-is-access-to-
There is additional data in evection cases in which the
justice , Accessed on 08 October 2019. plaintiff is represented versus those where the defendant is
22 Currie, Supra
not: in 62 % of those cases, eviction happens. But if there is a
23 Dempster, Supra).
lawyer on the other side, its 36%. That’s a big difference. Our
24 Alberta Civil Liberties Research Cebtre, What is access to
court system is adversarial, it’s designed to have advocates
justice, available at www.aclrc.com, accessed on 18 June on both sides to ensure a fair fight.
2018.
25 Macdonald, Supra
26 Ibid 29 O. Ha-Redeye, “access to justice starts with legal tuition”,
27 B. G. Garth, Comment: a revival of access to justice Slaw.ca, 5 may 2013.
research ? in Rebecca Sanderfur, ed, Sociology of crime law 30 S. Bock, Barriers blocking access to justice (and how to

and deviance, volume 12, Bradford, GBR: Emerald Group break them), November 2018. Available at
Publishing Ltd, 2009. Pg 258. www.relativity.com, accessed on 10 June 2018.
28 Ab Currie, Ibid. 31 Ibid.

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2.1.4. Lack of Awareness of legal rights, services and aim of CABx is ‘to ensure that individuals do not suffer
procedures through lack of knowledge of their rights and responsibilities
As the old saying goes, “you don’t know what you don’t or of the service available to them or through an inability to
know” and that’s painfully true for citizens trying to engage express their needs effectively and equally, to exercise a
with the legal system alone. Many of us simply don’t know responsible influence on the development of social policies
what rights we have, what services are available to us, or and services, both locally and nationally’37.
how to navigate an often cumbersome court system with
complex procedures and rules32. The action of Civil Society through various Non-
Governmental Organizations (NGOs) towards promoting law
Sadly, even when people do qualify for aid, they may not diffusion and legal literacy and advice, all in the aim of
know it. We do have relief for poor citizens in Cameroon, and improving the outcomes of justice decisions for the poor,
it’s an awareness problem – we need to make sure people should not be forgotten38. Countries have different
know about that. We need to increase funding to make organisations, which are all, however, based on the principle
people aware of the issue as well as address it directly. It’s of free aid and the provisions of the international legal
difficult because the court can’t fundraise, but we can use framework. It is the aim of the next section to assess the role
creative partnerships to work with other funders and make of bar associations through such mechanisms.
progress.
2.3. Ensuring Access to the Law
2.2. Mechanisms of access to justice International standards provide that bar associations have
The mechanisms suggested for strengthening the rule of law an obligation to ensure access to the law for all persons in a
and the protection of human rights internationally are also jurisdiction39. The UN Basic Principles include four articles
relevant for access to justice in Cameroon. Law diffusion, on access to legal services without discrimination (based on
access to counsel and legal aid are such mechanisms a non-exhaustive list of social status) and with specific
developed in this regards33. According to Bolivar Njupouen, provisions for the poor40. Additionally, bar associations are
Law diffusion seems a little general as it suggests a diffuse to work with governments to ensure that all persons have
process. However, international tools place more focus on equal and effective access to legal services and are assisted
access to counsel and legal aid34. These mechanisms are by lawyers without improper interference (Arts 24-25)41.
more accurate for the real ‘need’ of poor people, and focus on Access to legal services not only requires the availability of
real cases. Access to counsel and legal aid appears as a public lawyers and proximity to services, but also necessitates the
good, as they have been made an obligation in various affordability of legal services or the provision of low-cost or
international instruments35. free legal services to groups and individuals who are unable
to afford them. The UN Basic Principles call on governments
Bolivar Njupouen went further to state that, Legal aid is to ensure that there are sufficient resources to ensure legal
organized differently depending on whether it is a civil or a services to the poor42. They also underline, however, the
criminal issue. As far as criminal justice is concerned, the law important role that bar associations play in the organization
requires states to provide lawyers for poor litigants. In this and provision of such services, and in particular in enabling
case the judges organize legal aid that is basically the poor to access them43.
representation in courts. They appoint lawyers depending
on their qualifications and availability. The law states that The International Bar Association (IBA) has also argued that
Bar Associations can provide lawyers for pro-bono where one of the key responsibilities of bar associations is to
the state does not provide lawyers that the state pays to that promote free and equal access of the public to the justice
effect. system, including the provision of legal aid and advice44. To
ensure that no person is denied justice, the IBA also states
Civil matters require the direct legal aid of the bar, that is, that bar associations should make available the services of
lawyers appointed by the bar council to work on a pro-bono lawyers to those unable to pay for such services45. In its Pro
basis. Bars also organize legal advice in both cases, by Bono Declaration, the IBA states that such pro bono services
lawyers in free consultations. In certain countries there are are an integral part of the legal profession and therefore an
lawyers working on their own in their chambers on a
voluntary basis, provided that it complies with the
regulations of the bar association.
37 Citizens Advice Bureaux. Accessed on the 3 august 2018 at

Additionally, there are in some countries paralegals, working ‘http://www.citizensadvice.org.uk/print/index/campaigns/


on a voluntary basis or lowly paid for legal advice36. This is a social_policy/briefings/br_legalaffairs/cr-
step, before getting lawyers involved when need be. In the delivering_access_to_justice.
38 B. R Njupouen, Ibid.
UK, the Citizens Advice Bureaux fulfils this role. The public
39 Lawyers, Conflict transition, Effectiveness of bar

associations in conflict and crisis, December 2016.


32 Ibid. 40 UN Basic Principles on the Roles of Lawyers, (7 September
33 B. R Njupouen, Access to Justice for the Poor What Role 1990), paras 1-4.
For Bar Associations? The Case of Cameroon, Master of 41 Ibid. paras 24,25.

Science In Governance And Development Management, 42 Basic Principles, paras 1-4.

School Of Public Policy International Development 43 Ibid.

Department University Of Birmingham, 2005. 44 International Bar Association, IBA Standards for the
34 B. R Njupouen, Ibid. Independence of the Legal Profession, Adopted 1990. n. 11,
35 Ibid. para 18(e).
36 Ibid. 45 Ibid. para 15.

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integral part of the role and responsibilities of bar ‘(f) Professional associations of lawyers shall co-operate in
associations46. the organization and provision of services, facilities and
other resources, and shall ensure that:
As both the UN Basic Principles and the IBA suggest, the 1) When legal assistance is provided by the judicial body,
provision of pro bono legal services should be consistent and lawyers with the experience and competence
permanent as an integral part of the organization of the legal commensurate with the nature of the case make
profession. However, the provision of pro bono services are themselves available to represent an accused person or
of particular importance during periods of crisis or conflict47. party to a civil case;
As will be discussed further below, where jurisdictions 2) Where legal assistance is not provided by the judicial
experience upheaval, bar associations have a fundamental body in important or serious human rights cases, they
role in ensuring that all persons and communities, and provide legal representation to the accused or party in a
particularly the poor and underprivileged, have the civil case, without any payment by him or her.’
opportunity to access legal services.
The aforementioned are clear on the duties of lawyers.
3. Bar associations and its contribution to access to Having said that, it is important to explore their original
justice interests.
This section makes an assessment on the role lawyers and
Bar associations could play towards access to justice for the 3.2. The role of bar associations
poor. We shall first start by examining if the Bar has a special 3.2.1. To provide aid
interest on the poor making references to international A Bar Association is a professional association of lawyers.
instruments. We shall go further to reconsider the Some Bar associations are responsible for the regulation of
professional interest of bars and the examples we shall be the legal profession in their jurisdiction; others are
given will be used to illustrate how the Bar in developed professional organizations dedicated to serving their
countries deliver legal aid, while at the same time fulfilling members; in many cases, they are both. In many
their professional interest. commonwealth jurisdictions, the bar association comprises
lawyers who are qualified as barristers or advocates in
3.1. Does Bar associations have a special interest for particular, versus solicitors. Membership in bar associations
the poor may be mandatory or optional for practicing attorneys,
The Basic Principles of the Role of Lawyers, adopted by the depending on jurisdiction48. Bar Associations, as the above
8th United Nations Congress on the Prevention of Crime and suggests, could be seen as aiding access to justice. The
the Treatment of Offenders, Havana, 1990, state: profession helps people regardless of their wealth to have
1) All persons are entitled to call upon the assistance of a access to justice. Talcott49 supports this theory as he writes:
lawyer of their choice to protect and establish their ‘his [the lawyer’s] function in relation to clients is by no
rights and to defend them in all stages of criminal means only to ‘give them what they want but often to resist
proceedings. their pressure and get them to realize some of the hard facts
2) Governments shall ensure that efficient procedures and of their situations, not only with reference to what they can,
responsive mechanisms for effective and equal access to even with clever legal help, expect to get away with but with
lawyers are provided for all persons within their reference to what the law will permit them to do.’ Lawyers
territory and subjects to their jurisdiction, without defend their clients’ interests and consider their problems as
distinction of any kind, such as discrimination based on theirs.
[…], economic or others status.
3) Governments shall ensure the provision of sufficient Furthermore, given the gap between various groups and the
funding and other resources for legal services to the imbalance of justice, mechanisms are put in place and
poor […]. Professional associations of lawyers shall lawyers and bars play an important role: ‘lawyers […]
cooperate in the organization and provision of services display their altruism in providing gratuitous or low-cost
[…]. services; but the magnitude of such charity seem to vary
4) Governments and professional associations of lawyers inversely with how extensively it is publicized – conspicuous
shall promote programs to inform the public about their production being the necessary complement of compactors
rights and duties under the law and the important role consumption ’50. However although they assist the poor
of lawyers in protecting their fundamental freedoms. through pro-bono activities, lawyers also have professional
Special attention should be given to assisting the poor interests to fulfil51.
[…] persons so as to enable them to assert theirs rights
and where necessary call upon the assistance of 3.2.2. Hindrances
lawyers.’ Lawyers generally practice to make a living and gain money.
They interact with their clients, who have their own
Reference can also be made to the Principles and Guidelines
on the Right to a Fair Trial and Legal Assistance in Africa
(AU-ACHPR, 1994 cited in Baderin, 2005), which states:
48 Available at:
https://en.wikipedia.org/wiki/Bar_association , Accessed on
08 October 2019.
49Talcott Parson, 1964, p.384, quoted by Abel Richard L., The
46 IBA, IBA Pro Bono Declaration, 16 Oct 2008, paras 1-2. Legal Profession in England and Wales. Oxford: Basil
Available at Blackwell, 1988. pg. 26.
http://www.ibanet.org/Document/Default.aspx?DocumentU 50 Abel Richard L., The Legal Profession in England and

id=C4B06FD6-A807-44D4-A98A-C73B464589C6 Wales. Oxford: Basil Blackwell, 1988. pg. 30.


47 Ibid 51 B. R Njupouen, Ibid.

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interests, that of being advocated, and who trust them and 3.3. The experience of renowned international Bars
give them the authority to represent and defend their The mechanisms of legal aid are similar in all countries. To
interests. The challenge in such relations is to have a win- avoid being repetitive, the following examples focus on
win draw that satisfies each party52. But what sometimes innovative features.
happens is that the agents overlook their own interests and
Bowles53 writes on this relationship when he says ‘the moral 3.3.1. The English Bar and the British examples
hazard arising from the lawyer-client relationship is a The Bar Council of England
standard principal-agent problem in which there is a conflict The Bar of England is an example of a strong commitment in
of interest between two parties and an asymmetry of delivering access to justice for the poor. The Bar Council
information between them.’ For instance, the client agrees to critically responded to a Government White Paper by stating
pay the lawyer an hourly rate, ‘w’ and delegates to the that: “the aims of the Bar of England are to ensure:
lawyer the choice of how many hours of work ‘h’ to devote to  Justice: that everyone can obtain justice in the Courts
the matter. An honest lawyer will only act in what s/he within a reasonable time and at a reasonable expense;
judges to be the best interests of her client and will choose  Access: that everyone has the best possible access to the
the hours ‘h’ which would be recommended by an impartial services of lawyers of the calibre they need, both
observer. The unscrupulous lawyer, however, can maximize solicitors and independent and specialist barristers;
profits by suggesting to the client that the prospects of the  Choice and competition […];
case are better than they really are, in an effort to persuade  Cab-Rank Rule: that barristers are available to represent
the client that the best solution is to spend ‘h**’ hours on the everyone requiring legal representation whether in
case54. In this situation, the client who lacks sufficient criminal or civil proceedings whoever they may be and
knowledge may have to spend more and wait longer for whatever their cause;
results. As aforementioned, ‘justice delayed is justice denied.’  Quality and Standards […]; Fair and Reasonable Price
This is an example of hindering access to justice. […]; Advocacy […]; Legal Advice: that objective advice of
high quality is available from solicitors and other
Moreover, citizens who can’t pay legal representation are professionals from an independent Bar;
unable to represent themselves because of the restrictions  Quality of Judges […]”59.
placed by the Bar Association. ‘In most legal systems, private
citizens are not even allowed to appear in court to present This commitment is also seen in the organisation of the
their own cases, a monopoly of competence is bestowed on English Bar, there are several specialisation branches such as
the legal profession. Legal rules therefore require litigants to the English Society of Labour Lawyers and many services for
use Lawyers, who in turn are rare and expensive55. An legal aid, such as the Legal Service Commission, the Legal Aid
extreme example is in Chad, where there are roughly 100 practitioner group, the Bar pro-bono group, the Free
judges and seven practising lawyers for six million people56’. Representation Unit, and the legal aid policy service at the
In such circumstances, instead for a lawyer to defend the Law society60.
poor against abuses, they will rather concentrate on making
money57. It has been noted that professions generally tend to Nevertheless, Critics were clear that “the legal profession as
neglect the public good, despite claims to be ‘refining their presently organized has failed to provide high quality legal
technical skills in the service of society58’ due to their self- services to persons in such capacities as consumers, welfare
interest. This would also appear to be true for the legal beneficiaries, or enjoyers of clean air [….] a movement has
profession. now begun to provide diffuse interest with the advocacy
services of quality corporate law firms, and Pr. Handler’s
Much more could be written on how Bars hinder justice. Essay on ‘Public interest Law Firms in the United States’
However, certain Bar Associations where human rights and examines the most important manifestation of this new type
good governance have been proven demonstrates how of lawyer. Private foundation-sponsored public interest law
difficult it is to reconcile both the interests of lawyers and firms, operating since about 1970, began the process of
those of their clients. This is illustrated below with the finding means to redress the imbalance of advocacy61, which
French and English Bars. hinders the enforcement (and further development) of
important new rights on enforcement.

In fact, with the growing demand of free legal consultation


supposedly due to the government, according to the Bar:
52 B. R Njupouen, Ibid. ‘The government has for ten years reduced the availability of
53 R. Bowles, Reform of Legal Aid and the Solicitors’ legal aid and thus greatly increased the numbers of those
Profession in Hume papers on Public Policy, vol.4 No 4: with small means who cannot afford necessary legal advice
access to justice. Edited by Frank Stephen. Edinburgh: and representation’62, the state has increased mechanisms to
University Press, 1996. make legal aid, and thus the Bar, more efficient. Many other
54 Bowles 1996, Ibid.
institutions have been helping with legal advice before
55 B. R Njupouen, Ibid.
lawyers are required in the courts or elsewhere to represent
56Webb, Ibid. Pg. 50
57 M. Anderson, Access to Justice and Legal Process: Making

Legal Institutions Responsive to Poor People in LDCs,


comment paper on access to justice and legal process, paper 59 Bar Council 1989, Pg. 1-2
for discussion at WDR Meeting, 2003. Pg. 16-17.Accessed on 60 B. R Njupouen, Ibid.
25 July 2018 at www.penalreform.org- 61 Cappelletti, M. (Ed), Access to Justice and the Welfares

download/commentonthediagramsofproblems. state, Martinus Sijthof Publishers,Neetherlands, 1981.


58 Abel 1988, Ibid. Pg. 30 62 General Council of the Bar, 1989, Pg.8,

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poor litigants63. These include Ombudsman, Law Centres, England, because clients’ money is not susceptible to theft by
Legal Advice Centres and more significantly, Citizen Advice individual lawyers, all going to the bar. Secondly,
Bureaux. transactions relating to the funds are immediately traceable,
and so they believe that money laundering and other lawyer-
British Citizens Advice Bureaux related financial crime become impossible, or nearly so.
Citizens Advice Bureaux, or CABx, is a network of Lastly, although there are rules for paying interest to clients
independent charities throughout the United Kingdom that in exceptional cases relating to length of time or size of
give free, confidential information and advice to assist deposit, the usual rule is that the interest remains with
people with money, legal consumer and other problems64. CARPA. The interest payments accrued to CARPA in this way
The twin aims of the Citizens Advice service are “to provide are sizeable, and, once CARPAs own expenses have been
the advice people need for the problems they face” and paid, they go towards public interest activities undertaken
secondly “to improve the policies and principles that affect by the bars (such as the Paris Bar’s Solidarity Bus, which
people’s lives”65. This research and campaigns agenda also travels around Paris giving free legal advice to citizens)71.
known as social policy is more preventative in nature and
designed to stop problems arising in the first place66. This will be perfect in Cameroon where corruption is very
high. The French government is so convinced of the
‘The Citizens Advice Service is a key agency involved in respectability of the system that they gave responsibility for
helping people gain access to justice in today’s society and its payment of all legal aid funds to the CARPAs as well in 1991.
role is to ensure that ‘individuals do not suffer from lack of There are two things in play here, which do not need to go
knowledge of their rights and responsibilities, or of services hand in hand. First, the bar controls all client money, taking
available to them, or their inability to express their needs it out of the control of individual lawyers. It is a disciplinary
effectively and equally to exercise a responsible influence on offence for a lawyer not to hand over clients’ money to the
the development of social policies and services, both locally CARPA system. Secondly, the interest payments by and large
and nationally.67’ However, the Bar makes it clear that ‘the go to the bar72. It seems to me that you could have the first
Citizens Advice Bureaux, Law Centres and Legal Advice without having the second. Would it work here? I am
Centres cannot be used as a substitute for a proper system of throwing it into the ring as something to think about, but I
legal aid68. know that it has been considered before, but is not yet
operational to date. Here are some possible reasons why it’s
Despite this, it is noticeable that between 2016 and 2017, it not operational till date.
helped 2.7 million people with 6.3 million problems and over
48 million people visited their digital service69. This amply First, France has a fragmented system of local bars – over
illustrates the impact such institutions have on access to 180 of them, more than there are cheeses. Well over half of
justice and legal aid. This is likely to solve the problem of them have fewer than 100 lawyers. Apart from the Paris Bar
effectiveness and will make the Bar and Lawyers more and maybe a handful of larger cities, the rest are very small,
effective as they contribute at a higher level. and indeed the total size of the French profession is under
half that of ours. That contrasts with the centralised system
3.3.2. The French Bars and CARPAs in England and Wales, where the regulator would have to
In France, there is something called CARPA (Caisses des manage singlehandedly the accounts of over 100,000
Reglements Pecuniares des Avocats). It means that lawyers solicitors73 and over 5000 solicitors in Cameroon.
are not allowed to hold clients’ money, but must pay it into
the bar’s account, under the control of the president of the Second, the work of French lawyers – avocats – is different to
bar. There are over 100 CARPAs in France, and each is under that of solicitors, in that the avocats work is a notarial system
the political and ethical control of the local bar, rather than where notaries undertake real estate, family and other work
of a central body or a financial institution70. CARPA is not which traditionally involves the transfer of large sums of
itself a bank, but works with banks. money. Therefore, I assume that the sums passing through
solicitors’ accounts are much, much larger, and probably
The French are very proud of their system, for a number of more complex, than those passing through the accounts of
reasons. First, it guarantees the safety of client funds. They avocats. On top of that, although Paris is also a financial
don’t need a Compensation Fund like that in the USA and centre, the combination of the nature our country and the
work of solicitors would make handing the law firms’
accounts particularly challenging.
63 Hansen, Ole, Legal aid in Practice-3rd Edition. London:
Legal Aid Action Group, 1993. But I’m still trying to be positive, and offer it as something to
64 J. Insley, Citizens Advice Cuts threaten the most vulnerable
be considered when pockets are smarting from the way that
money, the Guardian, retrieved 21/05/2019 we handle clients’ money. Look across the channel – there
65 Campaigns, available at www.enfieldcab.org.uk, accessed
might be another way.
on 18 July 2018
66 Available at: 4. The Cameroonian bar association
https://livewell.oxfordshire.gov.uk/Services/3393 , It is argued that before showing particular interest on the
Accessed on 15 September 2019 poor, the Bar should be free and apt in defending everyone,
67 B. R Njupouen, Ibid.
68 General Council of the Bar, 1989. Pg. 9
69 Wins charity of the Year, Citizens Advice. Retrieved on 23

February 2018. 71 Ibid.


70 J. Goldsmith, Compensation Fund – Can we learn from 72 J. Goldsmith, Ibid.
France?, the Law Society Gazette, 16th July 2009. 73 Ibid.

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thus contributing to the enforcement of the rule of law74. The conformity with the required conditions and its capacity to
suggestion that the Bar be independent appears to be defend everyone. To some extent, it can be said that the Bar,
relevant in the case of the Cameroon Bar. Moreover, there since its creation in 1972, has succeeded in keeping its
are serious concerns in Cameroon over the significant role independence81 despite temptations and its members
the Bar Association could play in legal aid for the poor. provide defence to all (poor and rich). But beyond that, the
However conflicts of interest and poverty in general challenge is to determine what role the Bar plays specifically
continue to threaten this. Paralegals and CARPA are for the poor.
suggested solutions for an efficient legal aid system in
Cameroon75. 4.2. The Nature of the Cameroonian Legal Aid System
Legal aid can be defined as a system or a mechanism that
Section 4.1 examines the Bar’s role towards access to justice allows the underprivileged to benefit from total or partial
for the poor. The next section makes an assessment of the procedural fees like registration fees, bailiff, notary or expert
Cameroonian legal aid system by examining its nature 4.2 fees. It is also considered as an aid to any natural persons
and making an appraisal 4.3. whose resources are insufficient to defend their interests.
Within this perspective, legal aid enables the beneficiary to
4.1. The bar towards justice for all obtain either court judgment or the enforcement of it with
In his analysis on the state of the rule of law in Cameroon, no prior payment of all or part of the costs which he ought to
Justice A.N.T. MBU (2000)76 suggested: ‘the rule of law is have paid. In this circumstance, legal aid concerns all
freedom under the law. Freedom under the law is equality expenses by the courts, procedures or acts for which it is
before the law: Equality before the law is equality of granted. Article 2 of the 2009 law referred to above states
protection by the law. Protection under the law means due that, legal aid is said to be total when it is not limited to
process of law: due process of law means trial by your own certain acts nor specific stages of the procedure and partial if
peers, anybody whose rights have been violated, has a right the decision granting it indicates that it is limited only to
to remedy given to him by the law’. The due process suggests certain specific acts or specific procedure82.
not only an independent Magistracy, but also an independent
Bar. Muna77 exploring the role of the Cameroonian Bar in the But then, there is a resurging question as to what are the
processes of social justice asked “is the independence of the conditions for obtaining legal aid? The realistic response is
Bar as vital as the independence of the Judiciary?” and cited that; not everyone can claim legal aid, although its scope has
the Canadian Bar Association Committee78 to reply: been expanded with the new law. Therefore, only a specific
category of people can benefit from it. In order to enlighten
“In the first place, access to an independent legal expert the public, the law enumerates in its Article 5 persons
is just as critical for a viable legal system as access to an eligible to apply for legal aid. They are the indigenes, that is
independent judge. […]. Without such a legal expert, to say the extremely poor and needy, persons subject to the
there can’t be any true access to the legal process at all, discharge tax etc. It is also granted to natural persons whose
with equivalent injustice and alienation. In the second resources are inadequate to have their rights enforced by a
place of the two, the legal expert’s independence is the court or to follow up the enforcement of any writ or process
more difficult to ensure. A legal expert must be free to of execution obtained without legal aid or an unemployed
oppose and frustrate both government interests and wife with minor children in proceedings of divorce with her
public sentiment.” husband83.

The Bar can perhaps be seen as a watchdog which plays a Legal aid may exceptionally be granted to moral persons
role in ensuring the rule of law and, through this, access to with inadequate resources to enforce their rights in court.
justice for all. The Cameroonian Bar association comprises Article 6 of Chapter 2 extends its beneficiaries to workers
1500 lawyers, almost one lawyer for 10000 citizens, who are victims of an accident at work, claiming for
autonomously managed by the Bar Council whose members compensation against their employers and an unemployed
are elected by their peers79. As lawyers work on their own wife who has no resources and has been deserted by her
and the Bar is managed as described above, the profession is husband so that she can obtain from the court an order of
independent. Section 1 of the law regulating practice at the maintenance for herself or for the children under her
Bar stipulates that the legal profession is independent, and custody. Other beneficiaries from legal aid are persons under
honorariums are discussed between clients and lawyers80. death sentence making an appeal, whose defence was not
The problem with the Bar’s role in access to Justice is its handled by an advocate before the lower court.

4.3. An Appraisal of the Cameroonian Legal Aid System


74 B. R Njupouen, Ibid. In this section, an appraisal of the Cameroonian legal aid
75 Ngatchou Toto Carles. An Assessment of Cameroon’s Legal
system is made with emphasis on its practice and what has
Aid System as an Instrument to Promote Access to Justice for been done so far to better access its effectiveness on the
the Poor. Journal of Constitutional Law and Jurisprudence. poor.
2019; 2(2): 54–65p.
76 Mbu, ATN. 2000. The Common law in Cameroon: Lecture

on ‘The rule of law’.


77 Ibid. Pg 97 81 Muna, 1993
78 Canadian Bar Association Committee. 2000.The 82 Ngatchou Toto Carles. An Assessment of Cameroon’s Legal

independence of the Judiciary in Canada. Ottawa Ontario: Aid System as an Instrument to Promote Access to Justice for
The Canadian Bar Foundation. the Poor. Journal of Constitutional Law and Jurisprudence.
79 B. R Njupouen, Ibid. 2019; 2(2): 54–65p.
80 Recueil de lois.1990.Droits et Libertés. Yaounde:SOPECAM 83 Ibid

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4.3.1. Legal Aid Centres improve the respect of Human Rights in Cameroon by
With the objective to attain “access to justice for all”, the Bar ameliorating the judicial and prison system in general and
created legal aid centres at various courts for those who more particularly to reduce the dysfunctions and abuses
cannot afford lawyers84. The Bar realized that the poor lost linked to detention, precisely pre-trial detention.
cases in court either because they were not aware that they
were entitled to free legal aid, did not understand the Lawyers assist prisoners in enrolling their cases for
complex legal procedures or were legal illiterates or simply judgment90, with some simply need medical treatment, legal
illiterates. Although ignorance of the law is not an excuse, the advice or release for medical or other reasons. Generally
Bar thought it wise that the underprivileged should not these prisoners lack information, not only because of their
suffer from ignorance of their rights. The Bar provide literacy level but also because of their situations as detainees
assistance to indigenes who could provide a certificate of and the way they are treated in prisons.
indigence, minors, women and victims of massive
exploitation of land. Moreover, legal aid provides legal The Bar signed an agreement with the project to provide
information for every litigant, guides them through their lawyers who are experts. These lawyers provide legal
legal procedures and assist them in every step of their assistance to these prisoners. Lawyers assigned by the bar
judicial procedure85. council don’t receive money from their clients. They receive
a sum of 25000 XAF (Central African CFA Franc) equivalent
4.3.2. International donors to $45 per session91, which is very low compared to the
International donors also fund legal aid in Cameroon. For amount they normally agree with their clients92. One may be
instance, at the initiative of the Canadian Cooperative, the tempted to say that lawyers through this project contribute
first of three centres was created at the court of Appeal in significantly in helping the poor gain access to justice, which
Yaoundé. Following this, the British Council also opened a is not the case as shall be illustrated subsequently.
legal aid centre in Bamenda which covers the North West
Region and that which was created in Kumba was The above efforts notwithstanding, access to justice through
transferred to Buea and covers the whole of the South West legal aid and assistance is still a major problem in Cameroon.
Region86. Funds are not used to pay lawyers. Lawyers are 4.3.4. Conflict of Interest
paid pro bono. Generally, it concerns all lawyers, but in Cameroonian lawyers have sometimes become an obstacle
practice it is left to unexperienced lawyers and beginners. A to access to justice for their clients instead of serving as
roaster is normally drawn with lawyers working on shift. catalyzers. They have difficulties in fulfilling their client’s
They receive clients and provide legal assistance or advice interest with theirs. When a lawyer for example, who also
depending on the nature of the problem. acts as an agent, defends his client in a case of a serious
These legal aid centres provide aid to many Cameroonians. accident which resulted to death, physical or mental
Although the statistics from the Bar association may seem incapacity or the loss of an organ, and subsequently damages
insignificant87, it nevertheless shows that lawyers are are paid, it is his duty under Cameroonian law to collect the
participating in improving access to justice for the poor. money and give to his clients. Even though lawyers and their
These lawyers provide their services pro bono and the Bar clients generally agree in advance on a fixed sum to be paid
does not remunerate them. to the lawyer, some lawyers are tempted after recovering the
money to keep more than what they should93. Many of these
Another project which provides legal aid in Cameroon is cases have been reported to the Bar council94. The
PACDET, as it helps prisoners gain access to justice. consequences of such actions are that; lawyers illegally
enrich themselves, increase in poverty for the clients and
4.3.3. PACDET Project88 access to justice is generally undermined, particularly for the
This is a program for the amelioration of the conditions of poor. In fact there is a conflict of interest between both
detention for prisoners and the respect of Human Rights. parties. Furthermore, the reputation of the Bar is
This project was launched in 2002 by the European Union as undermined as the society generally have a negative opinion
a result of studies and research which showed that several of lawyers. Mechanisms have been put in place to deal with
citizens were awaiting judgments in very bad conditions of such cases and this assures good governance within the
detention89. The British Council manages it and the profession95. Many of such complaints have been brought
Cameroon Bar Association provides expertise. before the Bar council and these types of actions have an
impact on access to justice in Cameroon.
It effectively began on 30 June 2007 in certain prisons in
Cameroon like that of Bertoua in the Eastern Region of the Another problem is that of lawyers who retain their client’s
country. The general objective of this programme is to documents and do not assist to court sessions even after
receiving payment. They maximize profits and take other
84 B. R. Njupouen, Access to justice for the poor: What role
for Bar Associations? The case of Cameroon, Master’s Thesis, 90 PACDET. 2002. Convention –cadre de soutien entre le
University of Birmingham, 2005. Pacdet et le .barreau du Cameroun.
85 Ibid. 91 Ibid.
86 Ibid. 92 Ordre des avocats de Paris. 2002. Les dossiers du barreau
87 Cameroun Bar Association. 2000. Evaluation des de Paris: Maîtrise et transparence des honoraires,
conditions de détention dans les prisons au Cameroun. Nov.2002,No 1, Paris :Publications de l’Ordre.
Yaoundé. 93 N. M. Ebénézer, De l’Excellence à la Médiocrité, Yaoundé:
88 Programme pour l’amélioration des conditions de Editions Clé, 1970.
détention et respect de droit de l’homme. 94 Ibid.
89 Ibid. 95 Republic of Cameroun 1990.

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jobs. Additionally, in the poverty context, lawyers take other richer clients. This is likely to decrease conflicts of
money from their clients and make fake arrangements with interests.
the lawyers of the adversaries who make good offers. This is
sad because magistrates are sometimes involved in this kind 5. CONCLUSION AND RECOMMENDATION
of poor justice, especially when the interest of the rich and 5.1. Conclusion
most powerful are involved. This situation where the Justice can only be accessed if it is shared equitably among
powerful and rich dominate over the poor is an obstacle to citizens. The reality is that the wealthy and privileged are
access to justice for all. As Windsor Harriet, an ambassador likely to have justice on their side, either because of their
rightly said: influence over those rendering justice, lack of rule of law,
corruption or political influence, or simply because others
‘The promise to assure all citizens equal rights before the cannot afford fees for good lawyers. In practical terms,
law is good, but the reality is absolutely essential and, I lawyers are contributing towards access to justice by
am sorry to say , it is not always apparent. Too often, and assisting their clients, regardless of their status, with advice
we all know this to be true, the letter of the law is not and/or defence. However, some lawyers are hindering
respected in Cameroon. […]. At times certain individuals access to justice because they have not been able to reconcile
with political influence, with financial clout, enjoy an their professional interests with that of their clients. Such
advantage over their opponents in the courts, and justice cases were reported and it was found that poverty, a flexible
does not prevail. […]. Sometimes certain influential rule of law and a high rate of corruption might hamper
individuals have succeeded in pressurising the courts to access to justice for lower classes.
issue judgments that respond less to the law than to
individual will…96.’ Nevertheless, in Cameroon the Bar has taken significant
steps in ensuring access to justice for the poor. An
From another perspective, some pupils are sent by some admittedly insufficient number of lawyers has intervened in
lawyers to deal with the poorer clients. Given that, these advising and representing certain categories of poor people
pupils are not paid by their masters according to the internal through legal aid. The Bar has also established legal aid
regulation of the Bar council, nor given transport money, centres, where lawyers provide legal advice and
they are likely to collect money from their clients and this representation in courts free of charge for certain relevant
can have serious consequences on the poor. cases among indigents, women, minors, and victims of
violation of human rights. Funds provided by the European
The Bar is aware of these problems and tries as best as Union enabled the Bar in assisting prisoners for little or no
possible to deal with them, with the objective of assuring payments. Although the Bar council punishes behaviours
access to justice for the poor. Nevertheless, legal aid in which are contrary to the exigencies of loyalty and probity,
Cameroon is still a nightmare attached with strings. Certain the indelicacy of certain members of the Bar council
recommendations are suggested below for the Cameroonian continue to render justice inaccessible for the poor.
state and the Bar. Moreover, to prevent the mismanagement of clients’ funds
by lawyers, the Bar Council introduced CARPA. Analyses
4.3.5. The Creation of CARPA and paralegals in suggest that the Cameroonian Bar, like other Bars, helps
Cameroon more than it hinders access to justice. To conclude, the
CARPA (not yet in force) was put in place by the Bar in order Cameroonian Bar contributes significantly to improving
to ensure good representation. Cross sections of the access to justice for the poor. However, there is still much to
constitution state that CARPA are non-lucrative entities be done. Certain recommendations are suggested below for
which are under the patronage of the Bar Council; the the Cameroonian Bar and State.
interests generated at the bank shall be used by the bar
council to fund training and to supplement legal aid97. 5.2. Recommendation
The Bar should inculcate the altruistic spirit of lawyers
It is also important to consider the distribution of lawyers through training and disciplinary sanctions. This will create
across the country. There are approximately 1500 lawyers a suitable environment for the rule of law which is an
for 16 Million people: more than 1/10000, which is not quite indispensable condition for access to justice for the poor.
sufficient98. As the Bar has the positive attitude of copying
from renowned foreign bars, it is suggested that paralegal Necessary steps should be taken in order for CARPA to go
bodies, such as citizen’s advice bureaux, be established to operational in Cameroon. This will be beneficial not only to
help with legal information, as in England. They would also the bar association, but also to lawyers, their clients and the
cover the national territory more fully as lawyers are state. It is a secure and efficient way of dealing with clients’
concentrated in main cities and do not often move to provide money and thereby improving access to justice. Banking
legal advice. If local paralegals covered that, it would only be interest gotten from this money will enable the Bar to
left to lawyers to make the trip in order to cover finance legal aid and training.
representation before the courts for a proper legal aid. The
benefit of this would be to limit lawyers to representation, in Moreover, to cope with the scarcity of lawyers, it is
such a way that they would have sufficient time for their suggested that paralegals could contribute in providing legal
advice while lawyers concentrate on representation in court.
96 MBU, ATN, The Common law in Cameroon: Lecture on ‘The In this regard, The State and Civil society should provide
rule of law’, 2000 structures like CABx in the UK, with the aim of reaching the
97 (Ordre des Avocats du Cameroun,2004 and UNCA,1999). MDGs and donors should add subsidies for legal aid and legal
98 B. R. Njupouen, Access to justice for the poor: What role education.
for Bar Associations? The case of Cameroon, Master’s Thesis,
University of Birmingham, 2005.

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