By Abu Arome, Esq
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There has been considerable public outcry over Paragraph 49 of the Second Schedule to the Federal Road Safety Commission Bill, 2026 (“the Bill”), which prescribes a fine of ₦50,000 for preaching in commercial vehicles. Christian ministers, church leaders and evangelists across the country have voiced strong opposition, describing the provision as an attempt to criminalise a longstanding form of evangelism – bus evangelism.
For christians, the proposed law strikes at the heart of the Great Commission. In Mark 16:15, Jesus Christ commanded His disciples and, by extension, all christians: “Go into all the world and preach the gospel to every creature.”
In keeping with this command, christians proclaim the gospel in churches, crusades, markets, streets, homes, and commercial vehicles. Evangelism has never been confined to any particular location or method.
Following widespread criticism, the Senate, through a statement issued by the Directorate of Media and Public Affairs to the Senate Leader, clarified that the provision is not an innovation. According to the statement, the provision has existed in Section 10(4) of the Federal Road Safety Commission (Establishment) Act of 2007 and Regulation 220 of the National Road Traffic Regulations, 2012. The amendment, it explained, merely retains and renumbers an existing provision rather than creating a fresh offence.
The statement further maintained that the proposed amendment is not intended to restrict religious activities in public spaces, stating thus:
“It is about the safety of commuters and other road users and is not intended to undermine any religious activity in the public space.”
While road safety is a genuine concern, one must ask whether prohibiting preaching in commercial vehicles actually guarantees “road safety”. What is the nexus between communicating a religious message to willing listeners and driving vehicles safely?
Interestingly, the proposed legislation does not prohibit passengers from engaging in ordinary conversations in commercial buses, whether loud or otherwise. If ordinary conversation is permissible, why should religious conversation alone be proscribed? Does preaching cause a unique form of distraction that ordinary conversations do not? If the concern is driver distraction, then the law should address all forms of conduct capable of causing such distraction, rather than singling out religious expression for proscription.
Like many inelegantly drafted statutes, the Bill is not without ambiguity. Section 33, the “interpretation” section, defines a “commercial vehicle” to include a motorcycle. It provides that:
“Commercial vehicle” includes a motorcycle for hire, hackney carriage, stage carriage, prime mover, recovery vehicle, draw-bar trailer or articulated vehicle and any motor vehicle primarily designed for the carriage of goods and fare-paying passengers.”
The implication is that a christian who shares the gospel with an “Okada” rider while heading to his destination would equally be liable under the proposed law.
I vividly recall a pastor recounting how, in the early years of his ministry, he frequently shared the gospel with “Okada” riders while on transit. Under the proposed legislation, such conversations would become unlawful.
This again raises a fundamental question: is the true objective of the legislation road safety, or is it the restriction of evangelism?
Whatever its intended purpose, the Bill raises serious constitutional concerns.
First, it is inconsistent with Section 38 of the Constitution of the Federal Republic of Nigeria, 1999 (as amended), which guarantees freedom of thought, conscience and religion. Section 38 provides:
“Every person shall be entitled to freedom of thought, conscience and religion, including freedom to change his religion or belief, and freedom (either alone or in community with others, and in public or in private) to manifest and propagate his religion or belief in worship, teaching, practice and observance.”
The constitutional protection extends beyond merely holding religious beliefs; it expressly protects the freedom to manifest and propagate those beliefs in both public and private settings. Evangelism is one of the principal ways through which christians propagate their faith.
Secondly, the Bill falls short of a cardinal principle of sound legislation which postulates that laws should be of general application and not targeted at an individual or a group. See Lakanmi v. Attorney-General (Western State) & Ors. (1971) 1 UILR 201.
The provision of Paragraph 49 of the Second Schedule to the Bill, although appears neutral facially, falls almost exclusively on christian evangelists, whose faith places a positive obligation upon them to proclaim the gospel wherever opportunities arise.
In a nation as religiously diverse as Nigeria, where issues of faith are often delicate, legislation touching on religious expression must be approached with caution. A blanket prohibition on preaching in commercial vehicles risks undermining the constitutional right to propagate one’s religion.
Agreed, road safety is of public interest, but it should not become a justification for unnecessarily limiting fundamental rights. If the true concern is preventing distraction of drivers or ensuring order in commercial vehicles, the legislation should be tailored to prohibit conduct that actually endangers road users, irrespective of whether the communication is religious, political or social.
The National Assembly should revisit the proposed provision to ensure that the objective of promoting road safety is pursued in a manner consistent with the Constitution.
Abu Arome is the Managing Partner of The Counsel L-P ,arome@counsellp.com | +234 8032622359
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