The Instrument and The Gate - Fiscal Stabilization, Procedural Finality and the Two Registers of Revenue Legality in the Supreme Court of Ghana

The two holdings are individually defensible and jointly difficult to defend as a single system. Amadu JSC closed the Maersk Drillship IV judgment with the reminder that the judicial oath requires justice to be administered without fear or favour even where the State with all its robust apparatus is a party, and that the courts must uphold the sanctity of contracts which no vitiating factor has impeached. Fourteen months later the same judicial voice denied a hearing altogether to a taxpayer which had misread an administrative letter written by the very party whose assessment it wished to challenge. Between them, the two judgments describe a legal order in which the State is rigorously bound by what it has promised and rigorously advantaged by what it has drafted.