The Supreme Court of Liberia has ruled President Joseph Boakai acted unconstitutional and violated statutory due-process protections when he removed the scientist in charge of the country’s Public Health Institute in late 2025.
The Court ordered the immediate reinstatement of Dr. Dougbeh Christopher Nyan as Director General of the National Public Health Institute of Liberia (NPHIL).
In a ruling delivered Monday by Associate Justice in Chambers Her Honor Jamestta Howard Wolokolie, the Court held that the Executive Branch and the NPHIL Board failed to follow the investigatory and procedural requirements set out in the NPHIL Act of 2016. The Court emphasized that Section 4.4(c) of the act lists specific grounds for removal—including corruption and gross inefficiency—but requires a formal investigation and due process before dismissal.
“The word ‘investigation’ does not appear anywhere among the vocabularies used in the resolution,” the Court said, noting that government lawyers were unable to produce evidence of a lawful investigation that would justify termination. The decision also cited the constitutional right to due process under Article 20(a) and referenced the Court’s March Term 2024 opinion in Yealue et al. v. Executive Branch of Government, reaffirming that tenured officials cannot be removed without investigation and a proper hearing. “Due process is a law which hears before it condemns,” Justice Wolokolie wrote.
Dr. Nyan, an epidemiologist appointed NPHIL Director General in 2024, led Liberia’s response to the Mpox outbreak and other public health emergencies and earned international recognition for the institute’s interventions. In September 2025, the NPHIL Board adopted a resolution alleging “gross inefficiency” and actions “undesirable to public interest,” and recommended his removal. President Boakai accepted the recommendation and appointed Dr. Sia Wata Camanor, the Board’s co-chair, as interim director.
The Board accused Dr. Nyan of bypassing statutory oversight, failing to involve the Board in critical decisions, making numerous unnotified foreign trips, and sending official communications to the President and Legislature without Board input. The Board also said institutional budgets were submitted without its approval and that partners had raised concerns about his leadership.
Dr. Nyan challenged the dismissal through legal counsel at Gongloe & Associates—led by Cllr. Tiawan Saye Gongloe and Cllr. Kabineh Ja’neh—arguing that his five-year tenure under the NPHIL Act could not be cut short without a lawful investigation and proven cause. The petition alleged Dr. Nyan was given only 48 hours to respond to the Board’s charges and that he was dismissed the same day he submitted a detailed rebuttal.
The Court found several procedural defects: absence of a documented investigation, lack of evidence substantiating the Board’s claims, and reliance on a February 2025 inquiry report that had led to a one-month suspension—an action the Court said could not be repurposed to justify termination, as that would amount to double punishment. The Court also noted there is no record substantiating the Board’s claim that Dr. Nyan had been suspended as asserted.
Affirming an alternative writ of prohibition and granting the peremptory writ, the Supreme Court ordered Dr. Nyan’s reinstatement as NPHIL Director General. Alternatively, the Court directed the government to pay him full compensation as if he had served out his five-year term.
