Panel member seniority requirement is jurisdictional
The Supreme Court of Nigeria has set aside an Army court-martial on the ground that one of the members was junior to the accused, both being captains. Section 133(1) of the Armed Forces Act provides that all members of the court must be senior to the accused. The point had not been raised below, but the Supreme Court found it jurisdictional error and hence not waived. Here is a report from Nigeria.