Under the terms of a 2002 constitutional amendment, all presidential candidates were required to have lived in Togo for at least one year prior to the election. This created a legal barrier to Olympio's candidacy in subsequent elections, since he had been living outside of Togo since 1992. In 2003, Olympio was deemed ineligible to run in the June 2003 presidential election by the electoral commission on the grounds that he did not have a certificate of residency and a recent receipt of tax payments. On 26 April 2003, Olympio returned to Togo, saying that he did not have any taxable income in Togo. Olympio appealed the electoral commission's decision to the Constitutional Court, but it ruled against him on 6 May."TOGO: Constitutional Court upholds Olympio's rejection", IRIN, 7 May 2003. Emmanuel Bob-Akitani, the First Vice-President of the UFC, ran in place of Olympio; Eyadéma won the election.
