AFFIDAVIT IN SUPPORT OF APPLICATION FOR ENFORCEMENT OF FHR

IN THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY

IN THE ABUJA JUDICIAL DIVISION

HOLDEN AT ABUJA

SUIT NO……………..

IN THE MATTER OF AN APPLICATION CHIEF TOM WADILE FOR THE

ENFORCEMENT OF HIS FUNDAMENTAL RIGHTS TO PERSONAL LIBERTY AND

FREEDOM OF MOVEMENT UNDER SECTIONS 35 AND 46 OF THE 1999

CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA (AS AMENDED). AND

IN THE MATTER OF FUNDAMENTAL RIGHTS ENFORCEMENT PROCEDURE

RULES 2009 AS SUBSUMED IN THE 1999 CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA (AS AMENDED).

CHIEF TOM WADILE APPLICANT

AND

• STATE SECURITY SERVICE
• NIGERIAN PRISON SERVICE RESPONDENTS

AFFIDAVIT IN SUPPORT OF APPLICATION

I, Mrs. Amara Eze, Female, Adult, Christian, Business woman and a Nigerian Citizen of No. 1, Wadile Close, Maitama, Abuja, do hereby make oath and state as follows:

• I am the wife of the Applicant in this case, and by virtue of which I am conversant with the facts of this case.
• I have the authority of the Applicant to depose to this affidavit.
• On the _____ day of _________, 2015, I visited the Applicant in Kuje Prison, Abuja, at about 12 noon, where I met the him in an appalling condition and he reported the following facts to me, and I verily believe same to be true:
• While speaking at a political rally at the Millennium Park, Abuja, on the ___ day of ________, 2014, officers of the State Security Service (S.S.S.) arrested the Applicant for allegedly inciting political unrest.
• Since then, the Applicant has been in detention at Kuje Prison.
• The Applicant has been prevented from gaining access to his lawyer.
• The Applicant has a recurrent heart disease and should be allowed to visit his doctor every two (2) weeks.
• Since the Applicant was arrested, he has not been prevented from seeing his Doctor or any other Medical Doctor.
• The Applicant has been prevented from taking his medication as prescribed by his doctor. Attached is a copy of his Hospital Schedule with his Doctor, marked as Exhibit A.
• The last time I was in the prison to see the Applicant, his heart condition has drastically deteriorated and in need of immediate medical attention.
• It would be in the interest of justice if this application is treated with utmost urgency and immediately granted.
• I make this affidavit in good faith and conscientiously believing same to be true, correct and in compliance with the Oath Act.

__________