ORIGINATING MOTION

IN THE FEDERAL HIGH COURT OF NIGERIA

IN THE ABUJA JUDICIAL DIVISION

HOLDEN AT ABUJA

SUIT NO:……………………

IN THE MATTER OF AN APPLICATION BY CHIEF TOM WADILE FOR AN ORDER ENFORCEMENT

OF FUNDAMENTAL RIGHTS

AND

IN THE MATTER OF FUNDAMENTAL RIGHTS (ENFORCEMENT) PROCEDURE RULES 2009

BETWEEN

CHIEF TOM WADILE ………………………………………………… APPLICANT

AND

• STATE SECURITY SERVICE(SSS) RESPONDENTS
• CONTROLLER-GENERAL OF NIGERIA PRISON SERVICE

MOTION ON NOTICE

BROUGHT PURSUANT TO SECTION 46 CONSTITUTION OF FEDERAL REPUBLIC OF NIGERIA 1999, ORDER 2 RULE 1,2,3,4 AND 5 OF FUNDAMENTAL RIGHT

ENFORCEMENT PROCEDURE RULES 2009 AND THE INHERENT JURISDICTION OF THE COURT

TAKE NOTICE that this honourable court may/will be moved on the _____day of __________ 2015 at the hour of 9 O'clock in the forenoon or so soon thereafter as Counsel can be heard on behalf of the Applicant for the following reliefs:

• AN ORDER FOR DAMAGES OF N5,000,000.00 (FIVE MILLION NAIRA)
• AND FOR SUCH FURTHER ORDER OR ORDERS as this Honourable Court may deem fit to make in the circumstances in terms of the reliefs sought in the statement accompanying the affidavit in support of this application.

AND TAKE NOTICE that on the hearing of this application said Applicant will use the affidavit of CHIEF TOM WADILE and the exhibits therein referred to.