PLAINTIFF/APPLICANT'S WRITTEN ADDRESS TO AMEND WRIT

IN THE HIGH COURT OF ABUJA

IN THE MAITAMA JUDICIAL DIVISION

HOLDEN AT MAITAMA

SUIT NO:……………….

MOTION NO__________

FUNMINIYI LOLA ………….....…… PLAINTIFF/APPLICANT AND

ESOTERIC INVESTMENT LTD ……………………… DEFENDANT/RESPONDENT

PLAINTIFF/APPLICANT'S WRITTEN ADDRESS

Introduction

The present application which is made pursuant to Order 24 of the Rules of this Honourable Court seeks the leave of the Court to amend the originating processes in this suit. The proposed amendment is annexed to this application as exhibit "A". To further support the application is an affidavit of 8 paragraphs deposed to by the Applicant herself.

Issue for Determination

The major issue for determination is whether the Plaintiff/Applicant is entitled to the leave of this Honourable Court to enable him amend his originating processes.

Legal Argument

It is submitted that a party is entitled to amend his processes. The Rules of this Honourable Court allows a party to amend his processes so long such amendment would enable an important point of law to be properly pursued and exhausted.

We refer the Court to paragraphs 3, 4, 5,6,7,8 of the affidavit in support and submit that the applicant has proved that an amendment is deserved to enable him present all the issues before the court.

Conclusion

It is further submitted that Exhibit ‗A" which is the proposed amendment is in compliance with the requirements of Oder 24 of the Rules of this Honourable Court. It is submitted that the Applicant has satisfied this Honourable Court to be entitled to the relief sought. The authorities are numerous but we shall rely on Ojah v. Ogboni (1976) 4 SC 69, UBN plc v.

Sparkling Breweries Ltd (1997) 3 NWLR (Pt. 491) 29.

We urge the Court to grant this application.

Dated this 20th day of May, 2015.

A.W OLANIYI. ESQ

Counsel to plaintiff/applicant

5b Dawaki Extension,

Abuja.

For Service on: Defendant Ngozi Yakubu & Co No. 12, Wuse Zone 5, Abuja.