STATEMENT 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. BETWEEN

CHIEF TOM WADILE APPLICANT

AND

• STATE SECURITY SERVICE
• NIGERIAN PRISON SERVICE RESPONDENTS

STATEMENT IN SUPPORT OF APPLICATION

NAME AND DESCRIPTION OF THE APPLICANT

The name of the Applicant is Chief Tom Wadile, Male, Christian, Nigerian citizen of No. 1 Macho Street, Maitama, Abuja.

RELIEFS SOUGHT BY THE APPLICANT:

• A DECLARATION of this Honorable Court that the arrest and detention of the applicant is unlawful and contrary to Section 35 of the 1999 Constitution of the Federal Republic of Nigeria as amended.
• AN ORDER enforcing the applicant's fundamental rights by ordering his release from unlawful detention currently imposed on him by the Respondents.
• AN ORDER compelling the Respondents to tender an unreserved public apology to the Applicant for the infringement on his fundamental rights.
• AN ORDER MANDATING the Respondents jointly and severally to pay to the Applicant GENERAL DAMAGE of =N=2,000,000.00 (Two Million Naira) only for harassment, intimidation, torture, arrest, and unlawful detention of the Applicant's person.
• AND SUCH FURTHER ORDER as this Hon. Court may deem fit to make in the circumstances.

GROUNDS UPON WHICH THE RELIEFS ARE SOUGHT

• Under Sections 35 of the 1999 Constitution of the Federal Republic of Nigeria as amended, the Applicant's fundamental rights to personal liberty and freedom of movement are guaranteed.
• The Applicant has been severally harassed, intimidated, inhumanly treated, arrested and detained since the __ of _______, 2014, and have not been allowed to seek legal advice.
• That the Respondents have refused with impunity and without any reason every application for medical attention, despite the apparent worsening heart condition of the Applicant.
• The actions of the Respondents violate the rights of the Applicant as stated in paragraph (a) above.
• By the provisions of Section 46 of the 1999 Constitution of the Federal Republic of Nigeria, any Nigerian who alleges that any of his rights as guaranteed in the Constitution is being or likely to be contravened in any state by any person or authority may apply to High Court for redress.

Dated this……… day of …......…………….. 2015.