STATEMENT OF CLAIM

IN THE HIGH COURT OF FEDERAL CAPITAL TERRITORY

IN THE ABUJA JUDICIAL DIVISION

HOLDEN AT ABUJA

SUIT NO…………………….

BETWEEN

DR TADEJOKO OKORIE PLAINTIFF

AND

• IGOR THOMAS
• OSHOLEY TRANSPORT COMPANY LIMITED DEFENDANTS

STATEMENT OF CLAIM

• The Plaintiff is a consultant physician at the National Hospital, Abuja.
• The first Defendant is the driver and employee of the second defendant.
• The second Defendant is a company incorporated under the Companies and Allied Matters Act and the employer of the first Defendant whose object of the company is transport using its fleet of buses. The share capital of the company is a total of N25million divided into 25,000,000 ordinary shares of N1 each. The registered address of the company is situated at 1 Meridian Street, Garki, Abuja.
• The Plaintiff avers that on 1st of January 2015, he was travelling from Lokoja to Abuja in his brand new Mercedes Benz car with registration Number ABJ 111 BWR which he bought for N10,000,000.00.
• The Plaintiff avers that on getting to the Airport Junction in the Federal Capital Territory, the Plaintiff who was then driving at a speed of 60kmph noticed a motorcycle attempting to cross the road and applied his brakes to avoid hitting him.
• The Plaintiff avers that immediately, he was hit from behind by a bus belonging to Osholey Transport Limited driven by Igor Thomas.
• The Plaintiff avers that at the time of the accident, Igor was drunk and was driving at a very high speed.
• The Plaintiff avers that his car was badly damaged as a result of the accident.
• The Plaintiff avers that he also sustained serious injuries and had to be rushed to Garki Hospital where he received treatment and was discharged after one week.
• The Plaintiff avers that the Defendant was negligent and the ingredient of negligence is stated follows:

INGREDIENTS OF NEGLIGENCE

• Over Speeding
• Driving while drunk
• Breach of duty to take special care of other road users

11.The Plaintiff therefore plead special and general damages as follows:

SPECIAL DAMAGES

a. Cost of Drugs		N 100,000.00
b. Bed Admission		N 50,000.00

• Cost of Car N 10,000,000.00
• GENERAL DAMAGES N 500,000.00 Total N 10,650,000.00

12.TAKE NOTICE that the Plaintiff shall rely on the following evidence in the course of the trial: a. Hospital bill;