WRITTEN ADDRESS 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

WRITTEN ADDRESS

Introduction:

My Lord, this is an application for the enforcement of the fundamental right of the Applicant in this matter.

Brief Statement of Facts:

The facts of the case my Lord has to do with….

Issue for Determination:

The sole issue for determination formulated by the Applicant is as follows: WHETHER OR NOT THE APPLICANT'S FUNDAMENTAL RIGHT HAS BEEN BREACHED AND THEREFORE ENTITLED TO THE RELIEF SOUGHT.

Legal Argument

My Lord, the sole issue for determination raised ….

Conclusion

My Lord, we therefore urge this Honorable Court to grant the Applicant's application and grant and award damages against the respondent for the flagrant breach of the Applicant's rights as guaranteed under the 1999 Constitution of the Federal Republic of Nigeria, as amended.

We respectfully submit my Lord.

Dated this ____ day of _______________, 2015.

...…………………………………. F.O. IMAFIDON ESQ.

Okonkwo & Co

Counsel to the Plaintiff Suite 1, Hilltop Main, No.13 Benacol Street, Maitama, Abuja.

FOR SERVICE ON:

• 1st Respondent,

Director, State Security Service, Abuja.

• 2nd Respondent.

Controller of prison, Kuje Prison, Abuja.

CRIMINAL

LITIGATION DRAFTS

(Including Drafts Under the ACJA 2015)