to the A, Pplica same on Social monte embarassment detention and publication of embarrassed Pages of news prints. The Applicant = | harassed and humiliated. “"e 40) Still not satisfied Janu: j- by the report of the Panel by a letter dated 14 pee has With Ref, CB/33/DOPS/FH6AB./VOL. 23/27 the Applicants, invited to meet with the 2 Respondont personally on the 16” he esp 6" day of January, 2020 at 10:00 a.m At) On the 16” day of January, 2020 the Applicant including Chi Muritala Adedoyin Blegush in ean of Dr. Muiz Banire (SAN), Me Remi Basua of M. A Basua & Co and Mrs. M.A. Omotayo of Bandeie Omotayo & Co arrived for the meeting with first flight from Lagos and got to the office of the 2" Respondent as required before 10:00.a.m and was made to sit down waiting to be ushered in into the ae. Respondent's office. Also waiting at the same waiting room was SP. Joseph Ofor who was also invited based on the report of the earlier panel which seems not to be in favour of the 1" Respondent as expected by the 2™ Respondent 42) At about 12:32 p. m the lawyer to the 1" Respondent, Osara, another lawyer from Femi Okunnu & Co, Gbenga were led into the office of the 2” Respondent by the man who described himself at the previous meeting Coordinated by SP. Joseph Ofor as Prince of Lafia. while the Applicants and their lawyers were not called into the 2” Respondent's office and despite Mrs. Omotayo's protests to the protocol officer to the 2% Respondent the Applicants and their Lawyers were left unattended until 5:00 p.m of the day after they left for the Airport to catch their retum flight to Lagos which was slated for 6:00 p.m 43) At the Airport while waiting for flight the 1* Respondent's Qsara and Gbenga saw Chief Muritala Adedoyin Elegushi being attended to as he has become so weak due to the stress he was subjected to. Chief Muritala Adedoyin Elegushi did not recover from the effect of the stress until he eventually died on the 28" day pf May, 2020. 44) That the 1° and 2" Respondent continued to place a full unit of Mobile Policemen to guide and protect the land who have never allowed the Applicant ingress and egress onto the land. 45) That not satisfied with the outcome of the panel and still fishing for a way to nail the Applicants with Criminal charges the 2 Respondent also approved a petition to be investigated by at the i Police Zonal Headquarters, Zone 2 Onikan, Lagos State on a falseCaused thei, COPIES of the MMeF 10 demand for the real CERTIFIED TRUE ithony Challa Hed the investigating Police Officers led by DSP * Attached her his team under the supervision of Gp ‘Umar with & marked EXHIBIT BO10 is the copy of the ate 35) ’ eee That another letter was written to the Pendent and after much Applicants shi Attached he senda the letter an office of the 2 Protest approval was i Given that the i Given the TRUE COPY OF POLICE REPORT rewith and Marked EXHIBIT BO11 A & B are copies of id the CTC of the Real Police Report. 36) The Respondents Continued to harass, intimidate, and coerce the Applicants to come from Lagos to Abuja on spurious unsubstantiated accusation of thereat to life, trespass to land, malicious damage all in a bid to get the Applicants arrested and coerced to surrender their family property and possession when it was obvious they couldn't find anybody to arrest on the land irrespective of the unit of Mobile Policemen placed on the land to watch over the land. Attached herewith and Marked EXHIBIT BO12 are copies of some of the invitation letters sent to the Applicants by the by the 2" Respondent at the instigation of the 1" Respondent. 37) Realizing that Elegushi Royal Family and in particular the 2" and 3 Applicant and Chief Muritala Adedoyin Elegushi were undaunted and are resolute in their pursuit of the cases in Court and not yield to blackmail, intimidation and coercion; the 1“ Respondent with the aid and political strength of the 2™ Respondent and different department of the Nigeria Police Force resulted to harassing the 1" Applicant in particular, threatening to embarrass the 1* Applicant with handcuff and publishing same in pages of Newspapers and social media. 38), That the 1" Applicant, Late Chief Muritala Adedoyin Elegushi, the 2™ and 3" Applicants were all invited and: to the office of the 2” Respondent at Lois Edet House, Abuja to face a panel of investigation in which one SP. Joseph Offor from the Legal Department of the Nigeria Police Force was made to coordinate all in a bid to find a way to incriminate the Applicants. Attached herewith and marked EXHIBIT BO12 (a) is the copy of the letter of invitation 39) At the investigation panel a man who introduced himself as a Prince of Lafia, the 2" Respondent's home town was virtually coordinating and controlling the investigation panel. The said Prince threatened the 1" Applicant, Chief Muritala Adedoyin Elegushi (now deceased), Dr. Muiz Banire (SAN), Mrs. M. A Omotayo (also a lawyer34) Respondent shati Make re: © harass, intimidate and coerce the Appar many calle ge ptember 2017. the applicants have Feceived sq nex, Alagbar eee? And forbidden them from coming to Folp worse ene con IKoyi with lawyers as they sho. 28) That ld be ready for Notwithstandi ie ‘awa 4 standing the fact that the 1" R eee fespondent is the . ndency of the suits in Court the 2 continued to aid the "eh Respondent Respondent in gross abuse of My rights. With the intervention of a New Com: to head FclIp Alagbon Annex another set of Policemen were detailed to investigate the matter. DSP Anthony Challa was directed to take inet the case from Sp. Arit Isikong investigated by and her team. This case was the team and they gave their report. missioner of Police posteq 30) The 1* Respondent not Satisfied with the Report caused the Maer {9 be doctored on which basis the 2 Respondent detailed Mobile Policemen from Mopol 46 to the land with instruction to arrest the Applicants and any member of Elegushi Royal found on Ebute Ikate, Itedo and anywhere on or near the land Subject matter of litigation in Court, Attached herewith and marked EXHIBIT BOs and BO7a to d are copies of the dociored Police Report and pictires of the Policemen placed to help the 1" Respondent to wrestle the land from the Applicants. 31) That the Applicants wrote petition against the Mobile Policemen Placed on the land to support the 1* Respondent to wrestle Possession from the Applicants. 32) That on further enqui fy the Applicants discovered that Mobile Policemen were placed on the land based on a purported report of the investigation carried out by FCIID Alagbon Close by the team That the office of the 2" Respondent at first refused to make available the CTC but after much pressure father than giving the Applicants the CTC as Tequested the 2" and his men gave a doctored Police report written and addressed to the 1* Respondent. Attached herewith and marked EXHIBIT BOQ is the copy of the purported Police Report dated 24" October 2019 4 That on seeing the doctored-report the Applicants hereinon the 29" day of November 2017 the jent in favour of the Counterclaim ores ‘Ltd and Chief Kehinde Elegushi, Chief Lamigi mu Elegushi and Chief Morufu Elegushi for | behalf of all members of Elegushi Royal Family MOST REV. APOSTLE SABLONHARI 4 OTHERS VS. A. G LAGOS STATE, ELECUSH SSTMENT CO. LTD. & 5 OTHERS at the Elegushi Royal family who though won their Counts ‘Claim jn the suit then appealed part of decision of Hon Seas Abdulahi Oyekan to the Court of Appeal and filed stay of execution of the judgement. Attached herewith and marked EXHIBIT BO4 and O65 are copies of the Notices of Appeal and Stay of Execution filed against the judgement. 11) That | know as a fact that Records of Appeal has been forwarded to the Court of Appeal therefore Appeal has been entered. 12) That on Wednesday the 30" day of August 2017 the a Respondent led twenty thugs in company of the 1* Respondent's Solicitor one Gbenga, the 1* Respondent's Surveyor and Surveyor Assistant, the 1% Respondent's Chief security, the 1" Respondent's property manager, three regular Police from Force CIID Annex Alagbon Cloe Ikoyi led by one DSP and Sgt. Godwin and 16 Mobile Policemen fully armed to forcefully dispossess my family Elegushi Royal Family at Ebute Ikate Elegushi. 13) That they came in six vehicles including a Combi bus painted in State taxi colour, yellow. They ceased the two guards on duty collected their phones and locked them up in the cabin (iron container) placed by Elegushi Royal Family for the security. 14) That fortunately there was a phone being charged in the cabin this was used to place a call to inform me of the activities of the Respondents. | immediately came to the rescue of the guards and in their presence | instructed the family lawyer Mrs. M. A Omotayo of Bandele Omotayo & Co on phone to go to FCIID Annex Alagbon, Ikoyi Lagos State to protest. 15) That but my immediate intervention that | informed Sgt. Godwin and the other mol bile Policemen present that their action is tantamount to contempt of Court, the Royal guards on duty who were focked up in a container on the land by the policemen and the thugs would have suffocated to death. 16) That Mrs. Omotayo informed me that at the Nigerian Police beI HIGH COURT OF LaGos STATE INTHE LAGOs JupiciaL. DIVISION HOLDEN AT LAGOS. SUIT No; APPLICATION BY HRM KABIYES) AYELUWA ae ELEGUSHI, CHIEF ABDULAH) OLUSEGUN r EM ADENIYI ELEGUSH Fe OF FUNDAMENTAL RIGHTS. Rote | Kabiyesi Alayeluwa Oba Saheed Ademola Elegishi 2 Chief Abdulahi Olusegun Elegushi rae Applicants 3. Prince Akeem Adeniyi Elegushi AND 1. Bela Vista Property & Development Co Ltd Fe 2. The Inspector General of Poles 3. DCP. Kolo Yusuf 4. DSP. Ibrahim Agu (Tel: 08037864191) 5 Supol Udofia (Tel.09063239096), 6. Lagos State Attorney General and Commissioner of Justice Respondents AFFIDAVIT IN SUPPORT |, Chief Abdulahi Olusegun Elegushi, Opemolua of Ikate Elegushi Royal family Land, Male, traditionalist, Businessman and a Nigerian Citizen of Opemolua Compound, no 8 Palace Road, Ikate Elegushi, in the Eti-Osa Local Government Council Development area of Lagos State do make’ cath 1) That | ama Principal member of Elegushi Royal Family owners of all land known as Ikate Land which includes Ebute Ikate, Gbara, Igbokusu, Iroko Awe, Orile llasan, Itedo, Olube, Ologolo, Aro, all in the in the Eti-Osa Local Government Area of Lagos State. | hold the gazetted White Cap Chief by virtue of which |am a member of Lagos State Council of Obas and Chief, Eti Osa Local Government Council Area of Lagos State. the 2™ Applicant in this suit by virtue of which | am 2 ee with nee of this case while | have the consent and approval of HRM Alayeluwa Oba Saheed Ademola Elegushi (Kushenla Ill) (The First Apy licant) and other members of Elegushi Royal family including the 3” Applicant to deposed to the facts herein hat the 1* licant is the Paramount Ruler of Ikate Land, a Fi t 2 ne Oba ee State though a Principal member of Elegushi Royal Family the Monarch’s duty on the throne and as a First ClassIt from Teasor ad6 to INS given in item (a) aby Tt eatMent in ee the age 75 years inhuanverd neve fae age Ran) ono 5 : Lagos, APrlicants standing as Write Cap Chat 4) And On grou Section me they is ‘ 8 of Entitled to compensation by virtue of Nigeria, the 1999 Constitution of the Federal Republic of This S rae ete Was taken out by Mrs. M. A. Omotayo of Bandele i tayo A } Legal Practitioners, Plot 8 Omotayo Close, Off Ketu, legieeeee Off Demurin Street, Obanle Aro Bus Stop, Dated the 0... i MY. May of 2020 motayo (Mrs.) Bandele Omotayo & Co. Legal Practitioners 8, Omotayo Close, Off Irawo-Osan Street, Ketu, Lagos State. On Service to the Respondents 1. 1° Respondent 183. Isale Eko Avenue. EAS! Dolphin Estate, Ikoyi, Lagos State Le cass a ° ed? > 22" Respondent eo 3 The Inspector General of Police ee? Louis Edet House. Abuja & gon aioe, om. The Deputy Inspector General of Police, CASLOFFICE IGBOSE: Force CIID Annex, Alagbon Close, Ikoyi, Lagos State 3. 3 Respondent Office of the DIG of Police FIB Special Tactical Squad The Nigeria Police Force Headquarters SARS Premises, Old Abattoir, Ahmadu Bello Way, Guzape, Abujail the Applicants to surrender th Ebute kate Elegushi in the Eti Of Lagos State to the 1" Respondent by the through the officers of the Nigeria Police ithe 3% to the 5° Respondents is illegal, unconstitutional ancons lal and breach of the fundamental right of the Applicant as guaranteed by the Constitution of the Federal Republic of Nigeria. eit family -osa Local MW. Claim for: a. N250, 000, 000:00 (Two Hundred and Fifty Million Naira) being substantiaexemplary damages against the jointly and severally harassment, intimidation, coercion, embarrassments, arrests, for continuing threats to embarrass, blackmail, arrest and detain the Applicants by the 2" to the 5" Respondents at the instance of the 1° Respondent for the purpose of harassing, intimidating blackmailing and coercing the Applicants to give possession of the land which is subject Of litigation between the 1% Respondent and the Applicants. s An order restraining the Respondents jointly and severally their servants, agents and privies from further acts of violation of Applicants’ fundamental rights. That the Applicants seek these relieves on the following grounds. a) The Applicant, ‘apart from reasons given in Item B above, had been made to undergo, at the age of 69 and 73 years respectively inhuman and degrading treatment in violation of section 34 (1) (a) of the 1999 Constitution of the Federal Republic of Nigeria consolidated having fegard to the 1% Applicant standing as a first Class Traditional Rule in Nigeria as @ whole and Lagos State in Particular. the 2" Defendant being an old man a Gazetted traditional Chieftaincy title holder, White Cap Chief and member of Obas and Chief Council in Eti Osa” Local Government Area of L: ages State. And the 3° Applicant being a Royal Prince of kate Elegushi.g \ 65> }4 Jos > Lp)ros deren lacs GH COURT OF LAGOS STATE IE LAGOS JUDICIAL DIVISION "HOLDEN AT LAGOS SUIT NO: . PLICATION BY HRM KABIYES! ALAYELUWA vi ELEGUSHI, CHIEF ABDULAH! OLUSEGUN ! MR. AKEEM ADENIV| ELEGUSHI FOR THE ENFORCEMENT OF FUNDAMENTAL RIGHTS. tn the matter of : HRM. Kablyesi Alayeluwa Oba Saheed Ademola Elegdshi ‘Chief Abdulahi Olusegun Elegushit i Applicants 3. Prince Akeem Adeniyi Elegushi AND Bela Vista Property & Development Co Ltd a The Inspector General of Police hss DCP. Kolo Yusuf DSP. Ibrahim Agu (Tel: 08037864191) | Supol Udofia (Tel.09063239095). Lagos State Attorney General and Commission: Respondents er of Justice ogbena APPLICATION ON NOTICE VIDE ORDER 2 R. 2 OF THE FUNDAMENTAL RIGHT (ENFORCEMENT PROCEDURE) RULE, 2009 TAKE NOTICE that the Honourable Court shall be moved on........-the es Day Of... cecereerernn 2020 at the hour of 9 0 Clock in thes forenoon or so soon thereafter as ‘Counsel may be heard on behalf of the Applicant for the following relieves/orders: 4. AN ORDER enforcing the Applicants fundamental rights in the manner set out in the (i) Statement of facts, (ii) Affidavit in support of the Application and (iii) the Relief sought and in the manner stated herein-under as follows: i ‘A declaration that constant arrest, harassment coercion, embarrassment, persistent threat to arrest, detain, prosecute, embarrass the Applicants by the different departments: of the Police Force under the 2" Respondent and now in particular by the Office of the Deputy Inspector General Police FIB SPECIAL TACTICAL SQUAD, (SARS PREMISES) for no just cause and for a matter which is already subject of litigation at both the Lagos State High Court and Court of Appeal is illegal, unconstitutional and breach of the fundamental right of the Applicants as guaranteed by the Gonstitution of the Federal Republic of Nigeria. m \" . 4-Ja-ation that the harassment, intimidation and attempt to q