CONCERNS:

Excellency Sir, on Friday 4th of March 2022, a group by the name ‘Advocacy for
Advancement of Peace and Harmony in Africa Initiative (ADAPHAI)’ submitted
petitions to the Chairman of the All Progressives Congress’ (APC) Caretaker
Extraordinary Convention Planning Committee (CECPC), the Inspector General of
Police (IGP), and the Director-General of the Department of State Services (DSS). In
the said petition, they accused HE. Prince Adedapo Oluseun Abiodun of concealing
criminal offenses he allegedly committed in the USA in the 1980s. They thereby called
on the Chairman of the APC’s CECPC, His Excellency Gov. Mai Mala Buni, to remove
him as the Chairman of the Appeal Committee of the APC National Convention slated
for March 26, 2022. (Appendix 1)

Furthermore, on Friday 18th of March 2022, a coalition of student groups across Ogun
State namely ‘The Coalition of Ogun Students and Youths (COSSY)’ petitioned the
State Governor, HE. Prince Adedapo Oluseun Abiodun, and gave him a 14-day
ultimatum to clarify the alleged criminal records and possible Constitutional infractions
(Appendix 2). The Group also petitioned the Ogun State House of Assembly (Appendix
3) and its speaker, RT. Hon. Olakunle Oluomo (Appendix 4) to – within constitutional
limits- commence investigations into the alleged criminal past of the Governor.
Notable individuals, religious bodies, professional organizations, traditional
institutions, and critical stakeholders in Ogun State were copiously copied in the said
petitions.

Per the aforementioned, it became imperative for me - as a loyal member of the All-
Progressives Congress (APC) and a concerned indigene of Ogun State- to sift these
allegations (and other ones I shall enumerate hereunder) with a fine-tooth comb and
then bring them to your attention. The overarching aim of my intervention is to avert
the possible danger(s) that HE. Prince Adedapo Oluseun Abiodun’s gubernatorial re-
election bid in 2023 might portend for our party.

It is also important to note that all those allegations and documented pieces of
evidence are in the public space and readily available to opposition political parties in
Ogun State and the entire nation. In fact, words from the grapevine are that a former
prominent member of our party, APC, who just decamped to the opposition PDP to
procure a gubernatorial nomination form, has boasted to everyone that he has more
compelling and damning documentary evidence, such as Incident card and
mugshot of HE. Prince Adedapo Oluseun Abiodun, in his possession. This individual,
also from the same Senatorial District as the subject matter, is confident that the
incumbent will be disqualified by the courts to pave way for him to clinch the
Governorship seat.

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GROUNDS FOR A CALL FOR THE DISQUALIFICATION OF HE. PRINCE
ADEDAPO OLUSEUN ABIODUN FROM PARTICIPATING IN THE UPCOMING
2022 GUBERNATORIAL PRIMARY IN OGUN STATE:

GROUND 1: DISCREPANCIES IN INEC FORMS CF001 OF 2015 AND 2019

Excellency Sir, I note with grave concern that HE. Prince Adedapo Oluseun
Abiodun’s actions and integrity are questionable; this ought to expressly thwart
his participation in public office let alone vying for the position of the Governor
of a State. This is obvious from the fact that while filling the columns for his
educational qualifications in the INEC form CF001 for the office of Governor of
Ogun State in 2019, under ‘Primary School Attended’, HE. Prince Adedapo
Oluseun Abiodun recorded and claimed that he attended International
Primary School Ayetoro in 1971 (Appendix 5) while in his 2015 INEC Form
CF001, while vying to represent Ogun East at the Senate, he recorded and
claimed to have attended another primary school, Comprehensive High
School Ayetoro State Primary School, in the same 1971! (Appendix 6).

All efforts to locate both schools, which would have been in the present Ekiti
State or Ogun State- of the Old Western Region of Nigeria -proved impossible.
I submit that if he indeed had attended any of the above-stated schools, he
would have been consistent while filling the INEC forms. Please find attached
the proof of the non-existence of the said schools (Appendix 7) through a wide
search I conducted by investigating available records between 1960 and 1975.
His claim to have attended non-existent schools in 1971 also amounts to lying
on oath and presenting a false certificate to INEC which are very potent grounds
for disqualification as enshrined in Section 182 (1) (j) of the 1999
Constitution as amended which states that
“No Person shall be qualified for election to the office of
Governor of a State if- He has presented a forged certificate
to the Independent National Electoral Commission;”

It is trite that the minimum educational qualification to become a Governor in

Nigeria as stated in Section 177 (d) of the Constitution of the Federal
Republic of Nigeria, 1999 (As amended) is that such a candidate must be
assuredly educated up to at least School Certificate level or its equivalent. The
provision of Section 177 (d) of the Constitution of the Federal Republic
of Nigeria, 1999 (as amended) is reproduced hereunder for ease of
reference thus:
“A person shall be qualified for election to the office of
Governor of a State if-
(d) he has been educated up to at least School Certificate
level or its equivalent.”

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Given the above, with the 6-5-4 system of Education in Nigeria as at then, and
even now, no one could attend a secondary school without having passed
through the elementary level. More so, no one could attend two different
Primary schools and finish both at the same time as presented by HE. Prince
Adedapo Oluseun Abiodun in his INEC forms.

My fear for our great party in the forthcoming elections is that since the report
of HE. Prince Adedapo Oluseun Abiodun’s questionable primary school claims
are in the public domain already, the opposition parties shall test his eligibility
to stand for elections within the stipulated 14 days’ cause of action (pre-election
matters) as provided for in the Constitution and Electoral Act 2022 (as
amended). If action is not taken, the chances of our great party, APC, retaining
the Governorship seat in Ogun State shall be in jeopardy as previously seen in
Bayelsa and Zamfara States. God forbid!

Also, in Paragraph D (i) under ‘working experience with dates’ in his form CF001
of 2015, he claimed under oath to have been in the employment of Heyden
Petroleum Limited from 2001 till Date, (Appendix 8) and in his 2019 INEC form
CF001, D(i) of the same subheading, he also claimed under oath to be the CEO
of the same Heyden Petroleum from 1993 till present (Appendix 9). These
further validate the inconsistencies in both forms. See Section 182 (1) (j) of the
1999 Constitution as amended.

In Abubakar v. INEC (2020) 12 NWLR (Pt. 1737) 37 at 161,

the Supreme Court, per Eko, JSC, Incisively, proclaimed that:

“disqualification of the candidate on grounds of false

information in his form CF001 is a pre-election matter by
dint of Section 285(14) (c) of the Constitution”

The apex Court re-echoed and consolidated the hallowed principle

of law in AKINLADE V. INEC (UNREPORTED) APPEAL NO: SC,
1438/2019, delivered on 18th December 2019.

Just recently, the Court of Appeal in the case; APC & ANOR V.
OBASEKI & ORS (2021) LPELR-53538(CA) held that:

“by Section 465 of the Criminal Code, forgery consists of

making a false document or writing knowing it to be false
and with the intent that it may be used or acted upon as
genuine.”

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Excellency Sir, I state with all sense of responsibility that HE. Prince Adedapo
Oluseun Abiodun's profile can only best be described as a bundle of consistent
inconsistencies. I humbly refer you to his Form CF001 submitted to INEC in
2015 where he indicated under oath that he attended the University of Ife (now
known as Obafemi Awolowo University) in 1986 (Appendix 10) whereas, in Form
CF001 submitted to INEC in 2019, no mention was made of the University
(Appendix 11). My inquiries at the Obafemi Awolowo University, Ile-Ife,
revealed that HE, Prince Adedapo Oluseun Abiodun never even graduated from
the University of Ife. It beggars belief why he would say he did in his form
CF001 in 2015.

Also, in SALEH VS ABAH & ORS, (SC.144/216) [3PLR/2017/300] {SC},

HIS LORDSHIP SIDI BAGE, JSC, HELD THAT:

“The question in paragraph 6 of part E of the 1st

Respondents INEC form CF001 is very specific: Have you
ever presented a forged certificate to INEC. We align with
the position of the learned senior Counsel to the Appellant,
that this question relates to all elections, for as long as a
candidate had previously presented a forged certificate to
INEC. The same scenario plays itself out vis-a-vis the
provisions of Section 66(1)(i) of the 1999 Constitution (as
amended) which is to the effect that, quote:
"No person shall be qualified for election to the Senate or
the House of Representatives if:-
(i) he has presented a forged certificate to the Independent
National Electoral Commission.
The law is very clear to warrant any form of colourated
interpretation.

This Court must take the lead, in righting the wrongs in our
society, if and when the opportunity presents itself as in
this appeal. Allowing criminality and certificate forgery to
continue to percolate into the streams, waters, and oceans
of our national polity would only mean our waters are and
will remain dangerously contaminated. The purification
efforts must start now, and be sustained as we seek, as a
nation, to now 'change' from our old culture of reckless
impunity.

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 The Nigerian Constitution is supreme. It desires that no one
who had ever presented a forged certificate to INEC should
contest election into Nigeria's National Assembly. This is
clear and sacrosanct. More compelling as a judicial
determination had been taken by no less a technical panel
sitting in, at least, a panel of three judges as Election
Tribunal with the constitutional mandate to determine such
issues as they relate to elections and its outcomes,
including eligibility. This has also been affirmed by the trial
Court in this appeal. On these issues, our duty is to apply
the Constitution and the law in its start, original form
undiluted by colourated interpretations”.

GROUND 2: LYING ON SWORN INEC FORMS CF001 IN 2015 AND 2019,

ABOUT HIS INDICTMENT AND IMPRISONMENT IN 1986.
On July 12, 1986, an African American male, born on the 22nd of June 1959,
who went by the name Shawn Michael Davis, was arrested at the American
Express Travellers Office located at 32, Miracle Mile in Coral Gables, Florida, by
Officer G. Clayton of the CGPD and indicted for Forgery, altering a forged
Travellers Cheque, grand theft and theft of a credit card belonging to Mr. John
A. Moruay.

Similarly, at 8:20 pm on November 6, 1986, Officers R. Ubieta and R. Stewart

of the Miami (Metropolitan) Dade police department (MDPD), Florida, assisted
by US Secret Service Agent, S.A, Tim Cristine, arrested one Adedapo Oluseun
Abiodun (a male Security guard, an African of Nigerian origin with Date of Birth;
May 29, 1960) at 85ST, SW 107AVE (Horizons East) for forgery, altering forged
instrument and resisting arrest with violence. While being processed at the
Miami (Metropolitan) Dade Police Department (MDPD) for detention, the
fingerprint of the suspect, Adedapo Oluseun Abiodun, was squared on the US
criminal database and it was discovered that the suspect is the same person as
Michael Shawn Davis earlier mentioned, who then was still facing trial, and
released on bail, at Coral Gables (Appendix 12). Adedapo Oluseun Abiodun was
thereafter indicted for the offense of credit card fraud in Miami Dade, Florida,
USA, and remanded in jail as a repeat offender with jail number: 860089436.
Please find attached (Appendix 13) the documents showcasing the facts stated.

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In 2015, Prince Adedapo Oluseun Abiodun applied for the redaction of his
criminal records (Appendix 14). This could look innocuous to an untrained eye
but one would bet that it was primarily done to censor and conceal his criminal
records and indictment while the principal aim was to cover his track and not
leave any room for suspicions or give his opponent, Late Senator Buruji
Kashamu, any chance to vitiate the election petition he (Prince Adedapo
Oluseun Abiodun) had then just filed against him (Prince Buruji Kashamu)
challenging the victory of the latter, as the Ogun East Senator-elect, at the
election petition tribunal. Another reason for the redaction could be to forestall
future eligibility issues against any political aspiration he (Prince Adedapo
Oluseun Abiodun) might nurse in the future (such as the 2019 Gubernatorial
elections). I firmly believe that our party (APC) would have disqualified then
Prince Adedapo Oluseun Abiodun during the 2018 governorship screening
process, had it not been blindsided by way of the concealment of his criminal
indictment records thus misleading the screening committee to make the wrong
judgment call of clearing him to participate in the 2019 general elections.

It would interest you to know, your Excellency, that this issue is currently being
investigated by the Police authorities at Louis Edet House, Abuja. You can
however conduct an independent investigation by logging in to the Miami Dade
online criminal record portal and searching as indicated hereunder:
https://www2.miami-
dadeclerk.com/cjis/casesearch.aspx?AspxAutoDetectCookieSupport=1
i)At the first dialogue box, click F(felony)
ii)At the second, scroll to 1986
iii)At the third, input the Felony numbers (Either 032915 for Adedapo
Oluseun Abiodun OR 019816 for Shawn Michael Davis)
iv)Leave the fourth dialogue box as ABC
v)Click the ‘I am not a Robot’ part
vi)Click ‘Search’

HE. Prince Adedapo Oluseun Abiodun ought to be disqualified if he picks the

form for the 2023 gubernatorial primaries election because, as contained in
Section 182 (1) (j) of the Constitution of the Federal Republic of
Nigeria, 1999 (As Amended) quoted supra.

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A careful review of HE. Prince Adadapo Oluseun Abiodun’s INEC Form CF001 in
2015 (Appendix 15) when he contested for the Senate Seat of Ogun East
Senatorial District under the All Progressives Congress (APC), and in his CF001
2019 form (Appendix 16) when he contested for Governor indicates that his
claim under oath that he had never been under any sentence of imprisonment,
fine for any offense of dishonesty or fraud or any offense imposed by a Court,
(Appendix 17), is false.

Further, it is a settled matter that INEC Form CF001 is a specie of an

Oath/affidavit, and a misrepresentation of any fact thereon amounts to ground
for disqualification under the laws of the Federation of Nigeria. See PDP VS
DEGI EREMIENYO (2021) 9 NWLR PT. 1781 AT 274 where JUSTICE
EJEMBI EKO, JSC, held that:

‘” On what amounts to presenting forged certificate to the

electoral body for purpose of election and effect of- By
virtue of section 182(1)(j) of the 1999 Constitution, as
altered, no person shall be qualified for election to the
office of Governor of a State if he has presented a forged
certificate to the Independent National Electoral
Commission.

The ‘certificate’ therein is in small letters. It bears its

ordinary natural meaning. It is used as a noun that derives
from the verb ‘certify’ which means to attest, testify, vouch,
ascertain, verify. The word “forged” qualifies the word
“certificate” in the provision. The word forged is used in the
context of fabricating, framing, falsifying, inventing a false
attestation, vouching falsely”.

GROUND 3: NON-DISCLOSURE OF FORMER NAMES IN SWORN FORMS

CFOO1 OF 2015 AND 2019.

Excellency Sir, please find herewith attached HE. Prince Adedapo Oluseun
Abiodun’s sworn INEC forms 2015 (Appendix 18) and 2019 (Appendix 19)
wherein he dubiously omitted Section B(3) “Former Names” in both forms
whereas Appendix 20, also herewith attached, expressly shows that competent
authority, of the Circuit and County Court of the Eleventh Judicial Circuit of
Florida in and For Miami Dade County, captured and affirmed that he was - as
far back as 1986 - also known as Shawn Michael Davis.

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In the Bayelsa case which the Gubernatorial Candidate of Our Party, David Lyon,
lost to the PDP candidate, HE. Gov. Duoye Diri, on 13th February 2020, which is
aptly quoted in our law jurisprudence as PDP VS DEGI EREMIENYO (2021)
9 NWLR PT. 1781 AT 274 where JUSTICE EJEMBI EKO, JSC, held that:

“It is clearly fraudulent for one person to allegedly bear

several names that he uses variously chameleonically to
suit the changing environment”.

From the pronouncement of Justice Ejembi Eko, JSC, in the above-cited case,
my submission is that HE. Prince Adedapo Oluseun Abiodun is not permitted by
the laws guiding the INEC form CF001 to decide which of his past names to
keep and which one to disclose. He is compelled by law to make a full disclosure
and not to Chameleonically, as Justice Eko repeatedly said, use names as the
environment changes. If it was convenient for Oladapo Oluseun Abiodun to bear
Shawn Michael Davis in 1986, it should also be convenient for him to state the
name as demanded by the Sworn INEC form CF001.

CONCLUSION

Excellency Sir, it is deducible from the above-stated facts, vis-à-vis the above-
cited statutory and judicial authorities, that some of the past actions and records
of HE. Prince Adedapo Oluseun Abiodun amount to grave infractions of the
provisions of the Constitution. I, therefore, make a call for his disqualification
from any future elective position in the All Progressives Congress. An attempt
to field or present HE. Prince Adedapo Oluseun Abiodun for the 2023
gubernatorial election in Ogun State will simply amount to inadvertently (or
perhaps deliberately, having brought these infractions to your attention, sir)
ceding Ogun State to opposition parties as they have rightly commenced the
process of filing for his disqualification because he is not eligible to contest or
aspire for the office of governor of Ogun State or any State for that matter due
to the many constitutional and electoral law violations earlier enumerated.

In any case, by a consequential locus as gleaned from Section 84 (14) of the

Electoral Act 2022, as amended, which reads thus;

“Notwithstanding the provisions of this Act or rules of a

political party, an aspirant who complains that any of the
provisions of this Act and the guidelines of a political party
have not been complied with in the selection or nomination
of a candidate of a political party for election, may apply to
the Federal High Court for redress”.

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I am aware that, as an aspirant who is also committed to purchasing the form
to contest for the 2022 gubernatorial Primaries for the Governor of Ogun State
on the platform of our great Party (APC), there is a judicial leeway -at the law
courts - to seek the qualification of HE. Prince Adedapo Oluseun Abiodun from
being fielded at the forthcoming 2023 election but, as a loyal party man, I have
chosen this path of honour in regard for your highly distinguished person and
official authority, therefore making a conscious decision to, first and foremost,
bring these issues to your attention for justice, at the party level.

Therefore, sir, I most sincerely implore you to stand on the side of history and
integrity. I beseech you to remember the confidence reposed in you on the 26th
of March 2022 by the President and Commander in Chief of the Armed Forces
of the Federal Republic of Nigeria, His Excellency President Mohammed Buhari,
GCON, all the delegates to the National Convention, and the entire members of
our great Party, All Progressives Congress (APC), in electing you, our chairman.

Please use your good office to lay the foundation of trust, equity, and honour
in our party, APC, by ensuring that only credible candidates who have been
affirmed worthy in character and pedigree, candidates without any criminal
record, or impediments whatsoever, participate in the forthcoming primaries
and thus, emerge as flagbearers for all the various elective positions. This case
should be the starting point in this quest.

I accept the possibility that there will be attempts to blackmail you and by
extension surreptitiously pressure the National Working Committee (NWC) to
toe the path of the dishonourable old ways that almost brought our great party
to its knees but I am enamored of the quality and integrity of members of the
present National Working Committee, headed by your noble self, as this exudes
confidence in many of us to the extent that the right thing shall be done: that
HE. Prince Adedapo Oluseun Abiodun will be advised not to participate in the
forthcoming Ogun State Governorship Primaries.

However, should he decide not to yield the wise counsel of the NWC, he must
be prevented by way of disqualification so as not to jeopardize the chances of
our party in Ogun State at the 2023 gubernatorial elections.

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Finally, please note sir that all the supreme court judgements cited in this
petition on INEC form CF001 are unanimous decisions, there were no dissenting
judgements at all. This means that at least ten (10) Supreme court justices have
aligned that the form is a sworn document which invariably makes it a certificate
and any discrepancy makes it worthless thus becoming a ground for the
disqualification of a candidate.

Thank you, sir, in anticipation of your kind co-operation and action.

Yours faithfully,

___________________
Mr. Ayodele Oludiran,
APC Member,
Abeokuta South Local Government, Ogun State.

CC:
National Secretary, APC
National Vice Chairman, Southwest, APC.
National Legal Adviser, APC.
National Publicity Secretary, APC.
HE. Dr. Kayode Fayemi, Chairman of Nigeria Governors’ forum.
HE. Gov. Atiku Bagudu, Chairman of Progressive Governors’ forum
HE. Gov. Rotimi Akeredolu, Chairman of Southern Governors' forum
HE. Gov. Mohammed A. Badaru, Chairman of Northern Governors’ forum.

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 APPENDICES
APPENDIX PAGE CONTENT
Appendix 1 2 ADAPHAI’s petition to HE. Gov. Mai Mala Buni.
Appendix 2 2 COSSY’s petition to HE. Prince Adedapo Oluseun Abiodun
Appendix 3 2 COSSY’s petition to the Ogun State House of Assembly.
Appendix 4 2 COSSY’s petition to the Speaker of the Ogun State House of Assembly, Rt.
Hon. Olakunle Oluomo.
Appendix 5 3 INEC form CF001 (2019): Highlighting the Primary School attended by HE.
Prince Adedapo Oluseun Abiodun
Appendix 6 3 INEC form CF001 (2015): Highlighting the Primary School attended by HE.
Prince Adedapo Oluseun Abiodun (different from that of Appendix 13)
Appendix 7 3 Evidence of the non-existence of the two Primary Schools Filled by HE. Prince
Adedapo Oluseun Abiodun in his 2015 and 2019 forms.
Appendix 8 4 INEC form CF001 (2015): Highlighting the period of employment of HE.
Prince Adedapo Oluseun Abiodun at Heyden Petroleum Ltd. (2001 till Date)
Appendix 9 4 INEC form CF001 (2019): Highlighting the period of employment of HE.
Prince Adedapo Oluseun Abiodun at Heyden Petroleum Ltd. (1993 till Date)
Appendix 10 5 INEC form CF001 (2015): Highlighting that HE. Prince Adedapo Oluseun
Abiodun attended Obafemi Awolowo University in 1980.
Appendix 11 5 INEC form CF001 (2019): Highlighting the silence on Obafemi Awolowo
University.
Appendix 12 6 Evidence of Arrest of Michael Shawn Davis and Adedapo Oluseun Abiodun, in
1986.
Appendix 13 6 Evidence of Jail Number of Adedapo Oluseun Abiodun (Alias Shawn Michael
Davis)
Appendix 14 7 Evidence of redaction of his Criminal records by HE. Prince Adedapo Oluseun
Abiodun in 2015.
Appendix 15 8 INEC form CF001 (2015): Highlighting the name Adedapo Oluseun Abiodun
Appendix 16 8 INEC form CF001 (2019): Highlighting the name Adedapo Oluseun Abiodun
Appendix 17 8 INEC form CF001 (2015 and 2019): Highlighting Sections where HE. Prince
Adedapo Oluseun Abiodun filled that he had never been indicted for criminal
offenses.
Appendix 18 8 INEC form CF001 (2015): Highlighting that HE. Prince Adedapo Oluseun
Abiodun did not disclose that he once was known as Shawn Michael Davis.
Appendix 19 8 INEC form CF001 (2019): Highlighting that HE. Prince Adedapo Oluseun
Abiodun did not disclose that he once was known as Shawn Michael Davis.
Appendix 20 8 Document from the Circuit and County Court of the Eleventh Judicial Circuit
of Florida in and For Miami Dade County, capturing and affirming that HE.
Prince Adedapo Oluseun Abiodun was - as far back as 1986 - also known as
Shawn Michael Davis.

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