Criminal Litigation Drafts

CRIMINAL LITIGATION DRAFTS
ARRESTS, SEARCHES, CONSTITUTIONAL RIGHTS
1. Summons
2. Warrant of Arrest
3. Search Warrant
PRETRIAL INVESTIGATION
4. Application for Legal Aid
CHARGES
5. Charge in Magistrate Court North

6. Charge in High Court North
7. Charge in Magistrate Court South
8. Information in High Court South
9. Charge in High Court of FCT
10. Information in High Court of FCT
11. Charge in Federal High Court
BAIL PENDING TRIAL
12. Application for Police Bail

13. Application for Bail Pending Trial (Summons/Motion)
TRIAL PREPARATION & EVIDENCE
14. Case Theory

15. Trial Plan
JUDGMENT & SENTENCING
16. Allocutus
APPEALS
17. Notice & Grounds of Appeal

18. Bail Pending Appeal
SUMMONS (CRIMINAL FORM 4)
IN THE MAGISTRATE COURT OF LAGOS STATE
IN THE IKEJA MAGISTERIAL DISTRICT
HOLDEN AT IKEJA
CHARGE NO:
BETWEEN
COMMISSIONER OF POLICE COMPLAINANT
AND
ADEKUNLE GOLD DEFENDANT
TO ADEKUNLE GOLD of
3 Juice Estate, Ikeja,
Lagos
Complaint has been made this day by Corporal Joy of Ikeja Police Station, Ikeja that you Adekunle Gold
on the 5th day of October 2020 at Ikeja, within the jurisdiction of this court, did commit an offence of
stealing contrary to _______ of the Criminal Law of Lagos State.
You are hereby summoned to appear before Magistrate Court sitting at Ikeja on the ____ day of
_________ 2020 at the hour of 9 O’ Clock in the forenoon to answer the said complaint.
Dated this ______ day of ________ 2020
______________
Judge [or Magistrate]
Warrant For Arrest Of Defendant Who Has Disobeyed Summons [CRIMINAL FORM 5]
HOLDEN AT IKEJA
CHARGE NO:
BETWEEN
AND
WARRANT FOR ARREST OF DEFENDANT WHO HAS DISOBEYED SUMMONS
To Corporal Gold
or to each and all Police Officers.
Complaint has been made on the ______ day of __________2020 that Adekunle Gold, hereinafter called
the defendant, was thereupon summoned to appear before the Magistrate Court, sitting at Ikeja
Magisterial District on the _______ day of __________ 2020 at the hour of 9 o’ clock in the forenoon,
but did not appear and that such complaint is true
You are hereby commanded to bring the defendant before Magistrate's Court, Ikeja in the Ikeja
Magisterial District sitting at Ikeja forthwith to answer to the said complaint and be further dealt with
according to law.
Dated this ______ day of ________ 2020
______________
Judge [or Magistrate]
● WARRANT OF ARREST (CRIMINAL FORM 6)
HOLDEN AT IKEJA
CHARGE NO:
BETWEEN
AND
To: Corporal XYZ,
‘D’ Divisional Police Station, Ikeja,
Lagos
WARRANT FOR THE APPREHENSION OF DEFENDANT AT FIRST INSTANCE
Complaint on oath has been made on the ____ day of ______ 2020 by one Joy Gold that Adekunle Gold,
hereinafter called the defendant, on the _______ day of ________ 2020 at 5, Airport Road, Ikeja was
involved in _________ contrary to ____________ of Criminal Law of Lagos State.
You are hereby commanded to bring the defendant before Magistrate Court Ikeja in the Ikeja
Magisterial District sitting at Ikeja forthwith to answer the said complaint and be dealt with according to
law.
Dated this ________ day of ___________ 2020
__________________
Magistrate
SEARCH WARANT [CRIMINAL FORM 7]

HOLDEN AT IKEJA
CHARGE NO:
BETWEEN
AND
TO CORPORAL XYZ of Ikeja Police Station,
5, Airport Road, Ikeja
Lagos
SEARCH WARRANT
Whereas information on oath and in writing this day has been made that there is reasonable ground for
believing that there is in 20, Airport Road, Ikeja, Lagos, the selling of police uniform contrary to Section
111 of the Criminal Law of Lagos State.
You are hereby commanded in the name of Lagos State, with proper assistance, to enter the
above-named premises and there diligently search for the things aforesaid and if same or any part
thereof found on search, to bring the things found before this Court to be dealt with according to law.
This warrant shall be executed between the hours of 5 o’ clock in the forenoon and 8 o’ clock at night,
and may also be executed at any hour during the day or night.
Issued at ___________ this _______ day of _____________ 2020
_________________
Magistrate
APPLICATION FOR LEGAL AID
Adekunle Gold,
5, Airport Road,
Ikeja, Lagos
14th October, 2020
Director-General,
Legal Aid Council,
5, Vicky Estate, Ikeja
Lagos
Dear Sir,
APPLICATION FOR LEGAL AID
I wish to apply for legal representation from the Legal Aid Council to assist me in conducting my defence.
I was arrested for the offences of stealing and affray, and I have been informed that I will be charged to
court.
My annual income is N12,500 (Twelve Thousand, Five Hundred Naira) only, as shown in the payment slip
attached to this letter.
Thank you.
Yours faithfully,
______________
Adekunle Gold.
Encl: Annual Payment Slip.
CHARGES
A. MAGISTRATE COURT NORTH
IN THE MAGISTRATE COURT OF KADUNA STATE
IN THE KADUNA MAGISTERIAL DISTRICT
HOLDEN AT KADUNA
CASE NO:
BETWEEN
AND
AISHA GOLD ACCUSED PERSON
I, Mallam Yusuf Bisha, Chief Magistrate, Grade I, do hereby charge you, Aisha Gold, as follows:
CHARGE ONE
That you, Aisha Gold, on or about the 1st day of July 2020, at 5, Shinkasa Street, Yalla, Kaduna in the
Kaduna Magisterial District, stole a bag belonging to Miss Yesufu, and thereby committed an offence
punishable under Section ____ of the Penal Code Laws of Kaduna State, Cap___, Laws of Kaduna State,
and triable by this court.
And I hereby direct that you be tried by this court on the said charge.
Dated the 14th day of October, 2020.

__________________
Mallam Yusuf Bisha
Chief Magistrate
Grade I
B. HIGH COURT NORTH
IN THE HIGH COURT OF BENUE STATE
IN THE IDOMA JUDICIAL DIVISION
HOLDEN AT IDOMA
CASE NO:
BETWEEN
THE STATE COMPLAINANT
AND
AISHA BELLO ACCUSED PERSON
CHARGE ONE
That you, Aisha Bello, on or about the 1st day of August, 2020, at 5, Airport Road, Idoma in the Idoma
Judicial Division, broke into the house of one Miss Yesufu, and made away with the sum of N100,000
belonging to Miss Yesufu, and thereby committed an offence of armed robbery punishable under Section
---- of the Penal Code Laws of Benue State.
Dated the 14th day of October, 2020.
__________________
Vanilla Gold
Principal State Counsel
For: The Attorney general
Benue State
C. MAGISTRATE COURT SOUTH
HOLDEN AT IKEJA
CHARGE NO:
BETWEEN

AND
JAMES DEAN DEFENDANT
COUNT ONE
That you, James Dean, on or about the 25th day of August, 2020, at 5 Airport Road, Ikeja in the Ikeja
Magisterial District, stole the sum of N50,000 belonging to Marilyn Monroe, and thereby committed an
offence punishable under Section ----- of the Criminal Law of Lagos State, Cap ___, Laws of Lagos State,
2004.
Dated this _____ day of _______ 2020.
________________
Inspector Joy Gold
Police Officer
D. HIGH COURT SOUTH
IN THE HIGH COURT OF LAGOS STATE
IN THE IKEJA JUDICIAL DIVISION
HOLDEN AT IKEJA
CHARGE NO:
BETWEEN
THE STATE OF LAGOS COMPLAINANT
AND
At the session of this Court holden at Ikeja, on the ____ day of _______ 2020, the Court is informed by
the Attorney General of the State, on behalf of the State, that:
James Dean is charged with the following offence:
COUNT ONE
STATEMENT OF OFFENCE
Armed Robbery contrary to Section 2(a) of the Robbery and Firearms (Special Provisions) Act, Cap R11
LFN, 2004.
PARTICULARS OF OFFENCE
James Dean on or about the 2nd day of June, 2020, at 5 Airport Road, Ikeja in the Ikeja Judicial Division,
whilst armed with guns broke into Madam Justice’s house, and stole the sum of N500,000.
Dated this 14th day of October, 2020.

________________
Erica Nlewedim Esq.
For: Attorney General of Lagos State
E. MAGISTRATE COURT FCT
IN THE MAGISTRATE COURT OF FEDERAL CAPITAL TERRITORY
IN THE ABUJA MAGISTERIAL DISTRICT
HOLDEN AT ABUJA
CHARGE NO:
BETWEEN
AND
COUNT ONE
That you, James Dean, on or about the 25th day of August, 2020, at 5 Airport Road, Abuja in the Abuja
Magisterial District, stole the sum of N50,000 belonging to Marilyn Monroe, and thereby committed an
offence punishable under Section ----- of the Penal Code.
Dated this _____ day of _______ 2020.
________________
Inspector Joy Gold
Police Officer
F. HIGH COURT FCT
IN THE HIGH COURT OF FEDERAL CAPITAL TERRITORY
IN THE ABUJA JUDICIAL DIVISION
HOLDEN AT ABUJA
CHARGE NO:
BETWEEN
FEDERAL REPUBLIC OF NIGERIA COMPLAINANT
AND
At the session of this Court holden at Abuja, on the ____ day of _______ 2020, the Court is informed by
the Attorney General of the Federation, on behalf of the Federal Republic of Nigeria, that:
James Dean is charged with the following offence:
COUNT ONE
Armed Robbery contrary to Section 2(a) of the Robbery and Firearms (Special Provisions) Act, Cap R11
LFN, 2004.
James Dean on or about the 2nd day of June, 2020, at 5 Airport Road, Abuja in the Abuja Judicial Division,
whilst armed with guns broke into Madam Justice’s house, and stole the sum of N500,000.
Dated this 14th day of October, 2020.
________________
Erica Nlewedim Esq.
For: Attorney General of Federation
G. FEDERAL HIGH COURT
IN THE FEDERAL HIGH COURT OF NIGERIA
IN THE LAGOS JUDICIAL DIVISION
HOLDEN AT LAGOS
CHARGE NO:
BETWEEN
FEDERAL REPUBLIC OF NIGERIA COMPLAINANT
AND
COUNT ONE
That you, James Dean, on or about the 25th day of August, 2020, at 5 Airport Road, Lagos within the
Lagos Judicial Division, without lawful authority, were engaged in the selling of drugs otherwise known
as “cocaine” to truck drivers, and thereby committed an offence punishable under Section 11(b) of the
National Drugs Law Enforcement Agency Act, 2004.
Dated this _____ day of _______ 2020.

________________
Erica Nlewedim
Senior Law Officer
For the Chairman, NDLEA
APPLICATION FOR POLICE BAIL
FKA CHAMBERS
LEGAL PRACTITIONERS & SOLICITORS
2, KOKO DRIVE, IKOYI, LAGOS
www.fkachambers.com
fkachambers@gmail.com
08023323456
Our Ref: Your Ref: Date: 14th October, 2020
The Divisional Police Officer,
Ikeja Police Station,
Ikeja, Lagos.
Dear Sir,
APPLICATION FOR BAIL
I, Erica Nlewedim, as legal practitioner, hereby apply for bail of Adekunle Gold (my client), who was
arrested on 16th July, 2020, at 3, Airport Road, Ikeja, Lagos, for alleged offence of rape of one Miss Aisha
Gold, and is now in police custody.
Upon his release on bail, he will appear in court at all times when necessary and will not jump bail on
release. I recommend Marilyn Monroe of 45, Akpan Crescent, Lagos, as surety for my client’s bail.
Thank you for your anticipated cooperation.
Yours faithfully,
___________________
Erica Nlewedim Esq
FOR: FKA Chambers
APPLICATION FOR BAIL PENDING TRIAL
A. SUMMONS FOR BAIL IN HIGH COURT SOUTH

HOLDEN AT IKEJA
CHARGE NO:
BETWEEN
THE STATE OF LAGOS COMPLAINANT/RESPONDENT
AND
ADEKUNLE GOLD DEFENDANT/APPLICANT
SUMMONS FOR BAIL
BROUGHT PURSUANT TO SECTION 115 OF THE ADMINISTRATION OF CRIMINAL JUSTICE LAW OF LAGOS
STATE 2011, SECTION 35(4) AND 36 OF THE CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA,
1999 (AS AMENDED) AND UNDER THE INHERENT JURISDICTION OF THIS COURT
LET ALL THE PARTIES concerned attend at the High Court of Lagos State holden at 9 O’ Clock in the
forenoon or so soon thereafter on the hearing of an application for:
1. AN ORDER of this honorable court admitting the Defendant/Applicant to Bail.

2. AND FOR SUCH FURTHER ORDER OR ORDERS as this Honorable Court may deem fit to make in
the circumstances.
Dated the 14th day of October 2020.
________________
Erica Nlewedim Esq
Defendant/Applicant’s Counsel
FKA Chambers
16, Eve Road, Ikeja, Lagos
FOR SERVICE ON
The Complainant/Respondent
Attorney-General of Lagos State
Ministry of Justice,
Lagos.
AFFIDAVIT IN SUPPORT OF SUMMONS FOR BAIL
HOLDEN AT IKEJA
CHARGE NO:
BETWEEN
ADEKUNLE GOLD APPLICANT
AND
THE STATE OF LAGOS RESPONDENT
AFFIDAVIT IN SUPPORT OF SUMMONS FOR BAIL
I, Tatiana Gold, Female, Christian, Entrepreneur, Nigerian citizen of No. 3 Sunshine Estate, Lagos Island,
Lagos State, do hereby make oath and state as follows:
1. That I am the elder sister of the Accused/Applicant, and by virtue of this fact I am familiar with
the facts of this case.
2. That I have the authority and consent of the accused/applicant to depose to this affidavit.
3. That the Applicant was arrested by some police officers on the 10th of September 2019 on the
allegation of rape of one Miss Aisha Gold in his house at No 3, Airport Road, Ikeja, Lagos.
4. That I know for a fact that the Applicant is innocent of these allegations, as he traveled together
with me on the said date (10th September 2019) to Abuja, Federal Capital Territory, Nigeria to
attend some official meetings, and we came back to Lagos two days after.
5. That the Applicant informed me in our house and I verily believe him that he had informed the
police of his whereabouts on the said date and time but they insisted on prosecuting him.
6. That I know for a fact that the suspicion of the Applicant of the offence by the police must be as
a result of mistake of identity and that he is innocent of the offence.
7. That if granted, the Applicant would not jump bail.
8. That I make this oath bona fide and in accordance with the Oaths Act.
………………………………..
DEPONENT
Sworn to at the High Court, Lagos State, this…………….. day of…………………………. 2020.
BEFORE ME
……………………………………………..
COMMISSIONER FOR OATHS
B. MOTION FOR BAIL IN HIGH COURT NORTH
IN THE HIGH COURT OF FEDERAL CAPITAL TERRITORY
HOLDEN AT ABUJA
CASE NO:
BETWEEN
FEDERAL REPUBLIC OF NIGERIA COMPLAINANT/RESPONDENT
AND
AISHA GOLD DEFENDANT/APPLICANT
MOTION ON NOTICE FOR BAIL
BROUGHT PURSUANT TO SECTION 164 AND 165 OF THE ADMINSTRATION OF CRIMINAL JUSTICE ACT,
AND SECTION 35(4) AND 36 OF THE CONSTITUTION OF FEDERAL REPUBLIC OF NIGERIA 1999 (AS
AMENDED) AND UNDER THE INHERENT JURISDICTION OF THIS COURT
TAKE NOTICE that this Honorable Court will be moved on the _____ day of ________ 2020, at the hour
of 9 o’ clock in the forenoon or so soon thereafter as Counsel to the Applicant may be heard praying the
court for the following reliefs:
1. AN ORDER of this honorable court admitting the Defendant/Applicant to Bail.

2. AND FOR SUCH FURTHER ORDER OR ORDERS as this Honorable Court may deem fit to make in
the circumstances.
Dated the 14th day of October 2020.
________________
Erica Nlewedim Esq
Applicant’s Counsel
FKA Chambers
16, Eve Road, Abuja, FCT
FOR SERVICE ON
The Complainant/Respondent
Attorney General of Federation
Abuja, FCT
CASE THEORY
TRIAL PLAN FOR PROSECUTION
Charge Law Ingredients Evidence/Witnesses Penalty Prayer Remark

of the
Offence
NOTICE OF APPEAL FROM HIGH COURT TO NOTICE OF APPEAL [CRIMINAL FORM 1]
IN THE COURT OF APPEAL
HOLDEN AT ABUJA
APPEAL NO:
CHARGE NO:
BETWEEN
AISHA GOLD APPELLANT
AND
FEDERAL REPUBLIC OF NIGERIA RESPONDENT
NOTICE OF APPEAL
TO THE REGISTRAR OF THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY, ABUJA
I, Aisha Gold, having been convicted of the offence of armed robbery and sentenced to fourteen years
imprisonment with hard labour, and now being a prisoner at the Federal Prison, Kuje, Abuja, do hereby
give notice of appeal against my conviction to the court on the following grounds:
GROUNDS OF APPEAL
GROUND 1
That the learned trial judge erred in law when delivering his ruling on a no-case submission made by the
accused person at the trial.
PARTICULARS
1. The prosecution has not established a prima facie case against the accused person to warrant it
entering its defence.
2. That the onus of proof rests on the prosecution throughout the trial.
3. The decision of the court violated the constitutional right of presumption of innocence given to
the accused person.
GROUND 2
That the learned trial judge misdirected itself when it held thus:
“For the….”
PARTICULARS OF MISDIRECTION
1. The presumption of innocence of an accused person is sacrosanct and as such a defendant is not
required to testify in court.
GROUND 3
The decision of the trial court is unreasonable and cannot be supported having regard to the evidence.
__________________________
Signature or Mark of Appellant
__________________________
Signature and address of witness attesting mark
Dated 14th day of October 2020
PARTICULARS OF TRIAL & CONVICTION
Date judgment was delivered:
In what court tried:
Judge:
Sentence:
Whether questions of law now raised were raised at trial: No
Do you desire to be present on the hearing of your appeal by the court: Yes
BRIEFS OF ARGUMENT
HOLDEN AT ABUJA
APPEAL NO:
CHARGE NO:
BETWEEN
AND
APPELLANT’S BRIEF OF ARGUMENT
1.0 INTRODUCTION
2.0 STATEMENT OF FACTS
3.0 GROUNDS OF APPEAL
4.0 ISSUES FOR DETERMINATION
5.0 ARGUMENTS
6.0 RELIEFS SOUGHT
7.0 CONCLUSION
Dated this 14th day of October, 2020
________________
Erica Nlewedim Esq
Appellant’s Counsel
FKA Chambers
FOR SERVICE ON
The Respondent
Attorney-General of Federation
Abuja, FCT.
LIST OF AUTHORITIES
1. …
2. …
3. …
NOTICE OF LEAVE TO APPEAL
HOLDEN AT ABUJA
APPEAL NO:
CHARGE NO:
BETWEEN
AND

NOTICE OF LEAVE TO APPEAL
TO THE REGISTRAR OF THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY, ABUJA
I, Aisha Gold, having been convicted of the offence of armed robbery and sentenced to fourteen years
imprisonment with hard labour, and now being a prisoner at the Federal Prison, Kuje, Abuja, do hereby
apply for leave to appeal against my conviction to the court on the following grounds:
GROUNDS OF APPEAL
GROUND 1
That the learned trial judge erred in law when delivering his ruling on a no-case submission made by the
accused person at the trial.
PARTICULARS
1. The prosecution has not established a prima facie case against the accused person to warrant it
entering its defence.
2. That the onus of proof rests on the prosecution throughout the trial.
3. The decision of the court violated the constitutional right of presumption of innocence given to
the accused person.
__________________________
Signature or Mark of Appellant
__________________________
Signature and address of witness attesting mark
Dated 14th day of October 2020
PARTICULARS OF TRIAL & CONVICTION
Date judgment was delivered:
In what court tried:
Judge:
Sentence:
If you desire to be present when the court considers your present application for leave to appeal, state:
Whether or not you are legally represented, and the grounds on which you submit that the court should
give you leave to be present thereat.
MOTION FOR EXTENSION OF TIME TO APPEAL [CRIMINAL FORM 7]

HOLDEN AT ABUJA
APPEAL NO:
CHARGE NO:
BETWEEN
AISHA GOLD APPELLANT/APPLICANT
AND
NOTIFICATION OF APPLICATION FOR EXTENSION OF TIME WITHIN WHICH TO APPEAL
BROUGHT PURSUANT TO ORDER 17 RULE 5 COURT OF APPEAL RULES 2016 AND UNDER THE INHERENT
JURISDICTION OF THIS COURT
To the Registrar,
Court of Appeal,
Abuja
I, Aisha Gold, having been convicted of the offence of armed robbery on the ____ day of _______ 2020
in the High Court of the Federal Capital Territory, Abuja, presided over by Honorable Justice Dauda
Ibrahim, and being a prisoner at Kuje Prison, Abuja, do hereby apply to court for an extension of time
within which I may give Notice of Appeal on the following grounds:
1. That the judgment is unreasonable and cannot be supported having regard to the evidence.
2. Further grounds will be filed on the receipt of the records of proceedings.
Dated the 14th day of October, 2020
Aisha Gold
Appellant/Applicant
Federal Prisons
Kuje
FOR SERVICE ON
The Respondent
Director of Prosecution
Federal Ministry of Justice,
Abuja, FCT.

HOLDEN AT ABUJA
APPEAL NO:
CHARGE NO:
BETWEEN
AND
MOTION ON NOTICE
BROUGHT PURSUANT TO SECTION 28(1) COURT OF APPEAL ACT 2004 AND UNDER THE INHERENT
JURISDICTION OF THE COURT
TAKE NOTICE that this Honorable Court will be moved on the ______ day of _______ 2020, at the hour
of 9 o’ clock in the forenoon or so soon thereafter as Counsel to the Appellant/Applicant may be heard
praying the court for the following reliefs:
1. AN ORDER OF COURT releasing the applicant/appellant to bail pending the hearing and
determination of the appeal before this court.
2. AND FOR SUCH FURTHER ORDER OR ORDERS as this honorable court may deem fit to make in
the circumstances.
________________
Erica Nlewedim Esq
Appellant’s Counsel
FKA Chambers
FOR SERVICE ON
The Respondent
Director of Public Prosecutions
Federal Ministry of Justice,
Abuja, FCT.
AFFIDAVIT IN SUPPORT OF MOTION FOR BAIL PENDING APPEAL

HOLDEN AT ABUJA
APPEAL NO:
CHARGE NO:
BETWEEN
AND
AFFIDAVIT IN SUPPORT OF MOTION FOR BAIL
I, Tatiana Gold, Female, Adult, Muslim, Businesswoman, Nigerian Citizen of 3 Jabi Estate, Abuja, FCT do
hereby make oath and say as follows:
1. That I am the sister to the Appellant/Applicant in this case.

2. That by virtue of my position, I am very conversant with the facts of the case.
3. That I know as a fact that on the 2nd of July 2020 the Appellant/Applicant was convicted of the
offence of armed robbery by the High Court FCT, Abuja presided over by Honorable Justice
Dauda Ibrahim.
4. That consequent upon the conviction as aforesaid, the Appellant/Applicant was sentenced to 14
years of imprisonment with hard labor.
5. That the Appellant/Applicant is now serving her sentence at Federal Prison, Kuje, Abuja, FCT.
6. That I know as a fact that the Appellant/Applicant has appealed against the judgment of His
Lordship Dauda Ibrahim on the 25th of August 2020.
7. That the said Notice of Appeal and the grounds of appeal are attached herewith as ‘Exhibit B’.
8. That I know for a fact that the Appellant/Applicant has also filed a motion seeking extension of
time to file his appeal out of time and the said application is pending before this honorable court
for hearing.
9. That counsel to the Applicant/Appellant Erica Nlewedim Esq informed me in her office on the
25th of August 2020, and I verily believe that the ground of appeal is challenging the jurisdiction
of the lower court to entertain the case.
10. That Counsel to the Applicant/Appellant further informed me that the ground of appeal also
contained grounds bordering on infringement of the constitutional rights of the
Appellant/Applicant.
11. That the Appellant/Applicant informed me at the Federal Prisons, Kuje, Abuja, FCT that if granted
bail, it will grant him the opportunity of regularly consulting with her counsel.
12. That the applicant further informed me that she would not jump bail and will prosecute the
appeal to its logical conclusion.
13. That I make this affidavit in good faith believing same to be true and in accordance with Oaths
Act.
_____________________
DEPONENT
SWORN TO AT THE COURT OF APPEAL REGISTRY, ABUJA
THIS _____ DAY OF ______ 2020
BEFORE ME
______________________________
COMMISSIONER FOR OATHS
HOLDEN AT ABUJA
APPEAL NO:
CHARGE NO:
BETWEEN
AND
TO THE REGISTRAR
COURT OF APPEAL
ABUJA
NOTICE OF ABANDONMENT OF APPEAL
BROUGHT PURSUANT TO ORDER 17 RULE 18 COURT OF APPEAL RULES 2016
I, Aisha Gold, of Federal Prisons, Kuje, Abuja, FCT, having been convicted of the offence of armed robbery
and sentenced to fourteen years of imprisonment with hard labor by the High Court FCT, Abuja, presided
over by Honorable Justice Dauda Ibrahim on the 2nd of July 2020, and having been desirous of appealing
to the Court of Appeal against the said conviction and sentence do hereby give notice that I do not
intend further to prosecute my appeal, and I hereby abandon all further proceedings in regard thereto as
from the date thereof.
____________________
Signature/Mark of Appellant
_____________________
Signature and Address of Witness attesting Mark
Dated this 14th day of October 2020

PAST QUESTIONS
1. Draft the Charges
IN THE HIGH COURT OF OYO STATE
IN THE IBADAN JUDICIAL DIVISION
HOLDEN AT IBADAN
CHARGE NO
BETWEEN
AND
1. OKPORORO VRENDO
2. TAMUNO PREYE
3. DIKE NNE DEFENDANTS
At the session of this Court, holden at Ibadan on the _____ day of _______ 2020, the Court is informed
by the Attorney General of the State, on behalf of the State, that the following persons
1. OKPORORO VRENDO
2. TAMUNO PREYE
3. DIKE NNE
Are charged with the following:
COUNT 1
Impersonating police officers, contrary to Section 109 of the Criminal Code Law of Oyo State.
Okpororo Vrendo, Tamuno Preye and Dike Nne, on or about the 2nd day of August 2019, at Itire road,
Lagos-Ibadan Expressway within the Ibadan Judicial Division, wore mobile police uniforms, thereby
impersonating members of the Police Force.
COUNT 2
Murder contrary to Section 319(1) of the Criminal Code Law of Oyo State
Lagos-Ibadan Expressway within the Ibadan Judicial Division, murdered Mr. Ita Udo.
COUNT 3
Murder contrary to Section 319(1) of the Criminal Code Law of Oyo State
Lagos-Ibadan Expressway within the Ibadan Judicial Division, murdered Mrs Benita Itodo.
COUNT 4
Kidnapping contrary to Section 364(2) of the Criminal Code Law of Oyo State
Lagos-Ibadan Expressway within the Ibadan Judicial Division, kidnapped Iyabo Ekaro.
COUNT 5
Conspiracy contrary to Section 516 of the Criminal Code Law of Oyo State
Lagos-Ibadan Expressway within the Ibadan Judicial Division, conspired to kidnap Iyabo Ekaro.
COUNT 6
Armed Robbery contrary to Section 1(2) of the Robbery and Firearms (Special Provisions) Act, CAP R1
LFN 2004.
Okpororo Vrendo, Tamuno Preye and Dike Nne, on or about the 2nd day of August 2019, at Oshodi, Lagos
within the Judicial Division of this court, whilst armed with guns, robbed Uche Johnson of his Toyota
Corolla Car with Registration Number LKD 221 VI.
COUNT 7
LFN 2004.
within the Judicial Division of this court, whilst armed with guns, robbed Uche Johnson of his iPhone
worth N500,000.
COUNT 8
LFN 2004.
within the Judicial Division of this court, whilst armed with guns, robbed Uche Johnson of his Rolex
wristwatch worth N1,000,000.
COUNT 9
Rape contrary to Section 358 of the Criminal Code Law of Oyo State.
Okpororo Vrendo on or about the 2nd day of August 2019, at Ajegunle, Lagos within the Judicial Division
of this court, raped Iyabo Ekaro.
Dated the ____ day of ________ 2020
___________________
Vanilla Gold
FOR: Attorney General of Oyo State
CHARGE SHEET TWO
IN THE HIGH COURT OF OYO STATE
IN THE IBADAN JUDICIAL DIVISION
HOLDEN AT IBADAN
CHARGE NO
BETWEEN
AND
1. OKPORORO VRENDO
2. TAMUNO PREYE
3. DIKE NNE DEFENDANTS
At the session of this Court, holden at Ibadan on the _____ day of _______ 2020, the Court is informed
by the Attorney General of the State, on behalf of the State, that the following persons
1. OKPORORO VRENDO
2. TAMUNO PREYE
3. DIKE NNE
Are charged with the following offence:
COUNT 1
Robbery contrary to Section 1(1) of the Robbery and Firearms (Special Provisions) Act, CAP R1 LFN 2004.
Okpororo Vrendo, Tamuno Preye and Dike Nne, on or about the 2nd day of December 2018, at Itire Road,
Ibadan within the Ibadan Judicial Division robbed Arrow Bank of N3,000,000.
Dated the ____ day of ________ 2020
___________________
Vanilla Gold
FOR: Attorney General of Oyo State
IN THE HIGH COURT OF NIGER STATE
IN THE MINNA JUDICIAL DIVISION
HOLDEN AT MINNA
CASE NO:
BETWEEN
AND
1. OGUEBEGO UGO
2. ANYASADOR AUWULU
3. NGADI INADIKE ACCUSED PERSONS
CHARGE ONE
That you, Oguebego Ugo, Anyasador Auwulu and Ngadi Inadike, on or about the 5th of June 2018, at
Bosso Road, Mina within the Minna Judicial Division, conspired to commit the offence of armed robbery
and thereby committed an offence punishable under Section 97(1) of the Penal Code Law of Niger State.
CHARGE TWO
Bosso Road, Mina within the Minna Judicial Division, whilst armed with AK 47 rifles, broke into the vault
of Express Bank and made away with the sum of N50,000,000, thereby committing the offence of armed
robbery punishable under Section 2(a) Robbery and Firearms (Special Provisions) Act, Cap R11 LFN 2004.
CHARGE THREE
That you, Ngadi Inadike, on or about the 5th of June 2018, at Bosso Road, Mina within the Minna Judicial
Division, caused the death of Corporal Sule Dongo, a police officer in charge of security at Standard
Express Bank, by shooting him with a gun, and thereby committed the offence of culpable homicide
punishable with death under Section 221(a) of the Penal Code Law of Niger State.
CHARGE FOUR
Kusugi Road, Mina within the Minna Judicial Division, caused the death of Sergeant Ibrahim Talakiwa,
who was manning a road block, by shooting him with a gun and thereby committed the offence of
culpable homicide punishable with death under Section 221 of the Penal Code Law of Niger State.
CHARGE FIVE
Kusugi Road, Mina within the Minna Judicial Division, murdered Corporal Bokobin Ebube, who was
manning a road block, by shooting him with a gun and thereby committed the offence of culpable
homicide punishable with death under Section 221 of the Penal Code Law of Niger State.
CHARGE SIX
Kusugi Road, Mina within the Minna Judicial Division, murdered Inspector Alhassan Johnson, who was
manning a road block, by shooting him with a gun and thereby committed the offence of culpable
homicide punishable with death under Section 221 of the Penal Code Law of Niger State.
CHARGE SEVEN
That you, Oguebego Ugo, Anyasador Auwulu and Ngadi Inadike, on or about the 5th of June 2018, at 10,
Canisters Street, Lapai near Minna within the Minna Judicial Division, whilst armed, entered into a
supermarket belonging to Mallam Sadanki Maigmaleri and robbed him of his 43 inches flat screen
Samsung Television, thereby committing an offence of armed robbery punishable under Section 1(2)
Robbery and Firearms (Special Provisions) Act, Cap R11 LFN 2004.
CHARGE EIGHT
That you, Oguebego Ugo, on or about the 5th of June 2018, at 10, Canisters Street, Minna within the
Minna Judicial Division, raped Miss Rosemary Adam thereby committing the offence of rape punishable
undersection 283 of the Penal Code Law of Niger State.
Dated this _______ day of ______________ 2020
_________________
Vanilla Gold
For: Attorney General of Niger State

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CRIMINAL LITIGATION DRAFTS

ARRESTS, SEARCHES, CONSTITUTIONAL RIGHTS

4. Application for Legal Aid

5. Charge in Magistrate Court North

BAIL PENDING TRIAL

12. Application for Police Bail

TRIAL PREPARATION & EVIDENCE

14. Case Theory

JUDGMENT & SENTENCING

17. Notice & Grounds of Appeal

SUMMONS (CRIMINAL FORM 4)

IN THE MAGISTRATE COURT OF LAGOS STATE

IN THE IKEJA MAGISTERIAL DISTRICT

COMMISSIONER OF POLICE COMPLAINANT

ADEKUNLE GOLD DEFENDANT

Dated this ______ day of ________ 2020

IN THE MAGISTRATE COURT OF LAGOS STATE

IN THE IKEJA MAGISTERIAL DISTRICT

COMMISSIONER OF POLICE COMPLAINANT

ADEKUNLE GOLD DEFENDANT

WARRANT FOR ARREST OF DEFENDANT WHO HAS DISOBEYED SUMMONS

or to each and all Police Officers.

Dated this ______ day of ________ 2020

● WARRANT OF ARREST (CRIMINAL FORM 6)

IN THE MAGISTRATE COURT OF LAGOS STATE

IN THE IKEJA MAGISTERIAL DISTRICT

COMMISSIONER OF POLICE COMPLAINANT

ADEKUNLE GOLD DEFENDANT

To: Corporal XYZ,

‘D’ Divisional Police Station, Ikeja,

WARRANT FOR THE APPREHENSION OF DEFENDANT AT FIRST INSTANCE

Dated this ________ day of ___________ 2020

SEARCH WARANT [CRIMINAL FORM 7]

IN THE IKEJA MAGISTERIAL DISTRICT

COMMISSIONER OF POLICE COMPLAINANT

ADEKUNLE GOLD DEFENDANT

TO CORPORAL XYZ of Ikeja Police Station,

5, Airport Road, Ikeja

Issued at ___________ this _______ day of _____________ 2020

APPLICATION FOR LEGAL AID

14th October, 2020

5, Vicky Estate, Ikeja

APPLICATION FOR LEGAL AID

Encl: Annual Payment Slip.

A. MAGISTRATE COURT NORTH

IN THE MAGISTRATE COURT OF KADUNA STATE

IN THE KADUNA MAGISTERIAL DISTRICT

COMMISSIONER OF POLICE COMPLAINANT

AISHA GOLD ACCUSED PERSON

Dated the 14th day of October, 2020.

B. HIGH COURT NORTH

IN THE HIGH COURT OF BENUE STATE

IN THE IDOMA JUDICIAL DIVISION

THE STATE COMPLAINANT

AISHA BELLO ACCUSED PERSON

Dated the 14th day of October, 2020.

C. MAGISTRATE COURT SOUTH

IN THE MAGISTRATE COURT OF LAGOS STATE

Dated this day of __ 2020

Dated this day of __ 2020

Dated this day of ___ 2020

Issued at _______ this _ day of ___________ 2020

Dated this _ day of ___ 2020.

Dated this _ day of ___ 2020.

Dated this _ day of ___ 2020.