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Full Text Of Keyamo’s Suit

IN THE FEDERAL HIGH COURT OF NIGERIA
HOLDEN AT LAGOS

SUIT NO: FHC/L/CS/921/2013

IN THE MATTER OF AN APPLICATION FOR  JUDICIAL REVIEW  BY FESTUS KEYAMO FOR AN ORDER OF MANDAMUS

BETWEEN:

FESTUS KEYAMO      …….  APPLICANT

AND

WEST AFRICAN EXAMINATIONS COUNCIL  ……..  RESPONDENT

MOTION EXPARTE
BROUGHT UNDER:

1.  ORDER 34 RULE 1 (1)(a) AND RULE 3 (1) AND (2) OF THE FEDERAL HIGH COURT (CIVIL PROCEDURE) RULES 2009
2.  SECTION 1(1) ,(2), (3) & 4 OF THE FREEDOM OF INFORMATION (FOI) ACT, 2011.
3.  UNDER THE INHERENT JURISDICTION OF THIS HONOURABLE COURT

TAKE NOTICE that this Honorable Court will be moved on …… day of ………. 2013 at the hour of 9 0’clock in the forenoon or so soon thereafter as counsel may be heard on behalf of the Applicant for the following reliefs:

1. AN ORDER granting leave to the Applicant to apply for Judicial Review for an Order of Mandamus compelling the Respondent to produce the Certified True Copy of the West African Senior School Certificate of Hope Uzodinma to the Applicant, in accordance with Section 1(1), (2), & (4) of The Freedom Of Information (FOI) Act, 2011.

2.  AND FOR SUCH FURTHER ORDER OR OTHER ORDERS as this Honorable Court may deem fit to make in the circumstances of this Application.

Dated this 1st day of July, 2013

FESTUS AFEIYODION, ESQ.
FESTUS KEYAMO CHAMBERS
1, FESTUS KEYAMO LANE
OFF ADEBAYO MOKUOLU STREET,
OFF GBAGADA EXPRESSWAY,
BEHIND HOTEL NEWCASTLE,
ANTHONY VILLAGE,
LAGOS STATE.
08023388080, 08033371229

IN THE FEDERAL HIGH COURT OF NIGERIA
HOLDEN AT LAGOS

SUIT NO: FHC/L/CS/921/2013

IN THE MATTER OF AN APPLICATION FOR  JUDICIAL REVIEW  BY FESTUS KEYAMO FOR AN ORDER OF MANDAMUS

BETWEEN:

FESTUS KEYAMO      …….  APPLICANT

AND

WEST AFRICAN EXAMINATIONS COUNCIL  ……..  RESPONDENT

STATEMENT PURSUANT TO ORDER 34 RULE 2 (a) OF THE FEDERAL HIGH COURT (CIVIL PROCEDURE) RULES 2009.

1.  NAMES AND DESCRIPTIONS OF THE APPLICANT

FESTUS KEYAMO.
FESTUS KEYAMO CHAMBERS
1, FESTUS KEYAMO LANE
OFF ADEBAYO MOKUOLU STREET,
OFF GBAGADA EXPRESSWAY,
BEHIND HOTEL NEWCASTLE,
ANTHONY VILLAGE,
LAGOS STATE.

2. RELIEFS SOUGHT BY THE APPLICANT

a.  AN ORDER granting leave to the Applicant to apply for Judicial Review for an Order of Mandamus compelling the Respondent to produce the Certified True Copy of the West African Senior School Certificate of Hope Uzodinma to the Applicant, in accordance with Section 1(1), (2), & (4) Of The Freedom Of Information (FOI) Act, 2011.

b.  AND FOR SUCH FURTHER ORDER OR OTHER ORDERS as this Honorable Court may deem fit to make in the circumstances of this Application.

3.  GROUNDS UPON WHICH THE RELIEFS ARE SOUGHT:

a. The Applicant pursuant to Section 4 of the Freedom of Information Act (FOI) 2011 has with a letter dated 14th May, 2013 applied to the Respondent to produce the Certified True Copy of the West African Senior School Certificate of Hope Uzodinma to the Applicant.

b.  The Respondent has ignored and/or refused to produce the Certified True Copy of the West African Senior School Certificate of Hope Uzodinma to the Applicant in accordance with Section 4 of the Freedom of Information (FOI) Act 2011.

4.  FACTS LEADING TO THIS APPLICATION:

a. The Applicant is a legal practitioner, solicitor and advocate of the Supreme Court of Nigeria, who is passionately involved in legal activities for the protection of human rights and in the fight against corruption in public places in Nigeria.

b. Hope Uzodinma, a Senator of the Federal republic of Nigeria has always claimed to be an Alumni of Mgbidi Boys High School, Imo State from where he allegedly obtained his West African Senior School Certificate in 1982.

c. The said Hope Uzodinma claimed to have graduated from the Mgbidi Boys High School, Imo State in 1982.

d. That inquiry and investigation into the names and persons that graduated in that year has revealed that Senator Hope Uzodinma was not a graduate  of the school in 1982.

c. Consequent upon the legal activities of the Applicant, there has arisen a need to verify the claims of Hope Uzodinma by the Certified True Copy of his West African Senior School Certificate.

d. The Applicant is an active legal practitioner and a senior member of Nigeria Bar Association that has resolved to fight and expose corruption in public places in Nigeria and is passionately involved in legal activities for the protection of human right.

e. By a letter dated 14th day of May, 2013 served on the Respondent on the 24th day of June, 2013  the Applicant has applied for the production of the Certified True Copy of the West African Senior School Certificate of Senator Hope Uzodinma. Attached a marked exhibit “A” is the acknowledged copy of the said letter dated 14th May, 2013.

f. On the 1st day of July, 2013 at 10.00am Festus Afeiyodion, a Counsel in Chambers visited the Respondent’s office with a view of collecting the Certified True Copy of the West African Senior School Certificate of Senator Hope Uzodinma but he was left unattended to till the close of work.

g. The Respondent has ignored and/or refused to produce the Certified True Copy of the West African Senior School Certificate of Hope Uzodinma.

Dated this 1st day of July, 2013

FESTUS AFEIYODION, ESQ.
FESTUS KEYAMO CHAMBERS
1, FESTUS KEYAMO LANE
OFF ADEBAYO MOKUOLU STREET,
OFF GBAGADA EXPRESSWAY,
BEHIND HOTEL NEWCASTLE,
ANTHONY VILLAGE,
LAGOS STATE.
08023388080, 08033371229

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