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HOLDEN AT ABUJA
SUIT NO: FHC/ABJ/CS/904/2014
IN THE
MATTER OF AN APPLICATION FOR AN ORDER OF MANDAMUS BY FESTUS
KEYAMO
BETWEEN:
MR.
FESTUS KEYAMO ……………………………….…
APPLICANT
AND
1. DIRECTOR-GENERAL,
STATE SECURITY SERVICES … RESPONDENTS
2. THE INSPECTOR-GENERAL OF POLICE
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. SECTIONS 4 and 23 OF THE POLICE ACT, CAP P19
LFN, 2004.
3. UNDER THE
INHERENT JURISDICTION OF THIS HONOURABLE COURT
TAKE NOTICE that this
Honorable Court will be moved on the…… day of ………. 2014 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 the following reliefs:
a.
AN
ORDER OF MANDAMUS
compelling the 1st and 2nd
Respondents to invite for investigation one Government Ekpemupolo (alias Tompolo) over allegations of threat to kill Mr. Festus Keyamo, acts
of terror (kidnapping, torture and attempted murder) made against him by the
Applicant, Mr. Festus Keyamo and several other victims.
b.
AN ORDER OF MANDAMUS compelling the 1st and 2nd Respondents
to investigate one Government
Ekpemupolo (alias Tompolo) for the
allegations of threat to kill Mr. Festus Keyamo, acts
of terror (kidnapping, torture and attempted murder) made against him by the
Applicant, Mr. Festus Keyamo and several other victims.
c.
AN
ORDER OF MANDAMUS compelling the 1st and 2nd Respondents to make available to
the Applicant the report of their investigations into the allegations of threat to kill Mr. Festus
Keyamo, acts of terror (kidnapping, torture and attempted murder)
made against him by the Applicant, Mr. Festus Keyamo and several other victims.
2. AND FOR SUCH FURTHER ORDER(S) as this Honorable Court may deem fit to make in the circumstances of
this Application.
Dated
the 24th day of November, 2014
BALA DAKUM, ESQ.
FESTUS KEYAMO CHAMBERS,
COUNSEL TO THE APPLICANT,
13 NOUAKCHOTT STREET,
NEAR KEYSTONE BANK,
WUSE ZONE 1, ABUJA.
08033371229, 08023388080