We Don’t Want 4 Million Man Peter Obi Rally in Lagos, Tinubu’s BATmen Sue OBIdients

We Don’t Want 4 Million Man Peter Obi Rally in Lagos, Tinubu‘s BATmen Sue OBIdients

See files documents below

BETWEEN IN THE FEDERAL HIGH COURT OF NIGERIA IN THE LAGOS JUDICIAL DIVISION HOLDEN ATLAGOS SUIT NO 1) ADEDOTUN AJULO ESQ 21 SALAMATU SULEIMAN LEWI ESQ 3) HAKEEM HADUOLA, ESQ. OGUNBONA AKINPELI ESQ S OWOLABIK OLUWASEGUN , ESQ . MOGBOJURI KAYODE ESQ. 6 7 WUYEP MANTIN NADOM ESO DIMIMU MABEL ESQ ” KOLAWOLE SALAMI, ESQ. 14 ) WALEAHELAWRENCE AND 11 PETER GREGORY CO 2 ) LABOR PARTY 3 ) YUSUF DATTI BABA – AHMED 4 ) JULIUS ABURE , ESQ 5 ) INSPECTOR GENERAL OF POLICE 6 ) COMMISSIONER OF POLICE ( LAGOS STATE COMMAND ) 7 ) DIRECTOR GENERAL DEPARTMENT OF ITATE SERVICES ) LENKI CONCESSION COMPANY LIMITED ATTORNEY GENERAL OF LAGOS STATE 10 THE GOVERNOR OF LAGOS STATE * HC / 4 / 25 / 1729 / 2012 PLAINTIFIS DEFENDANTS ORIGINATING SUMMONS HROUGHT PURSUANT TO SECTION 60L ) OF CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA 1999 (AS AMENDED) SECTION OF THE POLICE ACT. 2020, SECTION (1) OF THE NATIONAL SECURITY AGENCIES ACT. CAP N74 SECTION 103) OF THE TERRORISM (PREVENTION AND PROHIBITION) ACT, 2322, ORDER 3, RULE & OF THE FEDERAL HIGH COURT (CIVIL PROCEDURE) RULES 2019 AND UNDER THE INHERENT JURISDICTION OFTHIS HONOURABLE COURT LET the Defendants (1) PETER GREGORY OBI of No. 29 Okraghe Street, Off Samuel Ladake Akintola, Boule vard, Garki IL Abuja (2) LABOUR PARTY, (3) YUSUF DATTI BABA-AHMED, (4) JULIUS ABURE, ESQ, of the National Secretariat of the LABOUR PARTY of No. 29 Okeghe Street Off Samuel Ladoke Akintola, Boulevard, Carl I. Abuja (5) INSPECTOR GENERAL OF FOLICE of the Nigetan Police Force Feadquarters Louis Rilet House Shehu Shagart Way, Ares 1 Garkt Abuja (5) COMMISSIONER OF POLICE (LAGOS STATE COMMAND) of State Command Headquarters 1 Oduduws Street, Ikeja, Lagos State (7) DIRECTOR GENERAL (DEPARTMENT OF STATE SERVICES) No. 1 Maitama Avenue, Three Arms Zone Abuja (8) LEKKI CONSESSION COMPANY LIMITED of Conservation Plaza Kilometer 136 E-Ou Lekks-Epe Expressway, Lagos (9) ATTORNEY GENERAL OF LAGOS STATE of Ministry of Justice comples, Alena Jecrearat Lagos (10) THE GOVERNOR OF LAGOS STATE of Governor’s Office Alsa within thirty (10) days after service of this summons on you indssive of the day of such service, cause appearance to be entered for you to this summons which is issued upon the application of the Plaintiffs c/ o their Counsel Romeo Ee – Michael , E of 13 , Soji Adepegha Close Off Alles Avenue , Ikeja , Lagos State , Nigeria within the jurisdiction of this Honorable Court was claims for the determination of the following questions and the grant of the following lis QUESTIONS : 1) Whether having regard to the true construction and intent of Section 40 of the Constitution of the Federal Republic of Nigeria 1999 (as amended), and the resultant effect of the END SARS Protest of 2 020 to destruction of lives and property, the 1, 2, 3 and 4 Defendants can hide under the guise of Right to peaceful assembly to endorse the Scheduled END SARS Anniversary Protest, tally tagged wobidatti23 Forward Ever Rally “being organized by their agents, privies , assigns , members or associates or howsoever described to come up on the 1 ” of October , 2022 2 ) Whether the 1,2,3 and 4 Defendants are under Statutory obligations citizens of the Federal Republic of Nigeria in view of Section 24 of the Constitution of the Federal Republic of Nigeria 1999 (as amassed) to exercise caution, restraint on their allies, privies, assigns, members and associates or Nowsoever described so as not to carry out the END SARS Anniversary, Protest, Rally tagged ” # Obidatti23 Forward Ever Rally “being scheduled to come up on the 1af October, 2022 in order not to instigate crisis in violation K

me apsina , peras , assignmers or associates or howsoever described to come up in the 1 of October , 2022 23 Whether the 1,2,3 and 4 Defendints are under Statutory obligations as citizens of the Federal Republic of Nigeria in view of Section 24 of the Constitution of the Federal Republic of Nigeria 1999 ( as ameaded ) to exercise caution , restraint on their allies , previes , assigns , members and associates nowsoever described so as not to carry out the END SARS Anniversary , Protest Rally tagged ” wibidatti23 Forward fiver Rally being scheduled to come up on the of October , 2022 in order not to instigate crisis in violation come up on the 1 of October , 2022 in order not to instigate crisis in violation of Section 45 ( 1 ) of the Constitution of the Federal Republic of Nigeria 1999 3. A DECLARATION OF THIS HONORABLE COURT that , hasing regard to the dear intent of the relevant provisions of the cybercrimes Act , 2015 , the 14 23 and 4 Delendants , whether acting through their allie s , assigns privies , agents , asociates and any person whatsoever , cannot subject the Plaintiffs to cyber – harassment , humiliation and intimidation for expressing their opinion as to the candidate of their choice having regard to their entitutional rights as provided for in Section 38 of the Constitution of the Federal Republic of Nigeria 1999 ( as amended ) 4. A DECLARATION OF THIS HONORABLE COURT that the scheduled END SARS anniversary protest / rally tagged ” # Ohidatti23 Forvand Ever Rally being organized by the 1 , 2 , 3 and 4 Defendants or their agents and associates runs is clear collision with the unequivocal relevant provisions of Terrarium ( Prevention and Prohibition ) Act , 2022 . SA DECLARATION OF THIS HONORABLE COURT that having regard to the Statutory requirements as enshrined 11 Section 45 of the Constitution of the Federal Republic of Nigeria 1999 ( ai amended ) , the 1 , 2 , 3 and 4 Defendants are under legal obligation to forthwith hat organizing or disassociate themselves from the argarisers of the END SARS Protest to come up on the 1 of Otaber , 2022 as well as to issue public statements to halt the said protest as almady scheduled for the interest of public salty and order . 6. A DECLARATION OF THIS HONORABLE COURT that the Defendant is under legal duty having regard to Section 15 of the Constitution of the Federal Republic of Nigeria 1999 ( as amended ) and the relevant provisions of the Companies and Allied Matters Act setting out its corporate functions , to not open its space at the Lekki Toll Gate for the purposes of aiding and allowing the 1 , 2 , 3 and 4 Defendants as well as their agents , privies , assigst , allies and servants , the organizers of the END SARS anniversary protest / rally tagend ” WOhidari23 Forward Ever Rally to anemble on the 1 of October , 2022 for the purpose of celebrating the END SAS Protest Anniversary 7. A DECLARATION OF THIS HONORABLE COURT that , having regard to Section 5 ( 2 ) , the first Schedule as wel as Section of the Constitution of the 8 ) Whether the 9 and 10 Defendants are under constitutional duties to disallow the 1 , 2 , 3 and 4 Defendants from using the Lekki Toll Gate sited within their territorial boundary of Lagos State to conduct the END SARS anniversary protest / rally tagged ” # Obidatti23 Forward Ever Rally ” on the 1 of October , 2022 . 3 ) Whether having regard to the Statutory Establishments Act and the relevant provisions of the Constitution of the Federal Republic of Nigeria 1999 ( as amended ) , the 5 , 6 and 7 Defendasts are under legal duies to protect and preserve lives and properties and in this regard by not allowing the 1 , 2 and 4 Defendants , as well as their agents , privies and associates from carrying out the scheduled END SARS anniversary protest / rally tagged Ohidan Fonwand Ever Rally on the 1 of October 2022 . 10 ) Whether this Hoserable Court can exercise its judicial powers as spelt out in Section 6 of the Constitution of the Federal Republic of Nigeria 1999 ( as amended ) to injunct or mandate the Defendants to preserve lives and properties and in this regard by preventing the 15 , 2 , 3 and 4 Defendants as well as their agents assigns , privirs , allies , members and servants of the from carrying out the scheduled END SARS anniversary protest / rally tagged ” Robidami23 Fend Ever Rally IN THE EVENT THAT the above questions ace in the positive , the plaintiffs seek the following relief K

me apsina , peras , assignmers or associates or howsoever described to come up in the 1 of October , 2022 23 Whether the 1,2,3 and 4 Defendints are under Statutory obligations as citizens of the Federal Republic of Nigeria in view of Section 24 of the Constitution of the Federal Republic of Nigeria 1999 (as ameaded) to exercise caution, restraint on their allies, previes, assigns, members and associates nowsoever described so as not to carry out the END SARS Anniversary, Protest Rally tagged “wibidatti23 Forward fiver Rally being scheduled to come up on the of October, 2022 in order not to instigate crisis in violation come up on the 1 of October, 2022 in order not to instigate crisis in violation of Section 45 (1) of the Constitution of the Federal Republic of Nigeria 1999 3. A DECLARATION OF THIS HONORABLE COURT that, having regard to the dear intent of the relevant provisions of the cybercrimes Act, 2015, the 14 23 and 4 Delendants, whether acting through their ally s, assigns privies, agents, associates and any person whatsoever, cannot subject the Plaintiffs to cyber-harassment, humiliation and intimidation for expressing their opinion as to the candidate of their choice having regard to their institutional rights as provided for in Section 38 of the Constitution of the Federal Republic of Nigeria 1999 (as amended) 4. A DECLARATION OF THIS HONORABLE COURT that the scheduled END SARS anniversary protest / rally tagged ” # Ohidatti23 Forvand Ever Rally being organized by the 1 , 2 , 3 and 4 Defendants or their agents and associates runs is clear collision with the unequivocal relevant provisions of Terrarium (Prevention and Prohibition) Act, 2022. SA DECLARATION OF THIS HONORABLE COURT that having regard to the Statutory requirements as enshrined 11 Section 45 of the Constitution of the Federal Republic of Nigeria 1999 (ai amended) , the 1 , 2 , 3 and 4 Defendants are under legal obligation to forthwith hat organizing or disassociate themselves from the argarisers of the END SARS Protest to come up on the 1 of Otaber, 2022 as well as to issue public statements to halt the said protest as almady scheduled for the interest of public safety and order. 6. A DECLARATION OF THIS HONORABLE COURT that the Defendant is under legal duty having regard to Section 15 of the Constitution of the Federal Republic of Nigeria 1999 (as amended) and the relevant provisions of the Companies and Allied Matters Act setting out its corporate functions , to not open its space at the Lekki Toll Gate for the purposes of aiding and allowing the 1 , 2 , 3 and 4 Defendants as well as their agents , privies , assigst , allies and servants , the organizers of the END SARS anniversary protest / rally tagend ” WOhidari23 Forward Ever Rally to assemble on the 1 of October , 2022 for the purpose of celebrating the END SAS Protest Anniversary 7. A DECLARATION OF THIS HONORABLE COURT that , having regard to Section 5 ( 2 ) , the first Schedule as wel as Section of the Constitution of the 8) Whether the 9 and 10 Defendants are under constitutional duties to disallow the 1, 2, 3 and 4 Defendants from using the Lekki Toll Gate sited within their territorial boundary of Lagos State to conduct the END SARS anniversary protest / rally tagged “#Obidatti23 Forward Ever Rally” on the 1 of October, 2022. 3) Whether having regard to the Statutory Establishments Act and the relevant provisions of the Constitution of the Federal Republic of Nigeria 1999 (as amended), the 5, 6 and 7 Defendants are under legal duties to protect and preserve lives and properties and in this regard by not allowing the 1, 2 and 4 Defendants, as well as their agents, privies and associates from carrying out the scheduled END SARS anniversary protest / rally tagged Ohidan Fonwand Ever Rally on the 1 of October 2022. 10) Whether this Hoserable Court can exercise its judicial powers as spelled out in Section 6 of the Constitution of the Federal Republic of Nigeria 1999 (as amended) to injunct or mandate the Defendants to preserve lives and properties and in this regard by preventing the 15 , 2 , 3 and 4 Defendants as well as their agents assigns , privirs , allies , members and servants of the from carrying out the scheduled END SARS anniversary protest / rally tagged ” Robidami23 Fend Ever Rally IN THE EVENT THAT the above questions ace in the positive, the plaintiffs seek the following relief K

IN THE EVENT THAT the above questions are in the positive , the Plaintiffs seek the following relief 1. A DECLARATION OF THIS HONORABLE COURT that having regard to the true construction and intent of Section 40 of the Constitution of the Federal Republic of Nigeria 1999 ( as amendef ) , and the resultant effect of the END SARS Prinesti 2020 so destruction of lives and property , the 1 , 2 , and 4 Defendants cannot hide under the guise of Right to peaceful assembly endirse the Scheduled END SARS Anniversary , Protest Rally tagged Obidatti23 forsed Kere Bally being organised by the agents privies asigns or associates to come up in the 1 of October , 2022 . 2. A DECLARATION OF THIS HONORABLE COURT that the 1 , 2 , 3 and 4 Defendants are under Statutory obligacions as citizens of the Federal Republic at Nigeria in view of Section 24 of the Constitution of the Federal Republic of Nigeria 1999 ( as amended ) to evertise caution , restralee on their alles privies , assigns and associates not be carry out the END SARS Anniversary . Protest , Rally tagged ” # dbidatti23 Forward Ever Rally being organised to of Section 45 ( 1 ) of the Constitution of the Federal Republic of Nigeria 1999 ( as amended ) 3 ) Whether having regard to the clear istent of the relevant provisions of the Cybercrimes Act 2015 , the 15 , 2 , 3 and 4 Defendants whether acting through their alies , assigns , proves agents , associates and any person whatsoever callet , can subject the Plantiffs to cyber – harassment , humiliation and intimidation for expressing their opinion as to the candidate of their chele having regard to their constitutional rights as provided for in Section 38 of the Constitution of the Federal Republic of Nigeria 1997 ( as amended ) 4 ) Whether the scheduled END SARS anniversary protest / rally tagged ” Obidatti23 Ferwand Ever Rally being organized by the 1 , 2 , 3 and 4 Defendants or their allies , privies , assigns , agents , members , and associates or howsoever described runs in clear collision with the unequivocal relevant provisions of Temoriam ( Prevention and Prohibition ) Act , 2022 5 ) Whether having regard to the Statutory requirements as enshrined in Section 45 of the Constitution of the Federal Republic of Nigeria 1999 ( as amended ) . the 1 , 2 , 3 and 4 Defendants are ander legal obligatior to forthwith halt the gaining or disassociate themselves from the organizers of the END SARS Protest scheduled to come up in the 1 of October 2022 as well as issuing public statements to halt the said protest as already scheduled for the interest of public safety and order . 6 ) Whether the Defendant is under legal duty , having regard to Section 45 of the Constitution of the Federal Republic of Nigeria 1999 ( as amended ) and the relevant provisions of the Companies and Allied Matters Act setting out its separate functions , to open its spare st the Lakh Tall Gate for the purposes of aiding and allowing the agents , prinies , assigns , allies and servants of the 1 , 2 , 3 and 4 Defendants as well as the organisers of the END SARS anniversary prest / rally tagged ” Obidatti23 Forward Ever Rally to assemble on the 1 of October , 2022 for the purpose of celebrating the END SARS Protest Anniversary . 7 ) Whether having tegard to Section 52 the First Schedule as well as Section of the Constitution of the Federal Republic of Nigeria 1999 las amended ) , the 9 and 10 Deferdants are under concitutional duty to ensure the protection and preservation of lives and properties within their territorial jurisdiction 1. That I am the 1 Plaintiff in this suit and by virtu e of which I an enversant with the facts hereinafter deposed to and I have the consent of the other Plaintiffs in this suit to depose to this Affidavit 2. That the facts hereafter deposed to are facts within my personal knowledge unless otherwise stated 3. That In the 24,345 , 49 , 59 , 69 , 74 , 04 , 9 and 10 Plaintifs who are equally Legal Practitioners resides and carry out their legitimate business within Lagos state 4. That I and the other Plaintiffs commute on daily basis within the metropolis of Lague State particularly within the enviders of Lebb lej 5. That time in October 2020 , and the other Plaintiffs as well as members of the general public within my environs were inhibited and / or restrained from K

CONECTAN WIRE the facts hereafter deposed to and I have the consent of the other Plaintiffs in this suit to depose to this Affidavit. 2. That the facts hereafter deposed to are facts within my personal knowledge unless otherwise stated. 3. That I know the 24,344 , 5 , 6 , 7 , 8 , 9 , and 10 Plaintiffs who are equally Legal Practitioners resides and carry out their legitimate business within Lagos state 4. That I and the other Plaintiffs commute on a daily basis within the metropolis of Lagos State particularly within the corridors f 5 That sometime in October 2020, 1 and the other Plaintiffs as well as members of the general public within my surroundings were inhibited and / or restrained from carrying out our lawful and legitimate businesses by the activities of the protesters who blocked the express read particularly the Lekki Toll Gate corridor under the guise of END SARS prutest of 2020 and this caused heavy gridlocks. 6. That I know the END SARS protest of 2320 which lasted for over two weeks adversely affected me and the other Plaintiffs as well as members of the public’s right to movement and also prevented us from going about with our legitimate businesses. 7. That I know by virtue of the activities of the last END SARS protests I and the other Plaintiffs lost millions of Naira due to our inability to meet with our clients, attend court proceedings, meetings among others. 8. That I am aware that : the destruction / loss of lives and properties caused by the END SARS protest started on the 20 % day of October, 2020 and lasted for about ten days resulted in psychological trauma for myself and the other Plaintiffs as well as other members of the public within my environment 9. That I know the 3 Plaintiff whose place of business is located within the corridors of Lekhi and they could not open his office during and after the dispersion of the protest due to the violence, loathing and other crimes that occurred during the last END SARS protest / riot 11

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