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.
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