IN THE FEDERAL HIGH COURT

IN THE ABUJA JUDICIAL DIVISION

HOLDEN AT ABUJA

SUIT NO: FHC/ABJ/CS/190/2024.

IN THE MATTER OF APPLICATION FOR ENFORCEMENT OF

FUNDAMENTAL RIGHTS (ENFORCEMENT PROCEDURE) RULES
2009

BETWEEN
CHINEDU NWOSU - APPLICANT
AND
1. Economic and Financial Crimes Commission
{EFCC}
2. C.S.P Fola Financial Crimes Commission
{EFCC}

RESPONDENTS
3. The Inspector General of Police
4. A.I.G Garba Baba Umar,
The Head, NCB{INTERPOL},
Force Headquater, Abuja
5. CSP Jolugbo Moses
6. Supol Peter I.G.P Special Tactical Squad
7. Hui Fang Hung.
APPLICANTS FURTHER AFFIDAVIT IN RESPONSE TO THE 7 TH
RESPONDENT’S COUNTER AFFIDAVIT IN OPPOSITION TO THE
APPLICANT’S ORIGINATING MOTION DATED THE 16TH DAY OF
OCTOBER, 2024.
l, Mr. Salihu Omeiza, Adult, Male, Muslim, and Nigerian citizen of no 988
Edwin-Ezeoke street, Wuye, Abuja, FCT do hereby make oath and state
as follows:
1. That I am a litigation secretary in the Law Firm of Messrs
Greenfield Chambers of counsel to the Applicant herein and by
virtue of which I am conversant with the facts deposed herein.

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
 2. That I have the authority of the applicant and the consent of my
principal to depose to the facts contained herein.
3. That the Applicant has chosen to remain in an undisclosed
location, avoiding public appearances, to ensure his safety until
these matters are resolved in court.
4. That the Applicant informed me during the said telephone
conversation that he has read the counter-affidavit filed by the 7th
Respondent on the 16th of October, 2024, and has directed me to
respond to its contents as follows:
5. That in response to paragraph 11 of the 7th Respondent's counter-
affidavit, the Applicant categorically denies the baseless allegation
that he or anyone acting on his behalf has distorted facts to
mislead the court. The facts deposed to in the Applicant's affidavit
are true, accurate, and based on verifiable evidence, which has
already been presented before this Honourable Court.
6. That he further denies paragraph 12 and 13 of the 7 th respondent’s
counter affidavit, reaffirming that the 1 st to 6th respondents have no
jurisdiction to involve themselves in what is clearly a civil matter.
The Respondents acted outside their statutory mandate in
arresting and detaining the Applicant, thereby violating his
constitutionally granted rights as a citizen of this Country,
specifically his right to liberty, right to dignity of human person,
right to life, etc.
7. That the applicant denies paragraph 14 and put the 7 th respondent
to the strictest proof.
8. That the averments in paragraph 18,19 and 20 does not accurately
reflect the true facts of the events. In response to Paragraph 19 of
the 7th Respondent’s Counter Affidavit, particularly where the
Respondent alleges that the applicant failed to remit proceeds
from the sale of goods supplied; While I admit that there were
business transactions between the 7th Respondent and myself, I
deny the assertion that I deliberately withheld proceeds from the
sales of goods.
9. That furtherance to paragraph 8 above, It is important to note that
any misunderstanding referenced by the 7th respondent was not
due to any fraudulent activity or misconduct on my part. It arose
APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S
COUNER-AFFIDAVIT
 from genuine business transactions that faced complications
beyond the applicants control, which were common in the line of
business ventured into by both parties and by extension, in the
course of our dealings.
10. That the 7th Respondent, instead of resolving the matter
through appropriate civil means, resorted to using law enforcement
agencies (1st to 6th Respondents) to apply undue pressure,
turning a contractual business dispute into a criminal matter. This
is a clear abuse of her influence and social standing.
11. That the applicant further submit that the 7th Respondent
has exaggerated the figures and misrepresented the facts
surrounding the debt, as her intent from the beginning was to use
these debts as leverage to coerce me and damage my reputation.
12. That paragraph 23,24,and 25 of the 7th respondents counter-
affidavit are false and misleading. Contrary to the facts deposed to
by the 7th respondents, the applicants did not deliver said cheques
to the 7th respondent. The said cheques were surreptitiously
obtained from the applicant’s possessions which the 7th respondent
had seized & withheld from the applicant.
13. That the applicant is not in the position to admit or deny
averments contained in paragraph 26 as they are facts solely
within the knowledge of the 7th respondent.
14. That the applicant admits paragraph 27 only to the extent
that he was admitted on bail on the 8th of August, 2017.
15. That Contrary to the assertions made in paragraph 28 of the
7th respondent's counter-affidavit, the applicant's statement was
not recorded in the presence of a lawyer, as required by statute.
Additionally, personal documents and title deeds were unlawfully
removed from the applicant's possession.
16. That Contrary to the assertions made in paragraph 29 of the
7th respondent's counter-affidavit, it is evident that upon the
conclusion of the investigation, the 1st and 2nd respondents
determined that the petition was without merit and granted the
applicant administrative bail. This is substantiated by Exhibit E at
paragraph 21 of the affidavit in support of the originating motion.
Moreover, the allegation that the applicant jumped bail is baseless;

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
 rather, the applicant diligently reported to the offices of the 1st and
2nd respondents at regular intervals as a condition of his bail for a
continuous period of at least six months.
17. That Contrary to the allegations stated in paragraph 30 and
31, and consistent with paragraph 16 above, the investigations
were not abandoned. Rather, the applicant was granted
administrative bail. Furthermore, in violation of his constitutional
right to liberty, the applicant was not charged to court, as there
was no reasonable basis for the 1st and 2nd defendants to initiate
prosecution for matters that only constitute civil liability.
18. That inclusion of legal grounds in paragraph 32 of the
affidavit by the 7th respondent is unwarranted and should be
omitted, as it does not pertain to the factual matters at hand.

19. That he applicant denies paragraph 33 as the accusations

are baseless and hereby put the 7th respondent to the strictest
proof.
20. That the assertions contained in paragraph 34 are not only
misleading but also appear to be intentionally calculated to mislead
this honorable court.
21. The applicant admits to the assertions only to the extent that
he has reason to believe that the 7th respondent intends to cause
him harm. This inference is reasonably drawn from the conduct of
the respondent.
22. The averments contained in paragraph 35 are false,
misleading, and aimed at misrepresenting the true circumstances
surrounding the matter before this honourable court. The applicant
never willingly handed over his business briefcase, rather, the 7th
respondent took it under the guise of helping him to reduce the
weight of the applicant’s personal luggage and adding it to the
container carrying the goods, with intent to unlawfully deprive the
applicant of his business records as well as to perpetrate her evil
intentions.
23. That paragraph 32 & 37 of the 7th respondent’s counter-
affidavit are irrelevant, clearly containing legal argument which has
no business in an affidavit and therefore should be
discountenanced.

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
 24. That contrary to the claims of the 7th Respondent in
paragraphs 38, 40, 41, and 43, the 7th Respondent did in-fact
utilize the 1st to 6th Respondents for her own personal vendetta
against the Applicant. This constitutes an abuse of power, as the
7th Respondent has employed state resources and the authority of
the aforementioned Respondents to pursue a private grievance
rather than addressing her grievances, which are clearly civil in
nature, having arose from contract in an appropriate court.

25. That the 7th respondent clearly admits to being Taiwanese,

not a Nigerian citizen and therefore cannot invoke the Nigerian
constitution as it does not apply to her.
26. The applicant admits paragraph 42 only to the extent that he
was eventually granted bail. However, he further asserts that this
does not remove or mitigate the fact that his rights were repeatedly
breached by officers of the 1st - 6th respondents who clearly acted
ultra-vires their legally given powers by letting themselves be used
as agents of intimidation and show of social status.
27. That it would be in the interest of justice for this Honourable
Court to discountenance the content of the 7 th respondent’s
counter-affidavit as they are false and calculated to distort the facts
of this matter at hand.
28. That I depose to this affidavit in good faith, believing the
contents to be true and correct to the best of my knowledge and in
accordance with the Oaths Act, 2004.

____________________
Deponent

SWORN TO at the High Court Registry, Abuja.

This………………day of …………………..2024

BEFORE ME

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
COMMISSIONER FOR OATHS

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
IN THE FEDERAL HIGH COURT
IN THE ABUJA JUDICIAL DIVISION
HOLDEN AT ABUJA

SUIT NO: FHC/ABJ/CS/190/2024.

IN THE MATTER OF APPLICATION FOR ENFORCEMENT OF

FUNDAMENTAL RIGHTS (ENFORCEMENT PROCEDURE) RULES
2009

BETWEEN
CHINEDU NWOSU - APPLICANT
AND
8. Economic and Financial Crimes Commission
{EFCC}
9. C.S.P Fola Financial Crimes Commission
{EFCC}

RESPONDENTS
10. The Inspector General of Police
11. A.I.G Garba Baba Umar,
The Head, NCB{INTERPOL},
Force Headquater, Abuja
12. CSP Jolugbo Moses
13. Supol Peter I.G.P Special Tactical Squad
14. Hui Fang Hung.

APPLICANTS FURTHER AFFIDAVIT IN RESPONSE TO THE 7 TH

RESPONDENT’S COUNTER AFFIDAVIT IN OPPOSITION TO THE
APPLICANT’S ORIGINATING MOTION DATED THE 16TH DAY OF
OCTOBER, 2024.

WRITTEN ADDRESS IN SUPPORT OF APPLICANT'S FURTHER AND

BETTER COUNTER AFFIDAVIT IN OPPOSITION TO THE 7 TH
RESPONDENT'S COUNTER-AFFIDAVIT DATED THE 16 TH DAY OF
OCTOBER, 2024.
APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S
COUNER-AFFIDAVIT
1.0 INTRODUCTION

1.1 Upon the receipt of the Respondent’s Further Counter-

Affidavit and accompanying written address, the Applicant
has filed its Further and better Affidavit, and this Written
Address in reply to the issues raised by the 7th Respondent
therein.

1.2 This Written Address encapsulates the arguments of counsel

to the Applicant and we shall adopt same as our response to
the points canvassed by the 7th respondent’s .

2.0 ISSUES FOR DETERMINATION

The Applicant has formulated four issues for determination as

follows:
ISSUE 1:
“Whether the Applicant has discharged the burden of proof
as required by law?”

ISSUE 2:
“Whether the applicant is entitled to the reliefs sought based
on the facts and the law?”

ISSUE 3:
“Whether the 7th respondent has discharged the burden of
proving fraud beyond reasonable doubt?”

ISSUE 4:
“Whether the action of the 7th respondent in instigating the 1st –
6th respondent to act ultra-vires, thereby occasioning the
violation of the applicant’s rights is not a violation of the
applicant’s Fundamental Human Rights.

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
 ISSUE 5:
"Whether the Applicant is entitled to damages and other reliefs
for the violation of his fundamental rights arising from the
unlawful detention and harassment by the Respondents."

3.0 LEGAL ARGUMENT

ISSUE 1

Whether the Applicant has discharged the burden of proof as

required by law?

3.1 Legal Argument

The burden of proof in civil matters rests on the party who asserts the
existence of a fact. Section 131(1) of the Evidence Act 2011 explicitly
provides that the party who seeks the court's judgment in his favor bears
the responsibility to prove his assertions. In cases of fundamental rights
enforcement, the applicant must prove the violation of his rights as
guaranteed under Chapter IV of the 1999 Constitution (as amended).

3.2 The Applicant, in his affidavit and further affidavit, has deposed to
facts illustrating the unlawful actions of the Respondents, particularly the
7th Respondent, in orchestrating the use of state apparatus to threaten
and unlawfully detain him, which resulted in relentless and continuous
breach of the applicant’, fundamental human right. The 7 th respondent in
her counter-affidavit corroborated same by admitting that these
harassments and arrests were done upon her instigations by way of
petition.

3.3 My Lord, the Applicant’s name has been unjustly tarnished, with his
reputation irreparably damaged by the baseless and defamatory actions
of the Respondents, particularly the 7th Respondent, whose actions
have cast a shadow over the Applicant's integrity in both his personal
and professional endeavors. As a direct consequence, the Applicant has

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
suffered significant financial losses, including the severance of critical
business relationships, which has ultimately led to bankruptcy.

3.4 In addition, the Applicant was unlawfully detained by the 1st to 6th
Respondents for an extended period of 71 days, and again for another
21 days between the 8th of August to the 29th of August, 2017, without
any justifiable cause. The Applicant has remained a diligent and law-
abiding citizen throughout this ordeal. He visited the offices of the 1st to
6th Respondents on approximately 47 occasions, seeking updates on
the status of his case, yet no progress was ever communicated to him,
nor was he charged to court. This, despite his constant cooperation,
underscores the Respondents' malicious intent to frustrate and harass
the Applicant without just cause

3.6 The Applicant has clearly deposed to these facts sufficiently and
have provided cogent evidence to substantiate his claims of the violation
of his fundamental rights as enshrined in Sections 34, 35, and 36 of the
Constitution of the Federal Republic of Nigeria, 1999 (as amended),
thereby discharging the burden of proof required under the law. In
accordance with Section 136 of the Evidence Act 2011, the burden of
proof shifts once the Applicant has discharged this burden, and it is now
upon the Respondents to rebut the Applicant's claims, a burden they
have not adequately discharged.

We also refer to the case of Fajemirokun v. Commercial Bank Nig.

Ltd (2009) 21 NWLR (Pt. 1170) 383, where the Court held that once the
burden of proof is shifted, the opposing party must provide cogent
evidence to rebut the claim, failing which judgment will be entered in
favor of the claimant.

3.7 The Applicant has tendered cogent evidence, which the

Respondents have failed to rebut in any substantial way. It is our
respectful submission that the Applicant has discharged the burden of
proof required by law, and the Respondents have failed to provide any
justification for their actions.

ISSUE 2
Whether the Applicant is entitled to the reliefs sought based on the
facts and the law?

4.1 Legal Argument

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S
COUNER-AFFIDAVIT
It is trite law that where a party has established that his fundamental
rights have been violated, he is entitled to the reliefs sought. Section
46(1) of the Constitution of the Federal Republic of Nigeria, 1999 (as
amended), provides that any person who alleges that any of the
provisions of Chapter IV has been, is being, or is likely to be
contravened may apply to the High Court for redress.
4.2 The reliefs sought by the Applicant in this case include declarations
of unlawful arrest, harassment, and a violation of his right to personal
liberty under Section 35 and his right to dignity under Section 34 of the
Constitution. The law is unequivocal that once these rights are
established to have been violated, the court must grant appropriate
reliefs.
In Anachebe v. Ijeoma (2014) 14 NWLR (Pt. 1426) 168, the court held
that damages and injunctive reliefs are appropriate remedies where a
party’s fundamental rights have been violated.
4.3 Furthermore, the ultra vires actions of the 1st to 6th Respondents, at
the instigation of the 7th Respondent, clearly exceed their lawful
mandate under the law.
In EFCC v. Diamond Bank Plc & Anor. (2018) LPELR-44227(CA),
Justice Eko, JCA (as he then was), stated in his ruling:
"It is not the function of law enforcement agencies such as the EFCC to
intervene in disputes of a civil nature or to act as debt collectors. Their
statutory powers are circumscribed within the investigation and
prosecution of economic and financial crimes. To use them outside of
this statutory purpose is an abuse of power."
It is settled law that any action undertaken without legal authority is void.
This Honourable Court is urged to declare such actions null and void as
they are in clear breach of the Applicant’s constitutional rights.
4.4 We submit that the foregoing assertions and the infractions by the
Respondents have been well established through credible evidence and
judicial precedents. Therefore, this Honourable Court should grant the
reliefs sought by the Applicant.

ISSUE 3:

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
 “Whether the 7th respondent has discharged the burden of
proving fraud beyond reasonable doubt?”
5.1 Legal Argument
It is a settled principle under Nigerian law that allegations of fraud must
be proved beyond reasonable doubt. Section 135(1) of the Evidence Act
2011 states that in any proceeding where a party asserts the
commission of a crime, such a fact must be proved beyond reasonable
doubt.
5.2 In Omisore v. Aregbesola (2015) 15 NWLR (Pt. 1482) 205 at 295,
the Supreme Court held that fraud, being a criminal offense, requires a
higher standard of proof than mere civil allegations. The party alleging
fraud must provide credible and compelling evidence to substantiate the
claim.
5.3 The 7th Respondent, in her counter-affidavit, made grave allegations
of fraud against the Applicant but have miserably failed to adduce
sufficient evidence to support same. It is our firm contention that the 7th
Respondent has made these claims of fraud in a calculated attempt to
mislead the Court and divert attention away from her own wrongdoing.
5.4 In the absence of credible evidence, the 7th Respondent’s
allegations of fraud amount to mere conjecture, and it is trite law that
conjecture has no place in judicial proceedings. We urge this
Honourable Court to reject the 7th Respondent's unproven allegations.
5.5 We submit that the 7th Respondent has woefully failed to discharge
the burden of proving fraud beyond reasonable doubt, as required by
law. Accordingly, his claims of fraud must be dismissed in their entirety.

ISSUE 4
Whether the action of the 7th Respondent in instigating the 1st –
6th Respondents to act ultra vires, thereby occasioning the
violation of the Applicant’s rights, is not a violation of the
Applicant’s Fundamental Human Rights?

6.1 Legal Arguement

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
It is trite law that the actions of public authorities must be within the
confines of the law. When such actions exceed the scope of their legal
authority, they are deemed ultra vires and illegal. In the instant case, the
7th Respondent, a private individual, instigated the 1st to 6th
Respondents, who are public authorities, to act outside their legal
mandate, resulting in the unlawful arrest and harassment of the
Applicant.
6.2 Section 35 of the Constitution guarantees the right to personal
liberty, and any arrest or detention must comply strictly with the law. The
unlawful actions of the 1st to 6th Respondents, instigated by the 7th
Respondent, have clearly violated this constitutional right.

6.3 In Okojie v. Attorney General of Lagos State (2020) LPELR-

51299(CA), the Court of Appeal held that where public authorities act
outside their statutory mandate, such actions are ultra vires and
unconstitutional. The Applicant’s right to liberty and dignity has been
infringed upon as a result of such illegal conduct by the Respondents.
6.4 Furthermore, the 7th Respondent's use of the state apparatus to
settle a personal grievance is a clear abuse of power and a violation of
the Applicant's fundamental rights. We submit that the actions of the
Respondents, particularly the 7th Respondent, amount to a gross
violation of the Applicant’s fundamental human rights.
6.5 We further submit that the ultra vires actions of the Respondents,
occasioned by the unlawful instigation of the 7th Respondent, amount to
a breach of the Applicant's fundamental rights. This Honourable Court is
urged to so hold and grant the reliefs sought.

ISSUE 5:
"Whether the Applicant is entitled to damages and other reliefs for
the violation of his fundamental rights arising from the unlawful
detention and harassment by the Respondents."
Legal Argument:

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
6.1 Section 35(6) of the 1999 Constitution (as amended) provides that
any person who is unlawfully arrested or detained is entitled to
compensation and public apology from the appropriate authority. The
Applicant has shown through cogent evidence that he was unlawfully
detained by the 1st to 6th Respondents at the instance of the 7th
Respondent, first for 71 days, and later for another 21 days, without
being charged to court, thereby violating his fundamental right to
personal liberty.
6.2 The Applicant has also deposed that he suffered emotional distress,
insomnia, and psychological trauma due to the constant harassment by
the Respondents, further intensified by the fact that the detentions were
baseless and driven by a personal vendetta rather than any legitimate
legal grounds. This Honourable Court is urged to recognize that the
prolonged and unjust detentions, as well as the use of law enforcement
agencies to settle private scores, constitute violations of the Applicant's
rights under Section 34(1) of the Constitution (the right to dignity of the
human person).
6.3 In Ojo v. Economic and Financial Crimes Commission (EFCC)
(2017) LPELR-42763(CA), it was reiterated that law enforcement
agencies must exercise their powers within the confines of the law, and
any detention without sufficient legal grounds is unlawful.
6.4 In this case, the Applicant has not only been deprived of his liberty
but has also suffered damage to his reputation and business, as he has
been unable to continue his usual activities due to the harassment and
detentions. As a matter of fact, the applicant have had to go into hiding
because of the level of threats and fear for his life. My Lord, nobody
deserves to live in perpetual fear, wondering if he would be able to live to
see another day or come back to his family, much less a Nigeria citizen
who is protected by the law, the constitution. The failure of the
Respondents to provide any justifiable reason for the detentions,
coupled with the 7th Respondent’s personal motive of using the 1st to
6th Respondents as instruments of intimidation, warrants the award of
damages.
6.5 We submit that the Applicant is entitled to compensatory damages,
as have been established by the above arguments.

7.0 CONCLUSION
APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S
COUNER-AFFIDAVIT
 7.1 In conclusion, we respectfully submit that the Applicant has
discharged the burden of proof required by law in showing
that his fundamental rights have been violated. The 7th
Respondent has failed to substantiate his allegations of
fraud, and the actions of the 1st to 6th Respondents,
instigated by the 7th Respondent, were clearly ultra vires.
We, therefore, urge this Honourable Court to grant the reliefs
sought by the Applicant, including damages, injunctions, and
any other reliefs deemed appropriate.

7.2 My Lord, we further submit that the Defendant/Applicant has

failed woefully to furnish this Honourable Court with sufficient
material upon which this application should be granted.

7.3 It is line with this that we respectfully urge this Honourable

Count to discountenance the application and arguments of
the 7th respondent herein and strike out this application.

7.4 We are most obliged.

Dated this 23rd day of October, 2024

________________________________
AGADA ELACHI, SAN, Ph.D.
CHIEF EMEKA OBEGOLU, SAN, Ph.D.
ONYINYE PRINCESS JAMES, ESQ.
GRACE ORAHACHI EHUSANI, ESQ.
LUCIA NGOZI ANYANOR, ESQ.
VINCENT O. OKOEDION, ESQ.
CHINONSO CHRISTIAN OSUMUNE, ESQ.
LOYIBO GOODLUCK, ESQ.
B. O. AYINDE, ESQ.
C.J AGU ESQ.
ANGEL OBI-NWOSU ESQ.
C.M NWATU, ESQ.
(COUNSEL TO THE 1ST RESPONDENT)

APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT
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OFF AMEH EBUTE STREET,
WUYE DISTRICT, FCT- ABUJA.
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APPLICANT’S FURTHER AND BETTER AFFIDAVIT IN RESPONSE TO THE 7TH RESPONDENT’S

COUNER-AFFIDAVIT