4.04 4.05 4.06 4.07 Mr. Tel: Oe. In the case of BUWANHOT V. BUWANHOT (2009) 16 NWLR (PT. 116) 22 CA the _court held that the welfare of the children of the marriage in terms of their peace of mind, happiness, education and co-existence, is the prime consideration in granting custody. My lord, the Applicant has deposed to the affidavit that she is the mother of the ‘Whdren of the marriage and capable mentally and psychologically of talking care of ceeenildren. The Respondent by his long absence and lack of care for the children te ne tke cece ne ime chuldre, But U neo) tat Get pideted (15) respondent be responsible and responsive to welfare of the children pase on the Teenomie factors which increased and the Applicant cannot continue to bear all alone. Further to this, the Respondent under Alternative Dispute Resolution (ADR) prayed, promised and undertakes to be responsible and responsive for the Child Preiare ks shown in Exhibits A&B. Afterward , the Respondent deliberately neglect the Children and he has shown no interest concerning the welfare of the children which is the paramount consideration for grant of custody We therefore urge the court to hold true that taking into consideration, the interest und welfare of the child as well as the conduct of the Respondent it is necessary that the Respondent be ordered to take fully responsibility of the Child in order that the Child may become an upright Citizen of this nation. \ We again. therefore urge this Honourable Court on the strength of the arguments We aeeeed herein to grant the Applicant the custody of the child. while, tie Respondent has. unrestricted~access. 17) him. and alse to grant all other-relicfs” sought in the statement accompanying this application as such grant shall be in the interest of justice of this case. F.A OGUNSEINDE ESQ..,, ADEMOLA FAKOYA ESQ,. 1.0 ADEYEMO ESQ., OLAYIWOLA BASHORUN ESQ.» OFFICE OF THE PUBLIC DEFENDANT CITIZEN RIGHT DEPARTMENT MINISTRY OF JUSTICE OPPOSITE NTA, ERUNWON ROAD, i IJEBU ODE OGUN STATE 0915 1786632 FOR SERVICE ON: Temitope Suliaman No.1, Igara Street, Isiwo, Ijebu 08055107994