PREPARED BY VICTORIA GEORGEWILL

IN THE DISTRICT COURT OF FCT

IN THE ABUJA MAGISTERIAL DISTRICT
HOLDEN AT ABUJA

SUIT NO:

BETWEEN
ADAMU SHAZALI………………………….CLAIMANT
AND
MAITUARE NIGERIA LIMITED…………..DEFENDANT

STATEMENT OF CLAIM

1. The Claimant is a Microsoft Trainer/Instructor

2. The Defendant is a limited liability Company with its registered address at No13 Nelson Mandela
Street Asokoro, Abuja.
3. The Claimant avers that on the 14th day of December, the claimant entered into a contract for
service with the defendant for the training of 4 (four) staffs of the defendant, on the use of Microsoft
Excel. The contract for Service dated 14th day of December 2017 is hereby pleaded and shall be relied
upon during trial.
4. The terms of contract for service between the claimant and defendant was that;

a) The training of the 4 staffs on Microsoft Excel was to be conducted for a period of 7 (seven)
weeks from Monday to Friday at the conference room of the defendants
b) The sum of one million six hundred thousand naira (N1,600,000) is the agreed contract sum
to be paid for the training of 4 (four) staffs
c) The Claimant is to be paid half the agreed contract sum upon the commencement of the
training and the balance to be paid at the end of the training program
d) Where the defendant is desirous of having additional staff enrolled in the training, it shall
dully inform the claimant in writing and the claimant and defendant shall agree on the sum to be paid in
respect of the additional trainee

5. The claimant commenced training of the 4 (four) staffs on the 20th day of December
6. The claimant states that the agreed half payment of the contract sum was not paid after
commencement of training despite repeated demands.
7. The claimant continued to train the defendants 4 (four) staffs despite not receiving any payment.
 8. The claimant states that on the 24th day of January 2018, one staff of the defendant was added
into the program without any form of notice on the claimant by the defendant making it a total of 5 (five)
staffs undergoing the training.
9. The claimant concluded the training program, still no payment was made by the defendant.
10. The claimant avers that two (2) demand letters dated 3rd day of February 2018 and 12th day of
February 2018 respectively, were written to the the defendant, for immediate payment of the agreed
contract sum of one million six hundred thousand naira (N1,600,000) for the training of 4 (four) staffs and
payment for the 1 (one) additional staff that enrolled in the training which the defendant refused to
honour and have not made payment stil. The demand letters are hereby pleaded and shall be relied upon
during trial.

WHEREOF THE CLAIMANT CLAIMS AS FOLLOWS:

a) An order of this honourable court directing the defendant to pay the sum N1,600,000 (one
million six hundred thousand naira) being the unpaid contract sum
b) An order of this honourable court directing the defendant to pay the sum of N400,000 (four
hundred thousand naira) being the additional payment for the additional staff trained
c) An order of this honourable court directing the defendant to pay the sum of N800, 000 as
general damages
d) An order of this honourable court directing the defendant to pay the sum of N2,000,000

DATED THIS……DAY OF……20218

………………………

V. A. GEORGEWILL
COUNSEL TO THE CLAIMANT
VICAZILL & CO
14 KAKA ROAD,
MAITAMA, ABUJA
XYZ@gmail.com
08161111111

FOR SERVICE ON:

THE DEFENDANT
MAITUARE NIGERIA LIMITED
NO 13 NELSON MANDELA STREET,
ASOKORO, ABUJA
 PREPARED BY SADIQ TANKO HASSAN

IN THE DISTRICT COURT OF FCT

IN THE ABUJA MAGISTERIAL DISTRICT
HOLDEN AT ABUJA

SUIT NO:

BETWEEN
ADAMU SHAZALI…………………………. CLAIMANT
AND
MAITUARE NIGERIA LIMITED…………...DEFENDANT

STATEMENT OF DEFENCE

SAVE AND EXCEPT as is herein expressly admitted, the defendant denies each and every material
allegation contained in the claimant’s statement of claim as if each paragraph were set out and
traversed seriatim

1. The defendant admits paragraph 1, 2, 3, 4 (b) (c) (d), 5, 8 and 10 of the statement of claim.
2. In respect to paragraph 4 (a) the defendant admits to the extent that the contract was for the training of
4 staff on Microsoft Excel, however it was to be conducted for a period of 7 (seven) weeks from Monday
to Friday from the hours of 8AM to 4PM at the conference room of the defendant.
3. The defendant denies liability in respect to paragraph 6 because the claimant was in breach of the agreed
time to start training from 8am to 4pm instead started from 10am, furthermore there was never a specific date
for the payment of half of the contract sum.
4. The defendant denies paragraph 7 because the claimant halted the program from 4th day of January
2018 to 11th day of January 2018 without any due notice as to the claimant’s absence.
5. The defendant denies paragraph 9 as the claimant did not conclude the 7 weeks training as stipulated in
the terms of the agreement.
6. The defendant avers that it was agreed in the contract for service that in the event of any dispute, the claimant
and defendant shall refer such dispute to arbitration.

THE DEFENDANT SHALL URGE THIS HONOURABLE COURT TO: Dismiss the claimant’s suit and refer the parties back
to Arbitration as the claimant did exhaust the available option of arbitration as a means of resolving this dispute as
agreed in the contract.

DATED THIS……DAY OF……2023

 ………………………

S. T. Hassan
COUNSEL TO THE DEFENDANT
ZAZA & CO
14 SPRING ROAD,
MAITAMA, ABUJA
ZAZA@gmail.com
08162222222

FOR SERVICE ON:

THE CLAIMANTS COUNSEL
V.A. GEORGEWILL
VICAZILL & CO
No 13 KAKA ROAD,
MAITAMA, ABUJA
XYZ@gmail.com
081611111111