IN THE HIGH COURT OF JUSTICE OF FCT ABUJA

IN THE ABUJA JUDICIAL DIVISION

HOLDEN AT ABUJA
SUIT NO: ……/…../……../2…..

IN THE MATTER OF AN APPLICATION FOR THE ENFORCEMENT OF

THE APPLICANT’S FUNDAMENTAL HUMAN RIGHTS TO FREEDOM OF
MOVEMENT PURSUANT TO SECTIONS 41 OF THE CONSTITUTION
OF THE FEDERAL REPUBLIC OF NIGERIA 1999 (AS AMENDED) AND
FUNDAMENTAL RIGHTS (ENFORCEMENT PROCEDURE) RULES 2009

BETWEEN:

MR. O.G. ATTAH - - - - - - -APPLICANTS

AND

NIGERIAN STATE SECURITY SERVICE - -RESPONDEDNT

MOTION ON NOTICE
BROUGHT PURSUANT ORDER 13 RULE IV OF THE ENFORCEMENT
PROCEDURE, 2009, SECTION 41 OF THE CONSTITUTION OF
NIGERIA, 1999 (AS EMENDED) AND THE INHERENT POWERS OF
THIS HONOURABLE COURT
TAKE NOTICE that this Honourable Court shall be moved on the … day of
……, 20… at 9’oclock in the forenoon or so soon thereafter as Applicant shall
be heard through his counsel praying this Honourable Court for the following
Orders;
1. AN ORDER enforcing the Applicant’s fundamental right to freedom of
movement on the Nigerian State Security Service
(Defendant/Respondent) through impounding the Applicant’s
International Passport on the 30th November, 2017 and disallowing the
Applicant to participate in the Human Right Conference without any
reason; in the interest of Justice.

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 2. AN ORDER directing the Defendant/Respondent to issue/release the
Plaintiff’s/Applicant’s International Passport impounded on the 30th
November, 2017, pending the hearing and determination of this suit.
3. ANY OTHER ORDER OR ORDERS as the court may deem fit to make
in the circumstance.
DATED THIS … DAY OF ………..……., 2023.
________________________
Yaya Esq.,
Bobo Esq.,
The Best Legal Practitioners,
(Counsel to the Applicant)
Legal Practitioners and
Consultants,
No. 223, Kwakware Street,
Sabon Gari-Zaria.
090xxxxxxxx
xxxxxxxxxxxx@gmail.com

ADDRESS FOR SERVICE ON THE RESPONDENT:

NIGERIAN STATE SECURITY SERVICE,
No. …………………………..,
……………………………….. (Address of the Respondent).

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 IN THE HIGH COURT OF JUSTICE OF FCT ABUJA
IN THE ABUJA JUDICIAL DIVISION
HOLDEN AT ABUJA
SUIT NO: ……/…../……../2…..

IN THE MATTER OF AN APPLICATION FOR THE ENFORCEMENT OF

THE APPLICANT’S FUNDAMENTAL HUMAN RIGHTS TO FREEDOM OF
MOVEMENT PURSUANT TO SECTIONS 41 OF THE CONSTITUTION
OF THE FEDERAL REPUBLIC OF NIGERIA 1999 (AS AMENDED) AND
FUNDAMENTAL RIGHTS (ENFORCEMENT PROCEDURE) RULES 2009

BETWEEN:

MR. O.G. ATTAH - - - - - - -APPLICANTS

AND

NIGERIAN STATE SECURITY SERVICE - -RESPONDEDNT

AFFIDAVIT IN SUPPORT

I, MR. O.G. ATTAH, Male, Adult, Christian, Civil Servant, Resident at No 112,
Mai Kowa Estate, FCT, Abuja, do hereby make oath and state as follows: -

1. That I am the Applicant in this case and by virtue of my position as

stated above, I am conversant with the facts leading to this affidavit in
support.
2. That on the Respondent is a Nigerian State Security Service residing at,
FCT, Abuja, within the jurisdiction of this court.
3. That on the 30th November, 2017, the Respondent impounded my
International Passport without any reason.
4. That on the said 30th November, 2017 I intended to attend Human Right
Conference at United State of America which I was invited by Californian
Foundation.

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5. That the Respondent deprived me of my right to freedom of movement
by impounding my international passport and thereby disallowing me to
attend the said program in paragraph 4.
6. That there is need for this Honourable to restrain the Respondent and
compel them to return my International Passport to enable me travel
outside the Country.
7. That there is serious urgency for the grant of this application.
8. That the Respondent with not be prejudice by the grant of this
application.
9. That I undertake to pay damages to the Respondents should the grant
of this Applicant turns out to be wrongful.
10. That I know that I will be greatly prejudiced if this Application is refused
11. That I depose to this affidavit in good faith conscientiously believing
same to be true and correct in accordance with the Oaths Act 2004.

______________________
Deponent

Sworn to at the High Court Registry, F.C.T., Abuja

Dated this …………. Day of …………., 2023

BEFORE ME

COMMISSIONER FOR OATHS