WRIT OF SUMMONS

IN THE HIGH COURT OF OGUN STATE

IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO:
BETWEEN

MR. ADEBISI STEPHEN ADEDAPO CLAIMANT

AND

1. PRINCE MURIANA ADETUNJI BANJOKO

2. MRS. OLAJOGUN AISHAT
3. PRINCE M. A. TAIWO
4. DEFENDAN

To THE DEFENDANTS:

THE 1ST DEFENDANT, PRINCE MURIANA ADETUNJI BANJOKO

THE 2ND DEFENDANT, MRS. OLAJOGUN AISHAT

THE 3RD DEFENDANT, M. A. TAIWO

THE 4TH DEFENDANT,

You are hereby commanded that within seven days after the service of this writ on
you, inclusive of the day of such service, you do cause an appearance to be entered
for you in an action at the suit of ………………………………………… and take
notice that in default of your so doing the Claimant may proceed therein, and
judgment may be given in your absence.

DATED this ………………….day of ……………………………, 2021

 ………………………………….
CHIEF TANIMOWO BABAJIDE, ESQ.
TANIMO BAJIDE LAW FIRM
CLAIMANT’S SOLICITORS
6, SHODUNKE CLOSE, OFF,
OKALAWON STREET,
OKANLANWONBUS STOP,
OLAMBE, OGUN STATE.
Tel: 08160600908

………………………………
Registrar
N.B – This writ is to be served within six calendar months from the date thereof,
or, if renewed, within three calendar months from the date of last renewal,
including the day of such date, and not afterwards

The defendant may enter appearance personally or by Solicitors either by handing

in the appropriate forms, duly completed, at the Registry of the High Court of the
Judiciary Division in which the action is brought or by sending to the Registry by
registered post.
INDORSEMENT

(a) A DECLARATION that the Claimant is the person entitle to the Staturtory
right of occupancy in respect of the landed property being the one plot of
land, lying and situate at Daniel Adejobi Close, Ifesowapo, Akute, Local
Govt, Area, Ogun State, measuring approximately Area 667.785 SQM, by
Survey Plan No………..

(b) .AN ORDER of Perpetual Injunction Restraining the Defendants by

themselves, their Agent or any other person howsoever called from further
disturbing or trespass on the Claimant landed property being the one plot of
land, lying and situate at Daniel Adejobi Close, Ifesowapo, Akute, Local
Govt, Area, Ogun State, measuring approximately Area 667.785 SQM, by
Survey Plan No……………
 (c) DAMAGES in the sum of N2, 180,000.00 (Two Million One Hundred and
Eighty Thousand Naira Only) as damages for the encroachment and the
destruction of the Claimant’s gigantic iron gate on the property.

(d) Cost of this suit N500,000.00 (Five Hundred Thousand Naira)

Dated this day of 2021

This writ was issued by Chief Tanimowo Babajide Esq. of TANIMOWO

BABAJIDE LAW FIRM whose address for service is 6, Shodunke Close. Off
Okanlawon Street, Okanlawon Bus Stop, Olambe, Ifo, Local Government Area
Ogun State, agent for …………….of…………… Legal Practitioners for the said
Claimant who reside at …………… …………………………………(Mention the
City, town or District and also the name of the street and number of the house of
the plaintiff’s residence, if any).
This writ was served by me ………………….………………On the
Defendant (describe mode of service) …………………on the……… day of
…………… 2021.
Indorsed the …………………..day of ………………….2021
Signed …………………………
Address …………………………
 IN THE HIGH COURT OF OGUN STATE
IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO:
BETWEEN

MR. ADEBISI STEPHEN ADEDAPO CLAIMANT

AND
1 PRINCE MURIANA ADETUNJI BANJOKO
2 MRS. OLAJOGUN AISHAT
3 PRINCE M. A. TAIWO
4 DEFENDANTS

STATEMENT OF CLAIM

1) The Claimant is a Nigerian Citizen, resides at ……… Local Government Area

of Ogun State.

2) The 1st Defendant is also a Nigerian Citizen, resides at……………

Local Govt Area, Ogun State.

3) The 2nd Defendant is also a Nigerian Citezen, resides at……………. Local Govt
Area, Ogun State.

4) The 3rd Defendant is also a Nigerian Citezen, resides at……………. Local

Govt Area, Ogun State.

5) The 4th Defendant is also a Nigerian Citezen, resides at……………. Local

Govt Area, Ogun State.

6) Claimant aver in the year 2011, he bought One plot of land situate and lying at
Daniel Adejobi Close, Ifesowapo, Akute, Local Govt, Area, Ogun State,
measuring approximately Area 667.785 SQM, who derived his title of the the
land, from Ismoila Obasanya, in 2008. A copy of the land purchased receipt
issued to the Claimant by Mr. Ismoila Obasanya is Marked as Exhibit A1,
shall stongly relied on at trial.
7) Claimant also aver that, Chief Mrs. Helen E. Oghuma Chairman of
EGHIEMAN INDUSTRIES LTD, of Plot 36 Yakoyo Road, Ojudu, Ogun State,
holder of Certificate of Occupancy NO: 023494, originally derived her titled
from the Osolo’s family, ( formerly known as the Dada Edu Family) of Ota in
 Ogun State Nigeria. A copy of the Deed of Assignment between Chief Mrs.
Helen E Oghuma, Chairman of EGHIEMAN INDUSTRIES LTD and
Dada Edu Family, Marked as Exhibit A2, shall be relield at trial.

8) Claimant further aver that, pursuant to the said purchase from Chief Mrs. Helen
E. Oghuma Chairman of EGHIEMAN INDUSTRIES LTD, of Plot 36 Yakoyo
Road, Ojudu, Ogun State, holder of Certificate of Occupancy NO: 023494, for
the sake of giving peace a chance, went into ratification with the following
people:
(a) Paid N400,000.00 (Four Houndred Thousand Naira) to
Descendant Development Fees, Adiyan ALausa, dated: 8th
November, 2005.

(b) Paid N10,000.00 (Ten Thousand Naira) to Agbado/Oke-Aro

and Enviros, Council of Baales & chief, dated: 18/11// 2005.

(c) Paid N200,000.00( Two Hundred Naira) to Olofin Chieftancy

Family, Isheri –Aworiland, dated: 24/11/2005. Receipt a to c
are Marked as Exhibit, B1, B2 and B3 respectively and shall
be tendered at trial.

9) Claimant aver that as a result of the above incidents, and to further re-secure
his ownership of the subject matter of this suit, he commissioned the land to be
surveyed.

10) Claimant aver that the land subject matter of this suit was thus measured as at
Daniel Adejobi Close, Ifesowapo, Akute, Local Govt, Area, Ogun State,
measuring approximately Area 667.785 SQM, by Survey Plan No……….. by
a licensed Surveyor: Olatubosun Shofisile at, Block D, Plot 2. Road F
Sparklight Estate, KLM2, lagos Ibadam Express Way, Isheri, Ogun State. A
copy of it shall be marked as Exhibit C1 and shall be relied upon at trial.

11) Claimant aver that, he went into possession of the land subject matter and have
thus been exercising every act of ownership and possession without any let or
hinderances from anyone.

12) Claimant aver that he continue in possession without any hindrances and enjoy
quite possession of the land subject matter of this suit until March 2019, when
the above named Defendants. Certifiably known as land speculators and
 trespassers, forcefully invaded the land and removed the gate of the land and
took it to unknown destination.

13) Claimant aver that after the above incident, he quickly ran to Ajuwon Police
Station to lodge a complaint about the Defendants barbaric action, to his
greatest astonishment and bewilderment, the Defendants ignored the invitation
of the Ajuwon Police, hence a petition was filed against them at, The Area
Commander, Ota Area Command Headquarters, Sango, Ogun State. A Copy of
the Petition is Marked as Exhibit C2 and shall be relied upon at trial

14) That the Defendants did not take to the Police advice but rather have continued
their encroachment on the land to the detriment of the Claimant.

15) Consequent to the above, the Claimant instructed his solicitors, the law firm of
Tanimowo Babajide Law, to warn the Defendants to desist from their trespass
on his land and the consequence of their action thereof Claimant Solicitor’s
letter of 17th February, 2020. Shall be relied upon at the trial of this suit.

16) Claimant avers that the said Solicitors letter dated the 17 th February, 2015 was
not responded to by the Defendants rather they have persist in their
encroachment of the Claimant’s land

17) Claimant aver that the Defendants despite the warning as contain in the
Claimant Solicitor’s letter admonishing and warning them of the legal
implication of their actions, the Defendants neither ceased their trespass nor
responds till date.

18) Claimant shall at trial rely on all equitable remedies available to the proving of
his case.

19) Claimant shall during trial rely on all documents relating to the institution of
this action

20) Claimant hereby plea the following documents to Wit:

(a) Claimant purchase receipts from Mr. Ismoila Obasaqnyan, Dated: 10 th of

April, 2008.

(b) Chief Mrs. Helen E. Oghuma Chairman of EGHIEMAN INDUSTRIES

LTD, of Plot 36 Yakoyo Road, Ojudu, Ogun State, holder of Certificate of
 Occupancy NO: 023494, Deed of Assignment with the, Osolo’s family,
( formerly known as the Dada Edu Family) of Ota in Ogun State Nigeria.

(c) The Certificate of Occupancy No: 023494.

(d) Chief Mrs. Helen E. Oghuma Chairman of EGHIEMAN INDUSTRIES

LTD, of Plot 36 Yakoyo Road, Ojudu, Ogun State, holder of Certificate of
Occupancy NO: 023494, documents of ratifications;

a. Paid N400,000.00 (Four Houndred Thousand

Naira) to Descendant Development Fees, Adiyan
ALausa, dated: 8th November, 2005.

b. Paid N10,000.00 (Ten Thousand Naira) to

Agbado/Oke-Aro and Enviros, Council of
Baales & chief, dated: 18/11// 2005.

c. Paid N200,000.00( Two Hundred Naira) to

Olofin Chieftancy Family, Isheri –Aworiland,
dated: 24/11/2005. Receipt a to c are Marked as
Exhibit, B1, B2 and B3 respectively and shall be
relied upon at trial.

(e) A Survey showing the land subject matter of this suit was thus measured as
at Daniel Adejobi Close, Ifesowapo, Akute, Local Govt, Area, Ogun State,
measuring approximately Area 667.785 SQM, by Survey Plan No………..
by a licensed Surveyor: Olatubosun Shofisile at, Block D, Plot 2. Road F
Sparklight Estate, KLM2, lagos Ibadam Express Way, Isheri, Ogun State.

(f) Claimant Solicitor letter of 17th February, 2020.

21) Claimant contends that he neither authorizes nor grant consent to nor does he
instruct a sale of his land subject matter of this suit to any other person(s).

22) WHEREUPON the Claimant Claim jointly and severally against the
Defendants as follows:

(e) A DECLARATION that the Claimant is the person entitle to the Staturtory
right of occupancy in respect of the landed property being the one plot of
land, lying and situate at Daniel Adejobi Close, Ifesowapo, Akute, Local
 Govt, Area, Ogun State, measuring approximately Area 667.785 SQM, by
Survey Plan No………..

(f) .AN ORDER of Perpetual Injunction Restraining the Defendants by

themselves, their Agent or any other person howsoever called from further
disturbing or trespass on the Claimant landed property being the one plot of
land, lying and situate at Daniel Adejobi Close, Ifesowapo, Akute, Local
Govt, Area, Ogun State, measuring approximately Area 667.785 SQM, by
Survey Plan No……………

(g) DAMAGES in the sum of N2, 180,000.00 (Two Million One Hundred and
Eighty Thousand Naira Only) as damages for the encroachment and the
destruction of the Claimant’s gigantic iron gate on the property.

(h) Cost of this suit N500,000.00 (Five Hundred Thousand Naira)

DATED THIS DAY OF 2021

………………………………….
CHIEF TANIMOWO BABAJIDE, ESQ.
TANIMO BAJIDE LAW FIRM
CLAIMANT’S SOLICITORS
6, SHODUNKE CLOSE, OFF,
OKALAWON STREET,
OKANLANWONBUS STOP,
OLAMBE, OGUN STATE.
Tel: 08160600908

FOR SERVICES ON THE

1. THE DEFENDANTS
C/O. PROPERTY IN DISPUTE; SITUATE AT

IN THE HIGH COURT OF OGUN STATE

IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO:
BETWEEN
 MR. ADEBISI STEPHEN ADEDAPO CLAIMANT

AND

1. PRINCE MURIANA ADETUNJI BANJOKO

2. MRS. OLAJOGUN AISHAT
3. PRINCE M. A. TAIWO
4. DEFENDANTS

STATEMENT ON OATH OF CLAIMANT WITNESS MR ADEBISI STEPHEN

ADEDAPO.

I, MR. ADEBISI STEPHEN ADEDAPO , male, Nigeria citizen of ………………

Local Government Area of Ogun State do hereby make oath and states as follows

1. I am the Claimant in this suit by virtue of which I am conversant with the

facts deposed to herein

2. I am the owner of the property, the one plot of land subject matter of this
suit lying and being at Daniel Adejobi Close, Ifesowapo, Akute, Local
Govt, Area, Ogun State, measuring approximately Area 667.785 SQM,
by Survey Plan No…………….

3. The 1st Defendant is also a Nigerian Citizen, resides at……………

Local Govt Area, Ogun State.

4. The 2nd Defendant is also a Nigerian Citezen, resides at……………. Local

Govt Area, Ogun State.

5. The 3rd Defendant is also a Nigerian Citezen, resides at……………. Local

Govt Area, Ogun State.

6. The 4th Defendant is also a Nigerian Citezen, resides at……………. Local

Govt Area, Ogun State.

7. in the year 2011, i bought One plot of land situate and lying at Daniel
Adejobi Close, Ifesowapo, Akute, Local Govt, Area, Ogun State,
measuring approximately Area 667.785 SQM, who derived his title of the
the land, from Ismoila Obasanya, in 2008. A copy of the land purchased
 receipt issued to the Claimant by Mr. Ismoila Obasanya is Marked as
Exhibit A1, shall stongly relied on at trial.

8. That Chief Mrs. Helen E. Oghuma Chairman of EGHIEMAN

INDUSTRIES LTD, of Plot 36 Yakoyo Road, Ojudu, Ogun State, holder
of Certificate of Occupancy NO: 023494, originally derived her titled from
the Osolo’s family, ( formerly known as the Dada Edu Family) of Ota in
Ogun State Nigeria. A copy of the Deed of Assignment between Chief
Mrs. Helen E Oghuma, Chairman of EGHIEMAN INDUSTRIES
LTD and Dada Edu Family, Marked as Exhibit A2, shall be relield at
trial.

9. That, pursuant to the said purchase from Chief Mrs. Helen E. Oghuma
Chairman of EGHIEMAN INDUSTRIES LTD, of Plot 36 Yakoyo Road,
Ojudu, Ogun State, holder of Certificate of Occupancy NO: 023494, for
the sake of giving peace a chance, went into ratification with the following
people:
(a) Paid N400,000.00 (Four Houndred Thousand Naira) to
Descendant Development Fees, Adiyan ALausa, dated: 8th
November, 2005.

(b) Paid N10,000.00 (Ten Thousand Naira) to Agbado/Oke-Aro

and Enviros, Council of Baales & chief, dated: 18/11// 2005.

(c) Paid N200,000.00( Two Hundred Naira) to Olofin Chieftancy

Family, Isheri –Aworiland, dated: 24/11/2005. Receipt a to c
are Marked as Exhibit, B1, B2 and B3 respectively and shall
be tendered at trial.

(10)That as a result of the above incidents, and to further re-secure my ownership

of the subject matter of this suit, I commissioned the land to be surveyed.

(11) That the land subject matter of this suit was thus measured at Daniel Adejobi
Close, Ifesowapo, Akute, Local Govt, Area, Ogun State, measuring approximately
Area 667.785 SQM, by Survey Plan No……….. by a licensed Surveyor:
Olatubosun Shofisile at, Block D, Plot 2. Road F Sparklight Estate, KLM2, lagos
Ibadam Express Way, Isheri, Ogun State. A copy of it shall be marked as Exhibit
C1 and shall be relied upon at trial.
(12)That, I went into possession of the land subject matter and have thus been
exercising every act of ownership and possession without any let or hinderances
from anyone.

(13) That he continue in possession without any hindrances and enjoy quite
possession of the land subject matter of this suit until March 2019, when the above
named Defendants. Certifiably known as land speculators and trespassers,
forcefully invaded the land and removed the gate of the land and took it to
unknown destination.

(14) Claimant aver that after the above incident, he quickly ran to Ajuwon Police
Station to lodge a complaint about the Defendants barbaric action, to my greatest
astonishment and bewilderment, the Defendants ignored the invitation of the
Ajuwon Police, hence a petition was filed against them at, The Area Commander,
Ota Area Command Headquarters, Sango, Ogun State. A Copy of the Petition is
Marked as Exhibit C2 and shall be relied upon at trial

(15)That the Defendants did not take to the Police advice but rather have continued
their encroachment on the land at my own detriment of the Claimant.

(`16)Consequent to the above, i instructed my solicitors, the law firm of Tanimowo

Babajide Law, to warn the Defendants to desist from their trespass on my land and
the consequence of their action thereof my Solicitor’s letter of 17 th February, 2020.
Shall be relied upon at the trial of this suit.

(17)Tthat the said Solicitors letter dated the 17 th February, 2015 was not responded
to by the Defendants rather they have persist in their encroachment of the my land

(18)That the Defendants despite the warning as contain in the Claimant Solicitor’s
letter admonishing and warning them of the legal implication of their actions, the
Defendants neither ceased their trespass nor responds till date.

(19) That i shall at trial rely on all equitable remedies available to the proving of
his case.

(20) That i shall during trial rely on all documents relating to the institution of this
action

(21)That i hereby plea the following documents to Wit:

 (g) Claimant purchase receipts from Mr. Ismoila Obasaqnyan, Dated: 10 th of
April, 2008.

(h) Chief Mrs. Helen E. Oghuma Chairman of EGHIEMAN INDUSTRIES

LTD, of Plot 36 Yakoyo Road, Ojudu, Ogun State, holder of Certificate of
Occupancy NO: 023494, Deed of Assignment with the, Osolo’s family,
( formerly known as the Dada Edu Family) of Ota in Ogun State Nigeria.

(i) The Certificate of Occupancy No: 023494.

(j) Chief Mrs. Helen E. Oghuma Chairman of EGHIEMAN INDUSTRIES

LTD, of Plot 36 Yakoyo Road, Ojudu, Ogun State, holder of Certificate of
Occupancy NO: 023494, documents of ratifications;

a. Paid N400,000.00 (Four Houndred Thousand

Naira) to Descendant Development Fees, Adiyan
ALausa, dated: 8th November, 2005.

b. Paid N10,000.00 (Ten Thousand Naira) to

Agbado/Oke-Aro and Enviros, Council of
Baales & chief, dated: 18/11// 2005.

c. Paid N200,000.00( Two Hundred Naira) to

Olofin Chieftancy Family, Isheri –Aworiland,
dated: 24/11/2005. Receipt a to c are Marked as
Exhibit, B1, B2 and B3 respectively and shall be
relied upon at trial.

(k) A Survey showing the land subject matter of this suit was thus measured as
at Daniel Adejobi Close, Ifesowapo, Akute, Local Govt, Area, Ogun State,
measuring approximately Area 667.785 SQM, by Survey Plan No………..
by a licensed Surveyor: Olatubosun Shofisile at, Block D, Plot 2. Road F
Sparklight Estate, KLM2, lagos Ibadam Express Way, Isheri, Ogun State.

(l) Claimant Solicitor letter of 17th February, 2020.

(22)Claimant contends that he neither authorizes nor grant consent to nor does he
instruct a sale of his land subject matter of this suit to any other person(s).
 10.WHEREUPON I Claim jointly and severally against the Defendants as
per my Writ of Summon and Statement of Claim,

11.I make this oath in good faith and in accordance with the oath law in force

…………………
DEPONENT

(The above deposition was read by me……………….

In the Yoruba Language to the Deponent and he affix
his signature after appearing to understand the content thereof.)

Sworn to at the High Court Registry IFO

This day of 2021

BEFORE ME

COMMISSIONER FOR OATHS

IN THE HIGH COURT OF OGUN STATE

IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO:
BETWEEN

MR. ADEBISI STEPHEN ADEDAPO CLAIMANT

AND

1. PRINCE MURIANA ADETUNJI BANJOKO

2. MRS. OLAJOGUN AISHAT
3. PRINCE M. A. TAIWO
4. DEFENDANTS

LIST OF DOCUMENT TO BE RELIED UPON AT TRIAL

(a) Claimant Solicitor letter of 17th February, 2021.

DATED THIS DAY OF 2021

………………………………….
CHIEF TANIMOWO BABAJIDE, ESQ.
TANIMO BAJIDE LAW FIRM
CLAIMANT’S SOLICITORS
6, SHODUNKE CLOSE, OFF,
OKALAWON STREET,
OKANLANWONBUS STOP,
 OLAMBE, OGUN STATE.
Tel: 08160600908

FOR SERVICES ON THE

1. THE DEFENDANTS

IN THE HIGH COURT OF OGUN STATE

IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO:
BETWEEN

MR. ADEBISI STEPHEN ADEDAPO CLAIMANT

AND
 1. PRINCE MURIANA ADETUNJI BANJOKO
2. MRS. OLAJOGUN AISHAT
3. PRINCE M. A. TAIWO
DEFENDANTS

CLAIMANT’S LIST OF WITNESSES.

1. MR.

DATED THIS DAY OF 2021

………………………………….
CHIEF TANIMOWO BABAJIDE, ESQ.
TANIMO BAJIDE LAW FIRM
CLAIMANT’S SOLICITORS
6, SHODUNKE CLOSE, OFF,
OKALAWON STREET,
OKANLANWONBUS STOP,
OLAMBE, OGUN STATE.
Tel: 08160600908

FOR SERVICES ON THE DEFENDANTS

C/O. PROPERTY IN DISPUTE;