IN THE HIGH COURT OF OGUN STATE
IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO: HCT/143/2021
BETWEEN:
1. MRS. AGNES IKOLO
(Trading under the name and style of MURAINE PROJECT) CLAIMANTS/RESPONDENTS
2. MR. TOCHUKWU OKAFOR
AND
MR. DELE OLORUNFEMI ……………………… DEFENDANT/APPLICANT
PROPOSED AMENDED STATEMENT OF DEFENCE
SAVE AND EXCEPT as hereinafter expressly admitted the Defendant denies each and
every allegation of fact contained in the Claimants’ Statement of Claim as if each were
specifically set out and denied seriatim.
1. The Defendant admits paragraph 1 of the Statement of Claim.
2. The Defendant denies paragraph 2 of the Statement of Claim and puts the
Claimants to strict proof of the same.
3. The Defendant admits paragraphs 3-10 inclusive, of the Statement of Claim.
4. The Defendant admits paragraph 4 of the Statement of Claim to the extent that a
Contract was awarded by the Ifo Local Government Area of ogun State on 7 th
January, 2010 to build Ultra-modern shops at Agbado market, but avers further
that the defendant brought in LATE YUSUF IKOLO as a partner using the name
MURRAINE PROJECTS.
5. The Defendant denies paragraph 11 of the Statement of Claim and puts the
Claimants to strict proof thereof.
6. The Defendant puts the Claimants to strict proof of paragraph 12 of the Statement
of Claim.
7. The Defendant denies paragraph 13 of the Statement of Claim and subjects the
Claimants to strict proof of the same.
8. The Defendant admits paragraph 14 of the Statement of Claim.
9. The Defendant denies paragraphs 15-19, inclusive, of the Statement of Claim and
puts the Claimants to strict proof of the averments therein.
10.Further to the above, the Defendant states that the true facts of the matter are as
follows:
i. It was the Defendant who sourced the contract from the Ifo Local
Government Area for the building of ultra-modern shops at Agbado
Market, and carried out all the negotiations relating to the contract,
starting from sometime in 2009.
ii. The Defendant was able to do this because he had all the necessary
experience in the field, which he gained from being part of the team that
built M.K.O. Abiola Market, Otubu Bus Stop Agege, Lagos, Sabo Market,
Yaba, Lagos, White sand Market, Oyingbo, Lagos, and Imota Market, via
Ikorodu, Lagos.
iii. It was the Defendant who did all the documentation towards securing the
contract, including the survey of the market, bill of quantities and the
proposal, and singlehandedly paid for them. The Defendant at this period
had not known or met LATE MR. YUSUF IKOLO.
iv. That it was the defendant that met with the relevant elders of the Agbado
Community to seek their blessings and support for the construction work.
The Claimants, particularly the 2nd claimant and LATE ENGR. YUSUF
IKOLO was not in the picture then. The defendant shall at the trial of this
suit plead and rely on photograph of himself and elders of Agbado
community.
v. It was after all the above had been done, including defense of the project
(contract), that the Defendant got to meet LATE ENGR YUSUF IKOLO,
who was introduced to him by one Alhaji Kazeem, who said Yusuf Ikolo
was an engineer and was his class mate, and encouraged the Defendant to
work with him, and gave the Defendant his phone number.
vi. The Defendant called Engineer Ikolo and fixed a meeting with him, and in
the course of their discussion, the Defendant discovered that he was from
the same Akoko area of Ondo State. They then decided to use Engineer
Ikolo’s registered company – Muraine Projects – for the project, and the
Defendant went ahead to conclude all the required documentation for the
contract. He also opened an account with Access Bank, Kola branch in the
name of the company and was the one signing all the cheques. The
contract was finally given in the name of the company in 2010, and the
execution of the contract was carried out jointly by the Defendant and
Engineer Ikolo (now late)
vii. It was one of the partners working with the Defendant and Engineer
Ikolo on the project, in the person of Mr. Vincent Akinyemi, who later
introduced the 2nd Claimant to the Defendant, that as a spare parts dealer
at Sango market, he would be of help in talking to other traders
concerning the project.
viii. Throughout the life time of Engineer Yusuf Ikolo, he had a smooth and
cordial working relationship with the Defendant, and the 1st Claimant was
not in the picture at all. It was some years after the demise of Engineer
Ikolo sometime in 2016 that the Claimants started the plan to sideline the
Defendant in the business, which was orchestrated by the 2nd Claimant.
ix. That not long after the 2nd Claimant was introduced into the business, he
started perpetuating act which amongst others include fraudulent
withdrawal from the business account.
x. That the 2nd Claimant at a point collected the sum of ₦650,000 (Six
Hundred and Fifty Thousand Naira) without the knowledge of the
defendant and LATE ENGR. YUSUF IKOLO.
xi. This prompted the defendant to order the suspension of the 2 nd defendant
from the business.
xii. That with the suspension, the 2nd Claimant started visiting the house of
LATE ENGR. YUSUF IKOLO to plead with the 1 st claimant (LATE ENGR.
YUSUF IKOLO’s wife) to talk to her husband to use his influence to re-
absolve him into the business.
xii. That after discussion with LATE ENGR. YUSUF IKOLO coupled with plea
from some elders in the market, the defendant eas constrained to re-
absolve the 2nd Claimanat.
xiv. That upon the re-absolving of the 2nd Claimant to the business, the 2nd
Claimant continued persisted in his dubious act and went to the extent of
writing a petition against the defendant and LATE ENGR. YUSUF IKOLO
himself.
xv. That following the petition, the defendant and LATE ENGR. IKOLO were
invited by the police and upon hearing their explanations, the police
advised the defendant and LATE ENGR. YUSUF IKOLO to expel the 2nd
Claimant from the business.
11. The Defendant avers that in his bid to sideline the defendant, intiated different
criminal action against the defendant at the Lagos Magistrate court and Ifo
Magistrate Court in charge no: MIF/659C/2016, which judgement was given on 22nd
day of January, 2021 in which His Worship F. A. IROKO discharged and acquitted
the defendant of all allegation in the Six (6) count charge brought against the
defendant. Copy of the certified true copy of the Judgment is hereby pleaded and
would be relied on at the trial of this suit.
12. That in the proceedings at the Lagos Magistrate Court and Ifo Magistrate Court
aforementioned, the 2nd claimant himself gave evidence to the effect that the
defendant is his partner in MURRAINE PROJECTS. The record of proceedings of the
20th day of October, 2017 is hereby pleaded and would be relied on at the trial of
this suit.
13.That the Police in the course of their investigation to uncover money illegally
collected from the account of Murraine Projects; sought an order of court that the
affected banks i. e. ACCESS BANK NIG. PLC and FIRST BANK NIG. PLC furnish
information through the investigating Police officer of the state criminal
investigation department on the respective account of MURRAINE PROJECTS
maintained with the banks. The copy of the certified true copy of the enrollment of
order and the request for same dated 27 th May, 2022 are hereby pleaded and be
relied on at the trial of this suit.
14.The Defendant will contend, at or before the trial of this case, that the Claimants do
not have the legal right to institute the instant action.
15. The Defendant shall contend further that the Claimants’ action as constituted has
not disclosed any cause of action against him, and ought to be struck out.
16. The Defendant avers that the Claimants are not entitled to any of the claims
contained in paragraph 21 of the Statement of Claim.
17. WHEREOF the Defendant prays this Honourable Court to dismiss the Claimants’
claims in theirs for being frivolous, vexatious and lacking in merit.
Dated this …………………. day of …………………………… 2023
ADEWALE SURAJ, ESQ.
ABIOLA ALANI ESQ.
DEFENDANT/APPLICANT’S COUNSEL
S. A. ADEWALE & CO.
FOR SERVICE ON: Suite 13, 1st Floor, Amop Complex,
THE CLAIMANTS/RESPONDENTS 59, Agbado-Ijaiye Road
C/O THEIR COUNSEL Opposite First Bank Plc.
CHIEF GODWIN O.D. OKEKE Ijaiye-Ojokoro, Lagos State.
G.O.D. OKEKE & CO. Tel: 08055265072
AGOZIE CHAMBERS Email: surajuadewale40@gmail.com
T.K.B. SHOPPING COMPLEX c/o 3, Adeyeri Close,
NO. 1, IDIROKO ROAD Agbado Crossing,
SANGO – OTA Ogun State.
OGUN STATE
TEL: 08033157372, 08179772053
IN THE HIGH COURT OF OGUN STATE
IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO: HCT/143/2021
BETWEEN:
1.MRS. AGNES IKOLO
(Trading under the name and style of MURAINE PROJECT) CLAIMANTS/RESPONDENTS
2. MR. TOCHUKWU OKAFOR
AND
MR. DELE OLORUNFEMI ……………………… DEFENDANT/APPLICANT
PROPOSED LIST OF WITNESS
1. MR. BAMIDELE OLORUNFEMI
Dated ………... day of ………………………………………………, 2023
ADEWALE SURAJ, ESQ.
ABIOLA ALANI ESQ.
DEFENDANT/APPLICANT’S COUNSEL
S. A. ADEWALE & CO.
Suite 13, 1st Floor, Amop Complex,
59, Agbado-Ijaiye Road
Opposite First Bank Plc.
Ijaiye-Ojokoro, Lagos State.
Tel: 08055265072
FOR SERVICE ON: Email: surajuadewale40@gmail.com
THE CLAIMANTS/RESPONDENTS c/o 3, Adeyeri Close,
C/O THEIR COUNSEL Agbado Crossing,
CHIEF GODWIN O.D. OKEKE Ogun State.
G.O.D. OKEKE & CO.
AGOZIE CHAMBERS
T.K.B. SHOPPING COMPLEX
NO. 1, IDIROKO ROAD
SANGO – OTA
OGUN STATE
TEL: 08033157372, 08179772053
IN THE HIGH COURT OF OGUN STATE
IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO: HCT/143/2021
BETWEEN:
1. MRS. AGNES IKOLO
(Trading under the name and style of MURAINE PROJECT) CLAIMANTS/RESPONDENTS
2. MR. TOCHUKWU OKAFOR
AND
MR. DELE OLORUNFEMI ……………………… DEFENDANT/APPLICANT
PROPOSED LIST OF DOCUMENTS
1. Photographs of Defendants and Elders of Agbado Community.
2. Certified true copy of judgement by His Worship F. A. IROKO, dated 22 nd January,
2021.
3. Certified true copy of Record of proceedings dated 20th October, 2017.
4. Copy of request for copy of enrolment of order dated 27th May, 2022 and Certified
true copy of Order dated 7th March, 2022.
Dated ………... day of ………………………………………………, 2023
ADEWALE SURAJ, ESQ.
ABIOLA ALANI ESQ.
DEFENDANT/APPLICANT’S COUNSEL
S. A. ADEWALE & CO.
Suite 13, 1st Floor, Amop Complex,
59, Agbado-Ijaiye Road
Opposite First Bank Plc.
Ijaiye-Ojokoro, Lagos State.
Tel: 08055265072
FOR SERVICE ON: Email: surajuadewale40@gmail.com
THE CLAIMANTS/RESPONDENTS c/o 3, Adeyeri Close,
C/O THEIR COUNSEL Agbado Crossing,
CHIEF GODWIN O.D. OKEKE Ogun State.
G.O.D. OKEKE & CO.
AGOZIE CHAMBERS
T.K.B. SHOPPING COMPLEX
NO. 1, IDIROKO ROAD
SANGO – OTA
OGUN STATE
TEL: 08033157372, 08179772053
IN THE HIGH COURT OF OGUN STATE
IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO: HCT/143/2021
BETWEEN:
1.MRS. AGNES IKOLO
(Trading under the name and style of MURAINE PROJECT) CLAIMANTS/RESPONDENTS
2. MR. TOCHUKWU OKAFOR
AND
MR. DELE OLORUNFEMI ……………………… DEFENDANT/APPLICANT
DEFENDANT’S FURTHER WITNESS STATEMENT ON OATH
I, BAMIDELE OLORUNFEMI, Adult, Male, Christian, Nigerian Citizen and Business man of
2, Oremeji Street, Isorosi, Sango-Ota, Ogun State, do hereby make oath and state as
follows:
1. I am the Defendant in this case, by reason of which I am conversant with the facts
deposed in this Statement on Oath, which are facts within my personal knowledge.
2. I know as a fact that sometime in 2010, Muraine Projects, aregistered Business
whose proprietor was Engineer Yusuf Ikolo (now deceased), was awarded a
contract by the Ifo Local Government for the building of ultra modern shops at
Agbado market, and I was a partner to the late Engineer Yusuf Ikoloin the execution
of the contract.
3. That I was not part of the contract for the execution of the contract and that I
trespassed into the premises of Agbado market and started building shops are
untrue.
4. That a Contract was awarded by the Ifo Local Government Area of ogun State on 7 th
January, 2010 to build Ultra-modern shops at Agbado market, but avers further
that the defendant brought in LATE YUSUF IKOLO as a partner using the name
MURRAINE PROJECTS.
5. I state that the true facts of the matter are as follows:
i. I was the one who sourced the contract from the Ifo Local Government Area
for the building of ultra-modern shops at Agbado Market, and did all the
negotiations relating to the contract, starting from sometime in 2009.
ii. I was able to do this because I had all the necessary experience in the field,
which I gained from being part of the team that built M.K.O. Abiola Market,
Otubu Bus Stop Agege, Lagos, Sabo Market, Yaba, Lagos, White sand Market,
Oyingbo, Lagos, and Imota Market, via Ikorodu, Lagos.
iii. That I was the one who did all the documentation towards securing the
contract, including the survey of the market, bill of quantities and the
proposal, and singlehandedly paid for them. That at this period I had not
known or met LATE MR. YUSUF IKOLO.
iv. That it was I who met with the relevant elders of the Agbado Community to
seek their blessings and support for the construction work. The Claimants,
particularly the 2nd claimant and LATE ENGR. YUSUF IKOLO was not in the
picture then. I shall at the trial of this suit plead and rely on photograph of
himself and elders of Agbado community.
v. It was after all the above had been done, including defence of the project
(contract), that I got to meet one Yusuf Ikolo, who was introduced to me by
one Alhaji Kazeem, who said Yusuf Ikolo was an engineer and was his class
mate, and encouraged me to work with him on the project, and gave me his
phone number.
vi. I subsequently called Engineer Ikolo and fixed a meeting with him, and in the
course of our discussion, it came to light that he was from the same Akoko
area of Ondo State like me. We then decided to use Engineer Ikolo’s
registered company – Muraine Projects – for the project, and I went ahead to
conclude all the required documentation for the contract. I also personally
opened an account with Access Bank, Kola branch, in the name of the
company and was the one signing all the cheques. The contract was finally
given in the name of the company in 2010.
vii. We (the late Engineer Ikolo and I) then started execution of the project
together.
viii. It was one of the partners working with us on the project, in the person of
Mr. Vincent Akinyemi, who later introduced the 2 nd Claimant to me, in the
belief that as a spare parts dealer at Sango market, he would be of help in
talking to other traders concerning the project.
ix. Throughout the life time of Engineer Yusuf Ikolo, he had a smooth and
cordial working relationship with me and the 1st Claimant (late Engineer
Ikolo’s wife) was not in the picture at all. It was some years after the demise
of Engineer Ikolo sometime in 2016 that the Claimants started their wicked
plan to sideline me in the business, which was actually orchestrated by the
2nd Claimant.
x. That not long after the 2nd Claimant was introduced into the business, he
started perpetuating act which amongst others include fraudulent
withdrawal from the business account.
xi. That the 2nd Claimant at a point collected the sum of ₦650,000 (Six
Hundred and Fifty Thousand Naira) without the knowledge of the
defendant and LATE ENGR. YUSUF IKOLO.
xii. This prompted me to order the suspension of the 2 nd defendant from the
business.
xiii. That with the suspension, the 2nd Claimant started visiting the house of LATE
ENGR. YUSUF IKOLO to plead with the 1st claimant (LATE ENGR. YUSUF
IKOLO’s wife) to talk to her husband to use his influence to re-absolve him
into the business.
xiv. That after discussion with LATE ENGR. YUSUF IKOLO coupled with plea from
some elders in the market, I was constrained to re-absolve the 2nd Claimanat.
xv. That upon the re-absolving of the 2nd Claimant to the business, the 2nd
Claimant continued persisted in his dubious act and went to the extent of
writing a petition against myself and LATE ENGR. YUSUF IKOLO himself.
xvi. That following the petition, I and LATE ENGR. IKOLO were invited by the
police and upon hearing their explanations, the police advised me and LATE
ENGR. YUSUF IKOLO to expel the 2nd Claimant from the business.
6. That in 2nd claimant’s bid to sideline me, he intiated different criminal action against
the defendant at the Lagos Magistrate court and Ifo Magistrate Court in charge no:
MIF/659C/2016, which judgement was given on 22nd day of January, 2021 in which
His Worship F. A. IROKO discharged and acquitted me of all allegation in the Six (6)
count charge brought against the me. Copy of the certified true copy of the
Judgment is hereby pleaded and would be relied on at the trial of this suit.
7. That in the proceedings at the Lagos Magistrate Court and Ifo Magistrate Court
aforementioned, the 2nd claimant himself gave evidence to the effect that I am his
partner in MURRAINE PROJECTS. The record of proceedings of the 20th day of
October, 2017 is hereby pleaded and would be relied on at the trial of this suit.
8. That the Police in the course of their investigation to uncover money illegally
collected from the account of Murraine Projects; sought an order of court that the
affected banks i. e. ACCESS BANK NIG. PLC and FIRST BANK NIG. PLC furnish
information through the investigating Police officer of the state criminal
investigation department on the respective account of MURRAINE PROJECTS
maintained with the banks. The copy of the certified true copy of the enrollment of
order and the request for same dated 27 th May, 2022 are hereby pleaded and be
relied on at the trial of this suit.
9. I will contend, at or before the trial of this case, that the Claimants do not have the
legal right to institute the instant action against me.
10.I will also contend further that the Claimants’ action as constituted has not
disclosed any cause of action against me, and ought to be struck out.
11.I state that the Claimants are not entitled to any of the claims contained in
paragraph 21 of the Statement of Claim, and I pray this Honourable Court to
dismiss the Claimants’ claims for being frivolous, vexatious and lacking in merit.
12.I depose to this Written Statement on Oath conscientiously believing the contents
to be correct and in accordance with the Oaths Law of Ogun State of Nigeria.
……………………………
DEPONENT
SWORN TO at the High Court Registry, Ifo, Ogun State
This …………… day of ……………………………….. 2023
BEFORE ME
COMMISSIONER FOR OATHS
IN THE HIGH COURT OF OGUN STATE
IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO: HCT/143/2021
BETWEEN:
1. MRS. AGNES IKOLO
(Trading under the name and style of MURAINE PROJECT) CLAIMANTS/RESPONDENTS
2. MR. TOCHUKWU OKAFOR
AND
MR. DELE OLORUNFEMI ……………………… DEFENDANT/APPLICANT
AMENDED STATEMENT OF DEFENCE
SAVE AND EXCEPT as hereinafter expressly admitted the Defendant denies each and
every allegation of fact contained in the Claimants’ Statement of Claim as if each were
specifically set out and denied seriatim.
1. The Defendant admits paragraph 1 of the Statement of Claim.
2. The Defendant denies paragraph 2 of the Statement of Claim and puts the
Claimants to strict proof of the same.
3. The Defendant admits paragraphs 3-10 inclusive, of the Statement of Claim.
4. The Defendant admits paragraph 4 of the Statement of Claim to the extent that a
Contract was awarded by the Ifo Local Government Area of ogun State on 7 th
January, 2010 to build Ultra-modern shops at Agbado market, but avers further
that the defendant brought in LATE YUSUF IKOLO as a partner using the name
MURRAINE PROJECTS.
5. The Defendant denies paragraph 11 of the Statement of Claim and puts the
Claimants to strict proof thereof.
6. The Defendant puts the Claimants to strict proof of paragraph 12 of the Statement
of Claim.
7. The Defendant denies paragraph 13 of the Statement of Claim and subjects the
Claimants to strict proof of the same.
8. The Defendant admits paragraph 14 of the Statement of Claim.
9. The Defendant denies paragraphs 15-19, inclusive, of the Statement of Claim and
puts the Claimants to strict proof of the averments therein.
10.Further to the above, the Defendant states that the true facts of the matter are as
follows:
i. It was the Defendant who sourced the contract from the Ifo Local
Government Area for the building of ultra-modern shops at Agbado
Market, and carried out all the negotiations relating to the contract,
starting from sometime in 2009.
ii. The Defendant was able to do this because he had all the necessary
experience in the field, which he gained from being part of the team that
built M.K.O. Abiola Market, Otubu Bus Stop Agege, Lagos, Sabo Market,
Yaba, Lagos, White sand Market, Oyingbo, Lagos, and Imota Market, via
Ikorodu, Lagos.
iii. It was the Defendant who did all the documentation towards securing the
contract, including the survey of the market, bill of quantities and the
proposal, and singlehandedly paid for them. The Defendant at this period
had not known or met LATE MR. YUSUF IKOLO.
iv. That it was the defendant that met with the relevant elders of the Agbado
Community to seek their blessings and support for the construction work.
The Claimants, particularly the 2nd claimant and LATE ENGR. YUSUF
IKOLO was not in the picture then. The defendant shall at the trial of this
suit plead and rely on photograph of himself and elders of Agbado
community.
v. It was after all the above had been done, including defense of the project
(contract), that the Defendant got to meet LATE ENGR YUSUF IKOLO,
who was introduced to him by one Alhaji Kazeem, who said Yusuf Ikolo
was an engineer and was his class mate, and encouraged the Defendant to
work with him, and gave the Defendant his phone number.
vi. The Defendant called Engineer Ikolo and fixed a meeting with him, and in
the course of their discussion, the Defendant discovered that he was from
the same Akoko area of Ondo State. They then decided to use Engineer
Ikolo’s registered company – Muraine Projects – for the project, and the
Defendant went ahead to conclude all the required documentation for the
contract. He also opened an account with Access Bank, Kola branch in the
name of the company and was the one signing all the cheques. The
contract was finally given in the name of the company in 2010, and the
execution of the contract was carried out jointly by the Defendant and
Engineer Ikolo (now late)
vii. It was one of the partners working with the Defendant and Engineer
Ikolo on the project, in the person of Mr. Vincent Akinyemi, who later
introduced the 2nd Claimant to the Defendant, that as a spare parts dealer
at Sango market, he would be of help in talking to other traders
concerning the project.
viii. Throughout the life time of Engineer Yusuf Ikolo, he had a smooth and
cordial working relationship with the Defendant, and the 1st Claimant was
not in the picture at all. It was some years after the demise of Engineer
Ikolo sometime in 2016 that the Claimants started the plan to sideline the
Defendant in the business, which was orchestrated by the 2nd Claimant.
ix. That not long after the 2nd Claimant was introduced into the business, he
started perpetuating act which amongst others include fraudulent
withdrawal from the business account.
x. That the 2nd Claimant at a point collected the sum of ₦650,000 (Six
Hundred and Fifty Thousand Naira) without the knowledge of the
defendant and LATE ENGR. YUSUF IKOLO.
xi. This prompted the defendant to order the suspension of the 2 nd defendant
from the business.
xii. That with the suspension, the 2nd Claimant started visiting the house of
LATE ENGR. YUSUF IKOLO to plead with the 1 st claimant (LATE ENGR.
YUSUF IKOLO’s wife) to talk to her husband to use his influence to re-
absolve him into the business.
xii. That after discussion with LATE ENGR. YUSUF IKOLO coupled with plea
from some elders in the market, the defendant eas constrained to re-
absolve the 2nd Claimanat.
xiv. That upon the re-absolving of the 2nd Claimant to the business, the 2nd
Claimant continued persisted in his dubious act and went to the extent of
writing a petition against the defendant and LATE ENGR. YUSUF IKOLO
himself.
xv. That following the petition, the defendant and LATE ENGR. IKOLO were
invited by the police and upon hearing their explanations, the police
advised the defendant and LATE ENGR. YUSUF IKOLO to expel the 2nd
Claimant from the business.
11. The Defendant avers that in his bid to sideline the defendant, intiated different
criminal action against the defendant at the Lagos Magistrate court and Ifo
Magistrate Court in charge no: MIF/659C/2016, which judgement was given on 22nd
day of January, 2021 in which His Worship F. A. IROKO discharged and acquitted
the defendant of all allegation in the Six (6) count charge brought against the
defendant. Copy of the certified true copy of the Judgment is hereby pleaded and
would be relied on at the trial of this suit.
12. That in the proceedings at the Lagos Magistrate Court and Ifo Magistrate Court
aforementioned, the 2nd claimant himself gave evidence to the effect that the
defendant is his partner in MURRAINE PROJECTS. The record of proceedings of the
20th day of October, 2017 is hereby pleaded and would be relied on at the trial of
this suit.
13.That the Police in the course of their investigation to uncover money illegally
collected from the account of Murraine Projects; sought an order of court that the
affected banks i. e. ACCESS BANK NIG. PLC and FIRST BANK NIG. PLC furnish
information through the investigating Police officer of the state criminal
investigation department on the respective account of MURRAINE PROJECTS
maintained with the banks. The copy of the certified true copy of the enrollment of
order and the request for same dated 27 th May, 2022 are hereby pleaded and be
relied on at the trial of this suit.
14.The Defendant will contend, at or before the trial of this case, that the Claimants do
not have the legal right to institute the instant action.
15. The Defendant shall contend further that the Claimants’ action as constituted has
not disclosed any cause of action against him, and ought to be struck out.
16. The Defendant avers that the Claimants are not entitled to any of the claims
contained in paragraph 21 of the Statement of Claim.
17. WHEREOF the Defendant prays this Honourable Court to dismiss the Claimants’
claims in theirs for being frivolous, vexatious and lacking in merit.
Dated this …………………. day of …………………………… 2023
ADEWALE SURAJ, ESQ.
ABIOLA ALANI ESQ.
DEFENDANT/APPLICANT’S COUNSEL
S. A. ADEWALE & CO.
FOR SERVICE ON: Suite 13, 1st Floor, Amop Complex,
THE CLAIMANTS/RESPONDENTS 59, Agbado-Ijaiye Road
C/O THEIR COUNSEL Opposite First Bank Plc.
CHIEF GODWIN O.D. OKEKE Ijaiye-Ojokoro, Lagos State.
G.O.D. OKEKE & CO. Tel: 08055265072
AGOZIE CHAMBERS Email: surajuadewale40@gmail.com
T.K.B. SHOPPING COMPLEX c/o 3, Adeyeri Close,
NO. 1, IDIROKO ROAD Agbado Crossing,
SANGO – OTA Ogun State.
OGUN STATE
TEL: 08033157372, 08179772053
IN THE HIGH COURT OF OGUN STATE
IN THE IFO JUDICIAL DIVISION
HOLDEN AT IFO
SUIT NO: HCT/143/2021
BETWEEN:
2. MRS. AGNES IKOLO
(Trading under the name and style of MURAINE PROJECT) CLAIMANTS/RESPONDENTS
2. MR. TOCHUKWU OKAFOR
AND
MR. DELE OLORUNFEMI ……………………… DEFENDANT/APPLICANT
LIST OF DOCUMENTS
5. Photographs of Defendants and Elders of Agbado Community.
6. Certified true copy of judgement by His Worship F. A. IROKO, dated 22 nd January,
2021.
7. Certified true copy of Record of proceedings dated 20th October, 2017.
8. Copy of request for copy of enrolment of order dated 27th May, 2022 and Certified
true copy of Order dated 7th March, 2022.
Dated ………... day of ………………………………………………, 2023
ADEWALE SURAJ, ESQ.
ABIOLA ALANI ESQ.
DEFENDANT/APPLICANT’S COUNSEL
S. A. ADEWALE & CO.
Suite 13, 1st Floor, Amop Complex,
59, Agbado-Ijaiye Road
Opposite First Bank Plc.
Ijaiye-Ojokoro, Lagos State.
Tel: 08055265072
FOR SERVICE ON: Email: surajuadewale40@gmail.com
THE CLAIMANTS/RESPONDENTS c/o 3, Adeyeri Close,
C/O THEIR COUNSEL Agbado Crossing,
CHIEF GODWIN O.D. OKEKE Ogun State.
G.O.D. OKEKE & CO.
AGOZIE CHAMBERS
T.K.B. SHOPPING COMPLEX
NO. 1, IDIROKO ROAD
SANGO – OTA
OGUN STATE
TEL: 08033157372, 08179772053
