 Some aspects of the Plaintiffs claim are res judicata while some are statute barred;  The Plaintiffs suit is speculative and does not disclose a reasonable cause of action;  The suit constitutes an abuse of Court process;  That there’s a feature in the Plaintiff’s suit which robs this court of jurisdiction, and  That the subject matter of the Plaintiff’s suit a subject of their domestic court. In defence to the Plaintiffs Application, the Defendant denied each and every material allegation of fact contained in the Plaintiffs’ application and puts the Plaintiffs’ to the strictest proof of those facts. Defendant further states that the facts relied upon by the Plaintiffs are false and made with the sole intention of misleading the court. That the award of operation license in the oil sector in Nigeria is done in compliance with global standards and are not made to individuals or families but to companies with requisite experience in the operation of oil business. That the award of oil blocs are done in line with the relevant laws regulating the operations of the oil sector and that the procedure for the issuance and renewal of licenses is prescribed by law. That the Petroleum Act of the Federal Republic of Nigeria has laid down guidelines on the necessary requirements needed before license is granted and the agency charged with the issuance of license complies with the due process. That the 9