ii. iii. SPECIAL DAMAGES in the amount of N100,089,140.00 (One Hundred Million, Eighty Nine Thousand, One Hundred and Forty Naira) only, being the total cost of building 3 new houses of the same and similar attributes with the 3 houses destroyed by the Respondents including household items, furniture, electronics, clothing, certificates, landed documents, receipts, farm tools, my traditional Chieftaincy beads and regalia, one complete small scale palm oil press plant, cash crops and orchards, indeed the entire personal property of the Applicants’. EXEMPLARY DAMAGES based upon the extreme ill will, recklessness, insensitivity, malice and deprivation of Applicants’ fundamental rights exhibited by the Respondents’ against the Applicants’ in the sum of N500,000,000.00 ( Five Hundred Million Naira) only. The Plaintiff in order to establish his claim, presented three witnesses who gave oral testimony. The Plaintiff witness 1 was the 1st Plaintiff himself who after adopting his witness statement on oath narrated how on the 19th of December, 2012, an agency called the Imo security network with armed Policemen and Soldiers arrested his son, one Obinna Kasarachi Onwuham. The Security agents came in the company of one Paul Obieze Amaliri and one Marshall Ifeanyi Akujinwa (alias Dauda). The witness further alleged no one informed him of the reason for the visit but that one of the Security officers stated that his son is suspected of being a kidnapper. He also stated that they entered his house, the part allotted to his son, Obinna, removed all the household item from the house and burnt them and at the same time demolished The House. They also demolished all other structures within the compound, including economic trees. They took away the son and till date he does not know his where about. According to him the demolition took place in 2012, 2013 and 2014. The second Plaintiff’s witness who identified himself as Justus Eromonsele is a qualified Quantity Surveyor. He stated his qualifications as Bachelor of Science Quantity Surveying from the Ahmadou Bello University Zaria, Nigeria and an Associate member of the Nigerian Institute of Quantity Surveyors. He stated that he was contracted to evaluate the buildings of the Plaintiff that was demolished. He evaluated same and submitted a report signed by him. He identified the report with his signature. The Report was tendered in evidence and marked as Exhibit 1. 6