- 10 Noel’s phone calls and the Plaintiff and Noel were not allowed entry at the gate of the DSS Office when they arrived there. XLVI. The Plaintiff states that after reporting at DSS office on the 27 th Jan, 2015, he caused his Solicitors (Jimmy & Jimmy Associates) to write to the Director General of DSS complaining about the unlawful arrest, detention and inhuman treatment mete out to him. XLVII. The Plaintiff avers that the Solicitor’s letter was dated 11 th February, 2015 was ignored by DSS and even the second letter dated 10th March, 2015 was equally ignored. XLVIII. The following is a graphic detail of what transpired between the Plaintiff and Agents of the Defendants, viz: Plaintiff was arrested without warrant. Plaintiff was bundled into a waiting car without any disclosure of the offence against him. He was whistled away against the midnight to a lonely area in Abacha Road, Mararaba in search of Shola. He was stripped of his belt, wristwatch, shoes and telephone handset He was left bear footed. He was lumped together with other detainees He was blindfolded for many hours He was detained from Saturday 6PM to Monday 6PM He was refused access to his family and starved of food for three days He was blindfolded, handcuffed and made to sleep on hard floor for two nights. Insults, harassments, intimidations and abuses were constantly hurled at him. a) b) c) d) e) f) g) h) i) j) k) ORDERS SOUGHT BY THE APPLICANT: 1) A DECLARATION that the arrest and detention of the Plaintiff at Office of State Security Service, Aso Drive, Asokoro, Abuja from 24 th to 26th January, 2015 by the Defendant is arbitrary, illegal, unlawful and constitutes a gross violation of the Plaintiff’s fundamental rights to personal liberty and freedom of movement guaranteed under Articles 6 and 12 of the African Charter on Human & People’s Rights (Ratification and Enforcement) Act, Cap. IV Laws of the Federation of Nigeria, 1990.

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