No: FHC/ABJ/CR/3 19/2015, Charge No: FHC/HC/CR/42/2015 and Charge No: FHC/HC/CR/43/2015. 17.That bail has been granted in all the Charges filed above. The inability of the Applicant to fulfill the bail conditions on time made him spend more time in detention. However, upon the release of the Applicant, the Department of State Security Service deemed it necessary to investigate the Applicant on suspicion to have committed or planning to commit offences bordering on National Security of the Defendant. 18.That it is justifiable under the Defendant’s law to detain the Applicant as the allegation borders on offence which affects the National Security of the Federal Republic of Nigeria, and the investigation so far has revealed that more weapons and ammunition are still in different locations in the territory of the Defendant and the Applicant is unwilling to reveal. 19.The Applicant being the former National Security Adviser has varieties of means to substantially intervene with his investigation and put the National Security of the Defendant and other neighbouring West African nations in jeopardy. 20.That the Federal Republic of Nigeria is committed to the protection of life and property of all Residents and Citizens of the Federal Republic of Nigeria since it is one of her obligation under the African Charter on People and Human Right. Defendant also relied on the following documents attached to the Defendant’s amended defense and Marked Exhibits FRN1 — FRN4: A letter titled: Re Request for clarification on issuance of license to private persons to own Tarvor Assault rifles dated 4" April 2016. 20

Select target paragraph3