1. That on the 14th of August, 2015 they accompanied their father Ikyase Chia ( the deceased ) to a mortuary in Gboko, Benue State Nigeria to remove the corpse of their grand father Late Pa Shiorbo Chia for burial when members of the Nigeria Police Force ( the Security apparatus of the Respondents burst into the place. 2. That the agents of the Nigerian Police arrested the deceased, beat him up and put him in their Hilux. 3. Furthermore, they handcuffed the deceased ( who was curious as to why he was being arrested ) and dragged him to their unmarked vehicle and sped off; after shooting sporadically into the air to scare off any intruder 4. The brothers of the deceased, Tarzaa Shiorbo, Teryila Shiorbo who were at the scene of the arrest used their vehicle to trail the Police Officers. 5. That while the Police Vehicle, Ikyase Chia was seated in between four (4) Police Officers who were fully armed with AK 47 Riffles. 6. That when the officers got to a village called Abiem near Makurdi the Benue State Capital, they stopped at one lonely junction and ordered Ikyase Chia out of the vehicle 7. That as Ikyase Chia was struggling to stand and go down from the Vehicle, one of the officers forcefully dragged him out and thereafter started beating him, kicking and hitting him with the head of his gun 8. That two other officers joined in the beating and kicking of Ikyase Chia and when Ikyase Chia fell down, they heard two gun shots before the Police officers bundled him in an unconscious state in the pool of blood to their (police) vehicle again; covered him with fresh leaves and drove off to Benue State Police Command Headquarters, Makurdi. 9. That Tarza and Teryila who had been trailing the police also continued without the police knowing until they got to the Police Headquarters Makurdi 10.That when some of the applicants and other family members went to the Police Headquarters to ask for their father’s where about, the police to their greatest surprise refused to attend to them or disclose the whereabout of Ikyase Chia. 11.That it was later the applicants got a clue from a Good Samaritan at the Police Station which led to the discovery of the corpse of Ikyase Chia in the morgue at the Federal Medical Centre Makurdi. 3

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