unlawfully detain the Applicant without any justification since 5" November,
2015.
4.
A DECLARATION
that it is an unlawful violation of the Applicant’s
Human Rights to dignity of human person, privacy and family life guaranteed
and protected rights under Section 34 and 37 of the Constitution of the Federal
Republic of Nigeria 1999 (As amended); Article 17 of the International Covenant
on Civil and Political Rights and Articles 12 of the Universal Declaration of
Human
Rights
a most
egregious
violation of the treaty obligations
of the
defendant under and by virtue of its being a signatory to the above listed legal
instruments,
for the Defendant’s
agents, privies, servants to have unlawfully
detained the Applicant under a de-humanizing condition since 5" November,
2015.
The Applicant relies on all processes already filed before this Court and adopt
the facts therein and incorporate same as if they were repeated herein and submits
that the detention and continued detention of the Applicant has no legal or any
judicial procedure in both domestic law of the Federal Republic of Nigeria and
any International Law/Treaty/Convention;
The Defendant also filed an amended statement of defense in which it stated as
follows:
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