EASY READ STUDY SHOP

Course: Criminal Litigation

EXAMS FORMAT

“Focus Drafts”
Focus drafts
 Charges
 Police bail
 Court bail
 Affidavit in support of bail application
 Omnibus grounds of appeal

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COURT/ TYPE OF COMPLAINANT REFERENCE PARAGRAPH (S) SIGNATURE/
LOCATION CHARGE SHEET NUMBER FRANKING

MAGISTRATE CHARGE BY COMMISSIONER CASE NO 3 PARAGRAPHS; PRESIDING

COURT FIRST OF POLICE 1. INTRODUCTION MAGISTRATE
NORTH INFORMATION 2. CHARGE(MAIN
REPORT BODY)
3. DIRECTION
MAGISTRATE CHARGE COMMISSIONER CHARGE 1 PARAGRAPH INVESTIGATING
COURT OF POLICE NO 1. Charge(main POLICE OFFICER
SOUTH body)

HIGH COURT CHARGE THE STATE CASE NO 1 PARAGRAPH ATTORNEY

NORTH CHARGE(MAIN BODY) GENERAL OF
STATE
HIGH COURT INFORMATION THE STATE CASE NO 2 PARAGRAPHS; ATTORNEY
NORTH 1. STATEMENT OF GENERAL OF
(TARABA OFFENCE STATE
AND 2. PARTICULARS
ADAMAWA) OF OFFENCE
HIGH COURT INFORMATION THE STATE CHARGE 2 PARAGRAPHS; ATTORNEY
SOUTH NO 1. STATEMENT OF GENERAL OF
OFFENCE STATE
2. PARTICULARS
OF OFFENCE

HIGH COURT INFORMATION THE STATE OF CHARGE 2 PARAGRAPHS; ATTORNEY

LAGOS LAGOS NO 1. STATEMENT OF GENERAL OF
OFFENCE STATE
2. PARTICULARS
OF OFFENCE

HIGH COURT INFORMATION FEDERAL CHARGE 2 PARAGRAPHS; ATTORNEY

FCT (ABUJA) REPUBLIC OF NO 1. STATEMENT OF GENERAL OF
NIGERIA OFFENCE FEDERATION
2. PARTICULARS
OF OFFENCE

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FEDERAL CHARGE FEDERAL CHARGE 1 PARAGRAPH ATTORNEY
HIGH COURT REPUBLIC OF NO CHARGE(MAIN BODY) GENERAL OF
OF NIGERIA NIGERIA FEDERATION

TIPS OF CHARGES IN BAR EXAMS

 Take note of the instructing authority; if it is Attorney GENERAL OF STATE the court is likely to be
the State High court; where it is ATTORNEY GENERAL OF FEDERATION, it likely to be the Federal
High court or High court of the FCT.
 Take note of the location; it determines whether the charge sheet will be by Charge or Information,
but once it is Federal high court irrespective of location it must be by charge
 Take note of the offence, property and victims; that is if one offence is committed against more
than one victim, they should all be placed in a separate count or list of item stolen should be placed
on separate count. See the instance below;
On August 5, 2017, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus
who both reside at No. 25 Odo-dono Street, Calabar, Cross
River State, Nigeria were arrested by men of the Criminal
Investigation Department of Nigeria Police Force, Calabar.
Their arrest was in connection with the offences of procuring
Miss Martina Opaku, 18 years old, Miss Rosemary Idiba, 17
years old and Miss Eteng Okon, 16 years old, all of No. 25,
Sabo Street, GRA, Calabar for prostitution at Independence
Hotel, No.1, Independence Road, Calabar, Cross River State,
Nigeria.
The count should read thus;
COUNT 1
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at No 25 Sabo Street, GRA,
Calabar in the Calabar Judicial Division procured 18 years old Miss Martina Opaku for prostitution and
thereby committed an offence punishable under section 15 (a) of Trafficking in Persons (Prohibition)
Law Enforcement and Administration Act, 2003 (as amended).
COUNT 2
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at No 25 Sabo Street, GRA,
Calabar in the Calabar Judicial Division procured 17 years old Miss Rosemary Idiba for prostitution and
thereby committed an offence punishable under section 15 (a) of Trafficking in Persons (Prohibition)
Law Enforcement an Administration Act, 2003 (as amended).
COUNT 3
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at No 25 Sabo Street, GRA,
Calabar in the Calabar Judicial Division procured 16 years old Miss Eteng Okon for prostitution and
thereby committed an offence punishable under section 15 (a) of Trafficking in Persons (Prohibition)
Law Enforcement an Administration Act, 2003 (as amended).
Note in the above instance, procure was repeated thrice to reflect the number of
victims.
 Take note of the offenders; if an offence is committed and one or more did not take part,
kindly join him to the offence regardless unless it is charge for Rape and Reckless Driving.

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  Take note of the proper arrangement of the count or charge; The Acronyms of the content of
a count or Charge are (ADPOPVS)
A- NAME OF ACCUSED
D-DATE OF COMMISSION OF THE OFFENCE
P- PLACE OF COMMISSION/ JURISDICTION
O- OFFENCE
P- PROPERTY
V- VICTIMS
S- SECTION OF LAW
Note where it is information the “S” moves into the statement of offence and you are left
with “ADPOPV” in the particulars of offence.

CONTENT OF A CHARGE SHEET

1. Heading
These contain basically three (3) features i.e. the name of the court, the division of the court and the
location of the court, all these forms the heading of the court.
For instance:
Magistrate Court
IN THE MAGISTRATES’ COURT OF KANO STATE
IN THE KANO MAGISTERIAL DISTRICT
HOLDEN AT KANO
High Court
IN THE HIGH COURT OF LAGOS STATE
IN THE LAGOS JUDICIAL DIVISION
HOLDEN LAGOS
High Court of Federal Capital Territory
IN THE HIGH COURT OF FEDERAL CAPITAL TERITORY
IN THE ABUJA JUDICIAL DIVISION
HOLDEN AT ABUJA
Federal High Court
IN THE FEDERAL HIGH COURT OF NIGERIA
IN THE KANO JUDICIAL DIVISION
HOLDEN AT KANO

2. Reference Number
This is largely dependent on the location of the court i.e. where the court is situate;
 In the southern part of Nigeria it reference number is indicated as “Charge number”
 In Lagos it reference number is indicated as “Charge number”
 In the Federal Capital Territory it reference number is indicated as “Charge number”
 In the North it is indicated as “Case Number”.
 In the Federal High Court in Nigeria it reference number is indicated as “Charge number”

It is usually situated at the right top flank of the charge sheet and it is immediately after the heading.
Note; the reference number in the Federal High court still remains as Charge number in respective of the
location i.e. north or south; The sole reason for this is the governing statute is that of the ACJA 2015.

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 3. Parties
This is dependent on the court and the Location in which the charge is filed. For instance:
 In the Magistrate Court the complainant is usually the “COMMISSIONER OF POLICE”
 In the High Court the complainant is usually “THE STATE”.
 In Lagos state High Court the Complainant is “THE STATE OF LAGOS”.
 In the High Court of the Federal Capital Territory, the Complainant is the “FEDERAL REPUBLIC OF
NIGERIA”
 In The Federal High Court , the Complainant is the “FEDERAL REPUBLIC OF NIGERIA”
Note the title of the offender depends on the location of the court and the Jurisdiction of the court. For
instance;
 In the South, Lagos ,Federal Capital Territory and Federal High Court they are refer to as
Defendant
 In North they are refer to as Accused.
Example:
BETWEEN
THE STATE OF LAGOS ……………………….. COMPLAINANT
AND
FEMI ADEYEMI ……………………………………………….. DEFENDANT

In the North
BETWEEN
THE STATE ……………………….. COMPLAINANT
AND
FEMI ADEYEMI …………………… ACCUSED

4. Preamble
This is mainly contained in the High Court Charges usually where it is by information. However for the
purpose of the bar finals, preamble in the High court in the north is not mandatory. For instance:
At the session Holden at Lagos judicial division on the ……day of
……..2018 the Court is informed by the Attorney-General on behalf of the
State that:
FEMI ADEYEMI (m)
is charged with the following offences:
5. Main Body
These contain the crime in which the Accused person or Defendant is alleged off. The main body of a
charge sheet depends on the type of charge,

a. By Charge
Charge one
That you OYEMECHI THANKGOD on or about 7th March 2014 at No 4, Church Road, Sabon
Geri, Kano in the Kano Magisterial District abducted one Haruna Musa and thereby
committed an offence punishable under section 273 of Penal Code Law, Laws of Kano
State and triable by Senior Magistrate Court

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b. By Information
COUNT 1
STATEMENT OFFENCE
Stealing contrary to section 390 of the Criminal Code Law of Lagos State
PARTICULARS OF OFFENCE
FEMI ADEYEMI on or about 20th August, 2014 at No. 5, Awolowo Road, Ikoyi, Lagos in the
Lagos Judicial Division stole a Nokia 3310 Hand Set property of Mr. Daramola Stanley.

c. Charge by First Information Report

I, Mari Ibrahim, Senior Magistrate Grade I charge you OYEMECHI THANKGOD as follows
(introduction)
CHARGE 1
That you OYEMECHI THANKGOD on or about 7th March 2017 at No 4, Church Road,
Sabon Geri, Kano in the Kano Magisterial District abducted one Haruna Musa and
thereby committed an offence punishable under section 273 of Penal Code Law, Laws of
Kano State and triable by Senior Magistrate Court.(main body)
I hereby direct that you be tried for the said offence by the said court. (Directional)
6. Date
The date of the preparation of the charge sheet must be indicated. For instance;
Dated this ……………….day of ………….. 2018

7. Name and signature of the person who drafts

The signature of the person who drafts the charge must be indicated on the charge sheet.
 In the Magistrate court it is drafted by “Investigating Police Officer”.
 In the Magistrate court in the North it is drafted by the “Presiding Magistrate”
 In the Magistrate Court in the Federal Capital Territory it is drafted by both “Investigation Police
Officer” or “Presiding Magistrate”
 In the High court it is drafted by “Attorney General or Law officers in his office”

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 EXAMPLE OF CHARGE SHEET BY THE USE OF QUESTIONS

QUESTION
On August 5, 2017, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus who both reside at No. 25 Odo-dono
Street, Calabar, Cross River State, Nigeria were arrested by men of the Criminal Investigation
Department of Nigeria Police Force, Calabar. Their arrest was in connection with the offences of
procuring, using, offering and deceitfully inducing Miss Martina Opaku, 18 years old, Miss Rosemary
Idiba, 17 years old and Miss Eteng Okon, 16 years old, all of No. 25, Sabo Street, GRA, Calabar for
prostitution at Independence Hotel, No.1, Independence Road, Calabar, Cross River State, Nigeria. The
suspects were alleged to have confined the girls for prostitution at the Hotel. The Police after
investigation forwarded the case file to the Attorney-General of the Federation who has instructed you,
as a Principal State Counsel in his office, to draft the charge, for arraigning the suspects in court.
Draft the relevant charge(s) for filing at the Federal High Court.

THE LAW
TRAFFICKING IN PERSONS (PROHIBITION) LAW ENFORCEMENT AND ADMINISTRATION ACT, 2003 (AS
AMENDED)
SECTION:
“15 Any person who:-
a) Procures, uses or offers any person for prostitution or the production of pornography, or for
pornographic performances;
b) Procures, uses or offers any person for the production and trafficking in drugs;
c) Traffics any person for the purpose of forced or compulsory recruitment, use, in armed conflicts;
Commits an offence and is liable on conviction to imprisonment for fourteen years without an option of
fine”
“19 (1) any person who:-
b) By force compels or by any deceitful means induces any person to go from any place, commits an
offence and is liable on conviction to imprisonment for ten years or to a fine not exceeding N200,
000.00 or both.
c) Confines or detains another person in any place against his will, or otherwise unlawfully deprives
another person of his personal liberty, commits an offence and is liable on conviction to imprisonment
for five years or to a fine of N100,000 or both”

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ANSWER QUESTION 1
IN THE FEDERAL HIGH COURT OF NIGERIA
IN THE CALABAR JUDICIAL DIVISION
HOLDEN AT CALABAR
CHARGE NO.:_______ ½ MARK
BETWEEN
FEDERAL REPUBLIC OF NIGERIA _______ COMPLAINANT
AND
1. MRS. CHICHI BASSEY – DEFENDANTS
2. MR. NGOZI ITSIFANUS

COUNT 1
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at No 25 Sabo Street, GRA,
Calabar in the Calabar Judicial Division procured 18 years old Miss Martina Opaku for prostitution and
thereby committed an offence punishable under section 15 (a) of Trafficking in Persons (Prohibition)
Law Enforcement and Administration Act, 2003 (as amended).

COUNT 2
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at No 25 Sabo Street, GRA,
Calabar in the Calabar Judicial Division procured 17 years old Miss Rosemary Idiba for prostitution and
thereby committed an offence punishable under section 15 (a) of Trafficking in Persons (Prohibition)
Law Enforcement an Administration Act, 2003 (as amended).

COUNT 3
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at No 25 Sabo Street, GRA,
Calabar in the Calabar Judicial Division procured 16 years old Miss Eteng Okon for prostitution and
thereby committed an offence punishable under section 15 (a) of Trafficking in Persons (Prohibition)
Law Enforcement an Administration Act, 2003 (as amended).

COUNT 4
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at Independence Hotel, No.1
Independence Road, Calabar, Cross River State, in the Calabar Judicial Division used 18 years old Miss
Martina Opaku for prostitution and thereby committed an offence punishable under section 15 (a) of
Trafficking in Persons (Prohibition) Law Enforcement an Administration Act, 2003 (as amended).

COUNT 5
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at Independence Hotel, No.1
Independence Road, Calabar, Cross River State, in the Calabar Judicial Division used 17 years old Miss
Rosemary Idiba for prostitution and thereby committed an offence punishable under section 15 (a) of
Trafficking in Persons (Prohibition) Law Enforcement an Administration Act, 2003 (as amended).

COUNT 6
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at Independence Hotel, No.1
Independence Road, Calabar, Cross River State, in the Calabar Judicial Division used 16 years old Miss

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Eteng Okon for prostitution and thereby committed an offence punishable under section 15 (a) of
Trafficking in Persons (Prohibition) Law Enforcement an Administration Act, 2003 (as amended).

COUNT 7
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at Independence Hotel, No.1
Independence Road, Calabar, Cross River State, in the Calabar Judicial Division offered 18 years old Miss
Martina Opaku for prostitution and thereby committed an offence punishable under section 15 (a) of
Trafficking in Persons (Prohibition) Law Enforcement an Administration Act, 2003 (as amended).

COUNT 8
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at Independence Hotel, No.1
Independence Road, Calabar, Cross River State, in the Calabar Judicial Division offered 17 years old Miss
Rosemary Idiba for prostitution and thereby committed an offence punishable under section 15 (a) of
Trafficking in Persons (Prohibition) Law Enforcement an Administration Act, 2003 (as amended).

COUNT 9
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at Independence Hotel, No.1
Independence Road, Calabar, Cross River State, in the Calabar Judicial Division offered 16 years old Miss
Eteng Okon for prostitution and thereby committed an offence punishable under section 15 (a) of
Trafficking in Persons (Prohibition) Law Enforcement an Administration Act, 2003 (as amended). ½ mark

COUNT 10
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at Independence Hotel, No.1
Independence Road, Calabar, Cross River State, in the Calabar Judicial Division deceitfully induced 18
years old Miss Martina Opaku to prostitution and thereby committed an offence punishable under
section 19 (1) of Trafficking in Persons (Prohibition) Law Enforcement an Administration Act, 2003 (as
amended).

COUNT 11
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at Independence Hotel, No.1
Independence Road, Calabar, Cross River State, in the Calabar Judicial Division deceitfully induced 17
years old Miss Rosemary Idiba to prostitution and thereby committed an offence punishable under
section 19 (1) of Trafficking in Persons (Prohibition) Law Enforcement an Administration Act, 2003 (as
amended).
COUNT 12
That you, Mrs. Chichi Bassey and Mr. Ngozi Itsifanus on August 5, 2017 at Independence Hotel, No.1
Independence Road, Calabar, Cross River State, in the Calabar Judicial Division deceitfully induced 16
years old Miss Eteng Okon to prostitution and thereby committed an offence punishable under section
19 (1) of Trafficking in Persons (Prohibition) Law Enforcement an Administration Act, 2003 (as
amended).
Dated__________ this day of August 2017.
(Principal State Counsel
Federal Ministry of Justice
For: Hon. Attorney-General of the Federation.

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 QUESTION 2

IN THE MAGISTRATES COURT OF KOGI STATE IN THE OKENE JUDICIAL DIVISION SITING AT OKENE
CHARGE NO.__________
BETWEEN:
THE STATE ____________ CLAIMANT
AND
OBI DAUDA _______ DEFENDANT
I, Inspector Edet Umaru, accuse you, Obi Dauda as follows:-
Count 1
That you, Obi Dauda, on January 10, 2017, at Emirate Road, Okene within Okene Judicial Division,
fraudulently took the sum of ten thousand naira (N10,000) belong to Mallam Yaro Ayuba and thereby
committed and offence contrary to Section 287 of the Criminal Procedure Code Law of Kogi State and
triable by this court.
Signed________________
For: insp. Edet Umaru
Hon. Commissioner of Police
Kogi State Command
i. Serially point out the errors, if any, without redrafting in the charge sheet.

ANSWER TO QUESTION 2
 The heading of the Court should be in three lines. It should be in the Okene Magisterial District not
Judicial Division. It should be “Holden” at Okene not “Siting” at Okene.
 ‘Charge No’ is wrong. It should be ‘Case No’
 It should be ‘Commissioner of Police’ as ‘Complaint and not the State as ‘Claimant’
 Obi Daudu should be described as ‘Accused’ and not ‘Defendant’
 The introductory paragraph should contain the name of the Magistrate drafting the Charge as Police
does not draft charge in Magistrate’s Court in the North.
 It should not be ‘accused you’ but rather ‘charge you’
 ‘Count 1’ is wrong, it should be ‘Charge 1’
 In the body of the charge (2nd paragraph) it should be ‘Magisterial District’ and not ‘Judicial Division’
 In the body of the charge the description of the offence should be
 The third paragraph should not be merged together with the 2nd paragraph, thus “triable by this
Court is part of the 3rd paragraph.
 The signing authority is wrong; it should be the Magistrate who drafted the charge, with his name
and cadre.
 S.287 Penal Code Law NOT S.287 Criminal Procedure Code Law

ii. As the Defence Counsel, raise a preliminary objection in respect of the above charge, siting clearly
the ground(s) for your objection (without affidavit and written address).
ANSWER TO QUESTION 2 ii
The charge is bad for ambiguity; and The authority that drafted the Charge lacks the power to draft a
charge and commence an action before the court in the North, thus there is nothing before the Court,
see Olatunji v State (2000) FWLR (pt. 30) 2635. 1 mark

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iii. Assuming that the Prosecution’s application to amend the charge was granted by the Court, what
step(s) will the Court take before continuing with the trial?
ANSWER TO QUESTION 2 III
The following are the steps the court would take before continuing with trial;
 The court must read and explain the alteration of addition to the accused person and his plea
taken afresh. See section 208(2) CPC.
 Either the prosecutor or the accused person is entitled to an adjournment of proceeding
immediately with the trial, on the amended charge will be prejudicial to them. See section 209
and 210 CPC.
 A note of the order for amendment shall be endorsed on the charge, which in its amended form
is deemed to be the original charge.
 Either the prosecutor or the accused person may call or recall any witness who may have given
evidence to testify again. See section 211 CPC.

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QUESTION 3
On the 10th May 2017, Miracle, Udoh, and Ejike agreed to rob at the Everyday Super market located at
Rumola, Port Harcourt, Rivers state. On the 20th May 2017, the date fixed for the operation, Miracle had
an accident and could not turn up for the operation. At about 9:00 pm, the duo flagged down a taxi cab
along Aba road, Port Harcourt. The instructions to the driver were simple:
Take us to Everyday Super market located at Rumola, park exactly where we ask you to park. Leave
the engine on, because our assignment is short. When we are back in the cab, take off without
stopping for any one unless we ask you to do so!
Thus, the unsuspecting driver of the taxi cab with registration number AX 121ACD drove the duo to
Everyday Super market located at Rumola, Port Harcourt. The name of the driver is Mercy. At the gate to
the supermarket, the driver was asked to park while the passengers alighted. Udoh had a pistol concealed
in his pocket. Ejike knocked down the security man at the entrance to the super market with his baton
and stood over him. Udoh entered the super market and with his gun pointed at the sale girl and the
helpless customers emptied the safe. Before he could put all his money in his bag, he heard a whistle
blown by Ejike signalling the presence of the police. Udoh managed to escape with the loot through the
nearby window. Frightened by the presence of the police, the taxi driver drove away with his cab. The
security man sustained serious injury in his left arm. They have all been apprehended and the Honourable
Attorney General of Rivers state has asked you as state counsel to draft the charge(s) to enable him file
the information.

Draft the charge(s)

THE LAW
CRIMINAL CODE LAW OF RIVERS STATE
Section 402 (1)
Any person who commits the offence of robbery shall upon conviction be sentenced to imprisonment for
not less than 21 years.
Section 402 (2)
If any offender mentioned in subsection (1) is armed with any firearms or any offensive weapon or any
obnoxious or chemical materials or is in company with any person so armed; or; Section 402 (2) (b) Or
immediately before or immediately after the time of robbery, the said offender wounds any person, the
offender shall upon conviction be sentence to death.
Section 403 A
Any person who conspires with any person to commit an offence under Section 402 of this law whether
or not he is present when the offence was committed, shall be deemed to be guilty of the offence as a
principal offender”
Section 355
Any person who unlawfully assaults another and thereby does him harm is guilty of a felony, and is liable
to imprisonment for three years.
Section 516
Any person who conspires with any person to commit an offence whether or not he is present when the
offence was committed, shall be deemed to be guilty of a felony, and liable if no other punishment is
provided, to imprisonment for seven years.

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ANSWER TO QUESTION 3
IN THE HIGH COURT OF RIVERS STATE
IN THE PORT HARCOURT JUDICIAL DIVISION
HOLDEN AT PORTHARCOURT

CHARGE NO ………………
BETWEEN
THE STATE …………………………………………………………………………..………………….. COMPLAINANT
AND
MIRACLE,
UDOH,
EJIKE ………………………………………………………………………………………… DEFENDANTS
MERCY

At the session Holden at Port Harcourt rivers state on the …………. Day of………………., the court is been informed by
the Attorney General of the state on behalf of the state of the followings;
1. Miracle
2. Udoh
3. Ejike
4. Mercy
Are charged with the following offences.
COUNT 1
STATEMENT OF OFFENCE
Conspiracy contrary to section 516 of the Criminal Code Law of River State
PARTICULARS OF OFFENCE
Miracle, Udoh, Ejike and Mercy on or about On the 10th May 2017,at Rumola, Port Harcourt, in Port Harcourt
Judicial Division agreed to rob Everyday Super market at Rumola, Port Harcourt, Rivers state. 3
COUNT 2
STATEMENT OF OFFENCE
Armed Robbery contrary to section 402 (2) (b) of the Criminal Code Law of River State
PARTICULARS OF OFFENCE
Miracle, Udoh, Ejike and Mercy on or about On the 20th May 2017,at Everyday Super market Rumola, Port
Harcourt, in Port Harcourt Judicial Division while armed with fire arm and offensive weapons robbed Everyday
Super market at Rumola, Port Harcourt, Rivers state.
COUNT 3
STATEMENT OF OFFENCE
Assault contrary to section 355 of the Criminal Code Law of River State
PARTICULARS OF OFFENCE
Miracle, Udoh, Ejike and Mercy on or about On the 20th May 2017,at Everyday Super market Rumola, Port
Harcourt, in Port Harcourt Judicial Division unlawfully assaulted a security man by knocking him down thereby
causing a serious injury to his left arm at the gate of Everyday Super market at Rumola, Port Harcourt, Rivers
state.

Date this ……………………. Day of ………………………………2018 (date of exams)

Signed…………….
Principal State Counsel
For: Attorney General of River state
Ministry of Justice, Rivers state

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 POLICE BAIL
[Letter Head]
[Date of application]
The Divisional Police Officer,
Bwari Police Station,
Bwari, Abuja.

Sir,
Application for Bail
We are solicitor to Oyemechi Thank God of 21, Yugo, Bwari, Abuja who is currently under arrest and
detention at your station and shall latter be referred to as “Our Client”. We humbly apply for his bail on
self-recognition.
It is part of our client instruction that he is arrested and detained in connection with alleged offence of
stealing of one MR. Ajayi Shehun of no 3 origin street, Ekiti at central market Abuja

Sir, our client pledge to appear at the station anytime he is requested by you or any of your officers, we
recommend Lucky Chima Agor, roommate of our client of No. 4 Aba Road Port Harcourt, as surety for our
client’ bail
We remain.

Yours Faithfully
-------------------
Oboagwina Caleb
managing partner

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COURT BAIL

a. HIGH COURT IN THE NORTH uses Motion on Notice (N- North N- Notice)

IN THE HIGH COURT OF KANO STATE

IN THE KANO JUDICIAL DIVISION
HOLDEN AT KANO
CASE NO
BETWEEN
OLUWA SHEHUN… …………………………… ACCUSED/APPLICANT
AND
THE STATE ……………………… COMPLAINANT/RESPONDENT

MOTION ON NOTICE
BROUGHT UNDER SECTION 341(3) OF THE CRIMINAL PROCEDURE CODE LAW OF KANO STATE AND
SECTION 36(5) OF THE CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA 1999

TAKE NOTICE that this Honourable court shall be moved on the …..Day of ….2018 at the hour of 9
o’clock or so soon thereafter as counsel for the Accused/Applicant, OLUWA SHEHUN shall be heard
praying this Honourable court for:

1. AN ORDER admitting OLUWA SHEHUN the accused/applicant to bail;

ANY FURTHER ORDER OR ORDERS as this Honourable court may deem fit to make in the
circumstance.

Dated this ………. Day of …….. 20………….. [Date of the exams]

…..…………………..
Oyanrin Michael Esq.
Oyatobility chambers,
Counsel to the Applicant.
FOR SERVICE ON:
The Attorney-General,
Ministry of Justice,
Kano State

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 HIGH COURT IN THE SOUTH uses summons (S- summons S south)

IN THE HIGH COURT OF OYO STATE

IN THE IBADAN JUDICIAL DIVISION
HOLDEN AT IBADAN
CHARGE NO…………….
BETWEEN:
AKINDELE FEMI ……………………….. ACCUSED/APPLICANT
AND
THE STATE …………………………. COMPLAINANT/RESPONDENT

SUMMONS BROUGHT UNDER SECTION 118(1) OF THE CRIMINAL PROCEDURE LAW OF OYO STATE
AND SECTION 36(5) OF THE CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA 1999.
LET ALL PARTIES concerned attend this Honourable court on the …..day of ….2018 on the hearing of
an application on the part of counsel for Accused/Applicant for an order admitting AKINDELE FEMI
the Accused/Applicant to bail in respect of the charge No……………………….

AND FOR SUCH FURTHER ORDER OR ORDERS as this Honourable court may deem fit to make in the
circumstances.
Dated this ………. Day of …….. 20………….. [Date of the exams]

………………
Oboagwina Caleb Esq,
Easy Read Chambers
Ibadan.
Counsel to the Applicant.
FOR SERVICE ON:
The Attorney-General,
Ministry of Justice,
Oyo State

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AFFIDAVIT IN SUPPORT OF BAIL APPLICATION

IN THE HIGH COURT OF KANO STATE

IN THE KANO JUDICIAL DIVISION
HOLDEN AT KANO
CASE NO
BETWEEN
OLUWA SHEHUN… …………………………… ACCUSED/APPLICANT
AND
THE STATE ……………………… COMPLAINANT/RESPONDENT

AFFIDAVIT IN SUPPORT OF APPLICATION FOR BAIL

I, Oluwa Shehun, male, adult Nigerian, resident at 15, Udoneria Street, Shomolu, Lagos, do hereby make
oath and state as follows:
1. That I am the accused/applicant in this case and by virtue of my position, I am conversant
with the facts of the case and the circumstances leading to this case.
2. That I was arrested by the police officers of the Kano Division, Kano on Friday the 20th of
February 2014 on the allegation of robbery of one Miss Akoura Chinelo on the dame date.
3. That we were arraigned before the Judge of the High Court Kano, on 20th March 2014 on a
charge of robbery. The charge sheet is hereby attached and marked as EXHIBIT K1
4. That I have never been arrested, charged nor convicted of any offence before.
5. That I was with my wife on the said day and the time in which the offence was said to have
been committed.
6. That I am an out-patient at the Gwagwalada Specialist Hospital where I have been
undergoing treatment for renal failure. The report is hereby attached and marked EXHIBIT
K2.
7. That the prison which I am kept has no facilities for the treatment of the kind of ailment.
8. That I can barely stand on my feet for more than 10 minutes at most.
9. That I make this affidavit in good faith believing same to be true by virtue of the Oaths Act
----------------------------------
Deponent
SWORN to at the High Court Registry, Abuja
This _______day of_______2015
BEFORE ME
__________________________
COMMISSIONER FOR OATHS

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QUESTION 1
On or about the 13th day of April, 2018, Dodo Oluwole and Gorimapa broke into the house of Alhaji Bala
Danladi in Jaji area of Suleja in Niger State. They disarmed the security and tied him down to gain access
into the compound. Alhaji Bala Danladi was away on business trip while his wife and daughter were
assaulted and robbed.
Aisha Danladi (daughter) was raped several times by Oluwole despite passionate pleas from her
mother, Hajia Maimunat. Maimunat was slapped and shoved into the bedroom and ordered to bring
out her valuables worth millions of Naira and carted same away.
On their way out Dodo noticed that the security man had untied himself. He (Dodo) shot him in the
head. The security man died instantly. The robbers’ spotted Alhaji Danladi’s brand new Toyota Prado
jeep parked in the garage, demanded for the key and drove it away with their loot.
Luck however ran out on them when they tried to cross the border to sell the car. They were
apprehended and taken into custody. Whilst in custody, Dodo, the 1st accused person became critically
ill and was diagnosed with hypertension and diabetes.
They were later arraigned before the High Court, Suleja, Niger State on the three counts of culpable
homicide punishable with death, rape and assault. The 1st count was for both culpable and rape and the
2nd count was for assault alone.

a. Draft the application with particular reference to the health condition of Dodo.
ANSWER TO QUESTION 1 a
IN THE HIGH COURT OF NIGER STATE
IN THE MINNA JUDICIAL DIVISION
HOLDEN AT MINNA
CASE NO._____
BETWEEN
THE STATE – COMPLAINANT/RESPONDENT
AND
MATHEW DODO – ACCUSED/APPLICANT
MOTION ON NOTICE
BROUGHT PURSUANT TO SECTION 34(5) OF THE CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA,
1999 AND SECTION 341(2) OF THE CRIMINAL PROCEDURE CODE AND THE INHERENT JURISDICTION OF
THE HONOURABLE COURT
TAKE NOTICE that this Honourable Court will be moved on____ the day of___ 2018 at the hour of 9:00
AM in the forenoon or so soon thereafter as Counsel to the Accused/Applicant may be heard praying the
court for the following reliefs;
1. An order admitting the Accused/Applicant to bail pending the determination of this case.
2. Any order or further order as the Honourable Court may deem fit to make in the circumstances of
the case.
Dated this_____ day of____ 2018
Signed_____________
A.B & Co
Counsel to the Accused/Applicant
No.1 Emir Road, Minna.
FOR SERVICE ON:
Attorney General, Niger State
Ministry of Justice, Minna.

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 IN THE HIGH COURT OF NIGER STATE
IN THE MINNA JUDICIAL DIVISION
HOLDEN AT MINNA
CASE NO._____
BETWEEN
THE STATE – COMPLAINANT/RESPONDENT
AND
MATHEW DODO – ACCUSED/APPLICANT
AFFIDAVIT IN SUPPORT OF MOTION FOR BAIL
I, Sunday Dodo, Male, Nigerian, Christian of No.20 Old Minna-Abuja Road, Minna, Niger State, do hereby
make oath and state as follows:
1. That I am the brother of Mathew Dodo, the accused in this case and I have authority and consent
of the Applicant to depose to this Affidavit.
2. That the accused person is standing trial before this Honourable Court for Culpable Homicide,
Rape and Assault.
3. That the accused was arrested on 10th January, 2018 and detained at the Minna Central Police
Station.
4. That the accused person suddenly took ill and has been diagnosed with hypertension and
diabetes. A copy of the medical report of the accused’s state of health is attached herewith and
marked as Exhibit A.
5. That there are no adequate medical facilities in the Prisons to cater for this sickness.
6. That the accused needs to visit the hospital regularly to attend to his health.
7. That the accused person will attend to his trial if granted bail.
8. That the accused will provide reliable sureties if granted bail.
9. That it is in the interest of justice to grant the accused bail.
10. That I swear to this affidavit in good faith.

____________
DEPONENT
SWORN TO AT THE HIGH COURT REGISTRY, MINNA
This____ Day of___ 2018.
BEFORE ME

COMMISSIONER FOR OATHS

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OMNIBUS GROUNDS OF APPEAL

“That the decision of the court is unreasonable and cannot be supported by

evidence”

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