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IN THE SUPERIOR COURT OF JUDIGATURE, COURT @F GHANA!
IN THE SUPREME COURT OF GHANA,
ACCRA - A. D. 2025.
IN THE MATTER OF CASE No. CR 904/17 INTITULED REPUBLIC v
EUGENE BAFFOE BONNIE AND FOUR OTHERS.
AND Je{e0!= Sak.
IN THE MATTER OF AN APPLICATION BY KEVIN TAYLOR FOR AN
ORDER OF CERTIORARI TO BRING UP INTO THIS COURT TO
BE QUASHED AND FOR PURPOSES OF QUASHING THE WARRANT OF
ARREST ISSUED BY THE HIGH COURT [COMMERCIAL DIVISION -7],
ACCRA DATED THE 16"! OF JANUARY 2020 FOR THE ARREST OF THE
APPLICANT (KEVIN EKOW TAYLOR).
AND
IN THE MATTER OF:
‘THE REPUBLIC
ve
HIGH COURT (COMMERCIAL DIVISION) i RESPONDENT.
EX PARTE KEVIN EKOW TAYLOR. i APPLICANT.
ATTORNEY-GENERAL INTERESTED PARTY. ... INTERESTED PARTY.
MOTION ON NOTICE TO INVOKE THE SUPERVISORY JURISDICTION OF
‘THE SUPREME COURT PURSUANT TO ARTICLE 132 OF THE
CONSTITUTION, 1992 AND RULE 61(1) OF THE SUPREME COURT
RULES, 1996 (C.I. 16).
PLEASE TAKE NOTICE that pursuant to the provisions of article 132 of the
1992 Coastiagien the Republic of Ghana, this Court will be moved on
Feige thepoday Jul+,opS ct Jan
of 2025 at 9 o’clock in the forenoon or so soon thereafter as Counsel for
and on behalf of the Applicant may be heard on an application for an order of
certiorari directed at the High Court, Commercial Di ion, to bring up into
this Court for purposes of being quashed and the quashing of the warrant of
arrest issued by His Lordship Eric Kyei Baffour JA (Sitting as an additional
Justice of the High Court) dated the 16" day of January, 2020 in the case
intituled the Republic v Eugene Baffoe-Bonnie & Four Others (Case No.
CR/904/17) for the arrest of the Applicant and for a declaration that the High
Court has no jurisdiction to issue a warrant for the arrest of the Applicant
Sathout first giving the Applicant an opportunity to answer any charges
against himUpon the grounds set out below and upon the facts deposed to in the
accompanying affidavit.
GROUNDS OF APPLICATION
a. The High Court acted in breach of the rule of natural Justice audi
alteram partem when it issued the warrant for the “apprehension of the
body of” the Applicant without first hearing the Applicant on the
allegations based on which the High Court issued the said warrant of
arrest,
b, The High Court’s warrant for the “apprehension of the body of” the
Applicant was not made in accordance with any procedure sanctioned
y law.
c The High Court committed an error of law when by its order directed
the Applicant's be first apprehended before being heard when there was
no previous order for the Applicant to appear before the High Court to
show cause which the Applicant did not comply with.
And for such further or other order(s) as this Honourable Court may deem fit.
COURT TO BE MOVED on.......... the ... day of ... 2025 at 9:00 0” clock in
the forenoon or so soon thereafter as Counsel for the 1 Defendant may be
heard.
DATED AT ACCRA THIS 2"° DAY.OF
PETER OKUDZETO ESQ.
COUNSEL FOR APPLICANT.
SOLICITOR’S LICENSE NO. eGAR00298/25.
CHAMBER NO: ePP09183/24.
‘TIN- P0016476050.
AND FOR SERVICE:
1, THE ATTORNEY-GENERAL,
ATTORNEY-GENERAL’S DEPARTMENT,
MINISTRIES, ACCRA.
2. THE INSPECTOR GENERAL OF POLICE,
POLICE HEADQUARTERS,
ACCRA.
3. NATIONAL SECURITY CO-ORDINATOR,
NATIONAL COUNCIL SECURITY SECRETARIAT,
ACCRA.j Filed en. DQIGH RSIS
imipm
legistrar |
___SUPREME C@URT OF GHANA
IN THE SUPERIOR COURT OF JUDICATURE,
IN THE SUPREME COURT OF GHANA,
ACCRA - A. D. 2025.
IN THE MATTER OF CASE No. CR 904/17 INTITULED REPUBLIC v
EUGENE BAFFOE BONNIE AND FOUR OTHERS.
AND
IN THE MATTER OF AN APPLICATION BY KEVIN TAYLOR FOR AN
ORDER OF CERTIORARI TO BRING UP INTO THIS COURT TO
BE QUASHED AND FOR PURPOSES OF QUASHING THE WARRANT OF
"ARREST ISSUED BY THE HIGH COURT [COMMERCIAL DIVISION -7],
ACCRA DATED THE 16™ OF JANUARY 2020 FOR THE ARREST OF THE
APPLICANT (KEVIN EKOW TAYLOR).
AND
IN THE MATTER OF:
‘THE REPUBLIC
ve
HIGH COURT (COMMERCIAL DIVISION).
RESPONDENT.
EX PARTE KEVIN EKOW TAYLOR. oS APPLICANT.
ATTORNEY-GENERAL INTERESTED PARTY. ... INTERESTED PARTY.
AFFIDAVIT OF KEVIN EKOW TAYLOR [THE APPLICANT] IN SUPPORT
‘OF MOTION FOR CERTIORARI AND DECLARATION IN RESPECT OF
WARRANT OF ARREST DATED 167 JANUARY 2020.
1, KEVIN EKOW ‘TAYLOR, of the United States of America, do hereby make
oath and say that:
1, 1am the deponent herein and the Applicant in the above intituled
application.
2. 1 therefore depose to this affidavit for and on my own behalf in
support of the application before the Court.
3, The facts I depose to in this affidavit, unless otherwise deposed to are
within my personal knowledge, information and honest belief.
4. Tacquired knowledge of the facts 1 depose to in my present affidavit
basal on media information and also a copy of the order the subject of
my instant application made available to me by my lawyers.
Page 1 of +10.
cud
12.
13.
14,
In the event that any statement I depose to in this affidavit state
matters of law, such deposition is based on my lawyer's advice to me
which advice I verily believe.
My counsel shall, if necessary, at the hearing of my application seek
leave of the court to refer to any processes filed in relation to the
matters which are relevant to my application.
For quite sometime friends and relatives in Ghana have informed me
that the High Court of the Republic of Ghana has issued a warrant for
my arrest but none of such relatives and friends have ever made
available to me a copy of the High Court's order despite several
requests.
Indeed, friends and relatives in Ghana have drawn my attention to
several social media discussions of the said warrant for my arrest but
none was able to provide a copy to me for my attention.
Because I do not ordinarily reside in Ghana, I have not paid attention
to it especially that no one ever showed me a copy of the order even
though I always asked for copies each time @ friend or relative
mentions it to me in a conversation or when I hear social media
discussions on it.
Given the frequency of the reference to the order and the discussions I
have heard about it on social media, 1 engaged the services of my
present solicitor sometime in April this year 2025 who after about a
month (that is sometime at the end of May) of search, sent me a copy
of the order which is exhibited hereto and marked A.
My lawyer explained the difficulty in obtaining a copy of the court
order because although I instructed him to find the order if any, I did
not know which court issued it.
‘The order says that it is issued for the arrest of a certain Kelvin
‘Taylor which is not my name but given its close resemblance with my
heme and the information I have received from my friends and
Telatives in Ghana, the order is believed to refer to me because all
Tnedia discussions 1 have heard on the subject all point to me as the
subject of the order.
‘The order refers to a “scandalous video circulating on social media...
which video contains an extremely scandalous and prima facie
contemptuous speak that scandalises the Judge, the Court and the
whole administration of justice.”
‘The order however did not direct that I be served with a copy of the
said video to enable me to appear before the Court to explain whether
Page 2 of +15.
16.
17s
18.
19,
20.
ai.
the video was generated by artificial intelligence or doctored or even
my thinking based on which the video was made before directing that
I be arrested.
My lawyer has also confirmed that the registry of the High Court did
not have a copy of the video to enable him to advise me on the video.
In any event, the order for my arrest was made in breach of my right
to be heard before any order is made against me and also contrary to
law because the order for my arrest was made without first giving me
a hearing.
In terms of of paragraph 14 of my affidavit I say that the order of the
High Court clearly undermines the High Court’s own obligation to
protect my fundamental human right to liberty because I have not on
invitation of the High Court refused to appear before the court to
answer the court’s charges of contempt against me for which reason
there is no legal basis for the warrant for my arrest before my
appearance in court to answer to the contempt charge.
In alll instances in which the courts are minded to summon persons to
appear before them to show cause why they should not be convicted
for contempt, appearing before the court to answer the contempt
charges is not preceded by an order for the arrest of the suspected
contemnor who has not indicated their intention to refuse to show up
in court voluntarily to answer the charge.
‘The warrant for my arrest therefore even before I am given a hearing
constitutes a real threat to my fundamental human rights and must
not be executed unless I am given the opportunity to voluntarily
appear before the court to answer the contempt charge.
‘The High Court's power to make orders to deprive any person of their
liberty must be made in accordance with law but no law sanctions
depriving me of my liberty before hearing me out.
WHEREFORE | depose to my present affidavit in good faith.
fh
DEPONENT.
SWORN AR ACCRA
THs b