CRIMINAL LITIGATION:BAIL APPLICATIONS
IN THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY
IN THE ABUJA JUDICIAL DIVISION
HOLDEN AT ABUJA
CASE NO…………….
BETWEEN
THE STATE……………………………………………………COMPLAINANT/RESPONDENT
AND
- IKPO BAKARI……………………………………………………ACCUSED/ RESPONDENT
- BURANGO CHADO………….……………………….ACCUSED/APPLICANT
Let all parties concerned attend this Honourable Court on the ……..day of …………………. 2015 at the hour of 9 O’clock in forenoon or so soon thereafter in the hearing of an application by counsel on behalf of the applicant for an order admitting the applicant to bail pending his trial.
Dated this ………………day of ………………… 2015
Mo Esq.
Applicant’s Counsel
Mo & Co
14 Law School Road, Bwari Abuja.
ON NOTICE TO
The Hon. Attorney General of the Federation,
Federal Ministry of Justice,
Maitama, Abuja.
IN THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY
IN THE ABUJA JUDICIAL DIVISION
HOLDEN AT ABUJA
BETWEEN
THE STATE……………………………………………………COMPLAINANT/RESPONDENT
VS.
- IKPO BAKARI………………………………………………….…ACCUSED
- BURANGO CHADO………….……………………….ACCUSED/APPLICANT
MOTION ON NOTICE
BROUGHT PURSUANT TO SECTION 341 (2) & (3) OF THE CRIMINAL PROCEDURE CODE AND SECTIONS 35 & 36(5) OF THE CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA 1999 AND UNDER THE INHERENT JURISDICTION OF THE HONOURABLE COURT.
TAKE NOTICE that this Honourable Court will be moved on the ...... day of .............................. 2015 at the hour of 9 O’clock in the forenoon or so soon thereafter as Counsel on behalf of the Applicant may be heard praying this Honourable Court for:
- AN ORDER admitting the accused/applicant to bail pending the trial of his case.
- Any further or other orders as the Court may deem fit to make in the circumstances.
Dated this ………………day of ………………… 2015
Mo Esq.
Applicant’s Counsel
Mo & Co
14 Law School Road, Bwari Abuja.
ON NOTICE TO
The Hon. Attorney General of the Federation,
Federal Ministry of Justice,
Maitama, Abuja.
IN THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY
IN THE ABUJA JUDICIAL DIVISION
HOLDEN AT ABUJA
BETWEEN
THE STATE…………………..…………………………COMPLAINANT/RESPONDENT
VS.
- IKPO BAKARI…………………………………………………...ACCUSED
- BURANGO CHADO………….………………….ACCUSED/APPLICANT
I, Burango Chado, Male, Christain, Nigerian Citizen of 23 Ekpa Agbara Road, Bwari Abuja, do hereby make oath and state as follows:
- That I am the accused/applicant in this case and by virtue of my position, I am conversant with the fact of this case and circumstances leading to the application.
- That I was arrested by men of the Nigeria Police on the 2nd January, 2015 on the allegation of robbing one Mrs Agbo on the 29th day of December, 2014 and have been detained at the FCT Police Command since then.
- That on the 5th January, 2015, my counsel, Chris Bamba Esq. applied to the Divisional Police Officer in charge of the Bwari Divisional Police for my bail but the Divisional Police Officer on the said day refused the application.
- That I was arraigned before this Honourable Court on the 17th day of January, 2011 and charged with robbery, obtaining with menaces and the conspiracy to commit the said offences. A certified true copy of the charge sheet is attached herewith and marked as ‘Exhibit A.’
- That on that day, my counsel, Chris Bamba Esq. made an oral application for my bail but this Honourable court directed that the application should be made formally and ordered that I be detained in prison custody.
- That I did not commit the offences charged or any other offence for that matter.
- That on the said 29th day of December, 2014, I and my friends were busy celebrating the birthday party of my fiancé at the Jollywell Hotel, Wuse Abuja.
- That the accused was duly issued with the hotel receipt for the expenses incurred at the said birthday celebration. The receipt is herewith attached and marked “Exhibit B”.
- That I am an out-patient at the Gwagwalada Specialist Hospital Abuja where I have been receiving treatment for renal failure. Attached herewith are copies of his hospital card as well as the test results showing the diagnosis of the said ailment and severally marked as “Exhibit C” and “Exhibit D”.
- That as part of the treatment procedure of the accused, I make weekly visits to the said Gwagwalada Specialist Hospital Abuja for treatment, with the Specialist in charge of his treatment warning of dire consequences of non compliance or disruption of the routine.
- That since my incarceration, I have not made my weekly visits to the Clinic nor have access to any other medical treatment for the period of 3 weeks since my arrest and detention by the Police as the Bwari Police Station where I was detained had no medical facility.
- That the Kuje Prison where I am currently being detained has no facilities for such treatment.
- That my life is in jeopardy if I am not allowed access to my medical treatment at the Gwagwalada Specialist Hospital Abuja.
- That there is no shred of evidence linking me to the said offence or any other offence whatsoever.
- That I have never been convicted of any offence before nor even stood trial before in my life.
- That I recently concluded my National Youth Service Corps programme and I am a responsible member of the society.
- That I am ready and willing to produce reasonable sureties who are ready to take me on bail.
- I was informed by Counsel to the accused person, Chris Bamba Esq. and I verily believed him that this application is necessary in view of the precariousness of the accused person’s condition.
- That I make this declaration conscientiously and in good faith, believing same to be true and in accordance with the Oaths Act of 2004.
....................................
DEPONENT
SWORN AT THE HIGH COURT REGISTRY
This ............Day of ................... 2015
BEFORE ME
.......................................................
COMMISSIONER FOR OATHS
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