15th May, 2017
The Executive Governor
of Kaduna State,
Sir Kashim Ibrahim House,
PETITION AGAINST RAVINIA INDUSTRIAL SUPPLIES LIMITED, ALHAJI SHEBEBI IBDO SULE, AND BIOLA OYEBANJI, ESQ FOR TRESPASS, DAMAGE TO PRIVATE PROPERTY, LOOTING, INCITING PUBLIC DISTURBANCE AND BREACH OF PUBLIC PEACE
We are Solicitors to Mr. and Mrs. Pius A. Mallam (“our clients”); and on whose behalf and firm instructions we write to you on the above-captioned subject-matter.
Our clients’ briefing to us which we verily believe to be true and correct reveals as follows, that:
- At about 5:40 am of 12/05/2017, some hoodlums numbering about fifty (50) accompanied by about twenty (20) well-armed policemen invaded our Client’s business premises situate at No. 1, Nyerere Road, Narayi High Cost, Kaduna.
- The said hoodlums who came in five (5) Toyota buses were brandishing deadly weapons such as machetes, cutlasses, knives, axes, diggers, sledge hammers, etc, chanting war songs and embarked on the demolition of the premises.
- They brought down the fence, gates and broke into the Accounts Office and carted away the sum of N480, 200.00 which were proceeds from the the sales of the previous night. They also looted the bakery; brought down the structure housing the kitchen; and damaged the lounge and other structures in the premises.
- The hoodlums were hired by Biola Oyebanji, Esq who is the Counsel to Ravinia Industrial Supplies Limited and its Managing Director, Alhaji Shebebi Ibdo Sule to carry out these illegal and criminal acts purportedly pursuant to the execution of a Warrant of Possession of Premises dated 24/02/2003.
- Our clients are the rightful owners of the premises having lawfully obtained a Certificate of Occupancy No. 18791 in the name of “Pius A. Mallam” duly executed and registered as No. KDR 83, at Page 83, in Volume 126 (Certificates of Occupancy) of the State’s Lands Registry Office, Kaduna.
- More worrisome is the fact that the hoodlums were all brought in from Rigasa and Tudun Wada axis of Kaduna metropolis (‘Muslim Dominated Areas’) to carry out these criminal and illegal acts in High Cost, Narayi(‘A Christain-Dominated Area’).
- The manner in which these hoodlums were chanting war songs, brandishing their deadly weapons and carrying out these criminal and illegal acts attracted the attention of the youths of the neighbourhood and beyond, especially from Sabon Tasha, who came out in large number to violently confront the hoodlums. When the hoodlums saw the large turnout of the youths, they ran away.
- But for the timely intervention of the Commissioner of Police who sent the 2nd-in-Command and other Police officers of the Barnawa Police Division to the scene, and that of Sa Gbagyi (the Chief of Gbagyi Chiefdom), the situation created by the hoodlums in concert with Biola Oyebanji, Esq., Ravinia Industrial Supplies Limited and Alhaji Shebebi Ibdo Sule would have escalated into a violent religious crisis and a serious security breach in the State.
- At a time when Your Excellency is putting a lot of time, resources and efforts to bring lasting and enduring peace in the entire State, the actions of the hoodlums in concert with Biola Oyebanji, Esq., Ravinia Industrial Supplies Limited and Alhaji Shebebi Ibdo Sule as aforesaid were capable of not only undermining these efforts, but also would have had the tendencies of breaching the peace that His Excellency has painstakingly ensured that the State is presently enjoying.
Based on the foregoing, we request His Excellency use his good office to thoroughly investigate this matteer with a view to bringing all the culprits to book in order to forestall a recurrence of such criminal and illegal acts, and to also ensure there is no breach of public peace, public disturbance, or violent unrest in whatever guise in the future.
We are most grateful for Your Excellency’s anticipated positive response.
Kindly be rest assured of our professional courtesy at all times.
D. Tabakwot, Esq.
PP: JAMES KANYIP & CO.
- The Commissioner of Police,
Kaduna State Command,
- The Director,
Department of Security Service,