IN THE FEDERAL HIGH COURT OF NIGERIA
ABEOKUTA JUDICIAL DIVISION
HOLDEN AT ABEOKUTA

SUIT NO:

IN THE MATTER OF AN APPLICATION FOR THE ENFORCEMENT OF FUNDAMENTAL HUMAN RIGHTS AS CONTAINED IN CHAPTER (IV) OF THE CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA (1999 AS AMENDED)

AND

IN THE MATTER OF AN APPLICATION BY MS. OMOLOLA STELLA AGBAJE FOR AN ORDER FOR THE ENFORCEMENT OF HER FUNDAMENTAL RIGHTS

BETWEEN

MS. OMOLOLA STELLA AGBAJE APPLICANT

AND

1. UNITED BANK FOR AFRICA
2. THE COMMISSIONER OF POLICE, RESPONDENTS
OGUN STATE POLICE COMMAND
3. NIGERIA POLICE SERVICE COMMISSION
4. INSPECTOR GENERAL OF POLICE

AFFIDAVIT IN SUPPORT OF APPLICATION TO ENFORCE FUNDAMENTAL RIGHTS
I, MS. OMOLOLA STELLA AGBAJE, a Banker, Female, Adult, Christian and Nigerian Citizen of 2 Alapa Community Estate, Ile-Ise Awo, Abeokuta, Ogun State do hereby make oath and state as follows:

A. The Applicant’s Unblemished Record
1. I am the Applicant herein, a graduate and a member of several professional bodies.

2. I have distinguished myself over the years as a trustworthy individual with impeccable integrity at work, church, community and amongst friends and relations.

3. I am equally a volunteer for several humanitarian causes.

4. My employment with the 1st Respondent commenced on July 27, 2006, though I only got a confirmation of my employment on the 27th of July, 2009.

5. I remained in the employment of the 1st Respondent until my traumatizing experience forming the fulcrum of my institution of this action.

6. I tendered my resignation by way of a letter dated the 29th of July, 2019 and my resignation took effect on the 1st of August, 2019. My letter of employment, confirmation and resignation are attached and marked as Exhibit J&G 1A, 1B & 1C.

7. I worked first at the 1st Respondent’s Apata Finance Business Office Branch, then at the University College Hospital, Ibadan and lastly at the Ita Eko Business Office which was my last office until the 1st of August, 2019 when my resignation came into effect.

8. Throughout the entire period of my employment with the 1st Respondent, I neither had cause to be reprimanded, face any disciplinary panel, receive a query nor found wanting in the discharge of my duties.

9. Further to the above, I was never implicated in any wrongdoing as to warrant any investigation by the 1st Respondent’s internally constituted disciplinary authority neither do I have a criminal record with any agent of the 1st to the 4th Respondents.

10. As a matter of fact, during the course of my employment with the 1st Respondent spanning for over a decade, I was bestowed by the 1st Respondent with Ten Years Meritorious Service Award in acknowledgement of my forthrightness due to my diligence.

B. The Incident
11. On 14th December 2019 I resumed at the Ita Eko Business Office Branch of the 1st Respondent diligently discharging my official duties.

12. On that fateful day, being the 31st of January 2019, at about 10a.m, I began my daily assigned duty as usual at the Ita Eko Business Office Branch of the 1st Respondent; having been assigned to load the Automated Teller Machines (ATM) alongside my colleague - one Odunayo Fatoki.

13. My colleague and I approached the custodians of the vault on that day together and we were given the cash to be loaded into the ATM; we were given a total of N10,600,000.00 (Ten Million, Six Hundred Thousand Naira) by the Branch Operations Manager in dual custody for sorting and loading into the ATM. As it is the standard practice, which I never failed to comply with, we signed off the exchange slip with the Branch Operations Manager and he posted the amount he had given to us for loading into the ATM, as usual.

14. My Colleague and I sorted the money at the sorting machine and stacked it as usual, in the order in which we were going to load the three (3) Automated Teller Machines (ATM) numbered as 2, 5 and 6 respectively.

15. After splitting the aforementioned funds, I loaded ATM 2 with N3,600,000.00 (Three Million, Six Hundred Thousand Naira) only while my colleague loaded in ATMs 5&6 with N4,000,000.00 (Four Million Naira) only and N3,000,000.00 (Three Million Naira) only respectively and these sums were duly cross-checked and signed off by my Colleague, Ms. Odunayo Fatoki as it is the standard practice.

16. After loading the said ATMs at about 10 a. m. on the 31st day of January 2019, myself and my Colleague locked the ATM room and submitted the key to the Branch Operations Manager, Mr. Daramola Ayoola as it is the standard practice.

17. There were routine cash loads into the ATMs of the 1st Respondent subsequently by other staff of the Ita Eko Business Office Branch of the 1st Respondent.

18. On the 1st day of February 2019, at about 9:30 a. m., the Control Officer of the Ita Eko Business Office Branch of the 1st Respondent summoned the Cash Officer, Seyi Ayoola, Ms. Odunayo Fatoki and myself for a cash count. It was at that point a shortfall of the sum of N1,000,000.00 (One Million Naira) only was discovered from the money that was loaded into the ATMs the previous day and Mr. Daramola Ayoola demanded an explanation from us on how the shortfall came about.

19. I informed Mr. Daramola Ayoola that I knew nothing about the missing money as the funds I loaded into the ATMs on the said date had all been duly verified by Ms. Odunayo Fatoki, while other members of staff of the Bank also loaded the ATMs subsequently, therefore, I could not be held responsible for the shortfall.

20. Of note, other members of staff who subsequently loaded the ATM with cash at different times on 31st day of January 2019 were not interrogated or investigated with regards to the missing sum of N1,000,000.00 (One Million Naira) only.

21. Not satisfied with my explanations that I knew nothing of the shortfall or how it came about, Mr. Daramola Ayoola threatened that unless I gave him options as to how I plan to pay back the missing N1,000,000.00 (One Million Naira) only, I will be arrested.

22. The Branch Operations Manager of the Ita Eko Business Office Branch of the 1st Respondent, Mr. Daramola Ayoola, later escalated the matter to the Branch Manager of the Ita Eko Business Office Branch of the 1st Respondent, Ms. Nneka Priscilla Alaba, who in the Banking Hall, without any just cause whatsoever, singled me out and labelled me a culprit to my utter dismay and embarrassment since I neither have a track record of such nor was I solely involved in loading the ATMs for the day in question.

23. I was further threatened with arrest and torture by the Branch Manager of the Ita Eko Business Office Branch of the 1st Respondent, Ms. Nneka Priscilla Alaba if I failed to produce the said missing sum of N1,000,000.00 (One Million Naira) only.

24. I still maintained my innocence which further infuriated Ms. Nneka Priscilla Alaba who then maliciously ordered the other Bank officials to “do the needful” to me.

C. Irreparable reputational Damage and Inhumane Treatment Meted on Applicant
25. This incidence between myself and the Branch Manager of the Ita Eko Business Office Branch of the 1st Respondent, Ms. Nneka Priscilla Alaba happened in the Banking Hall which drew the public attention of both staff, visitors and customers of the Ita Eko Business Office Branch of the 1st Respondent, who gazed at me like a common criminal.

26. True to the threats and at the behest of the top management staff of the Ita Eko Business Office Branch of the 1st Respondent, I was arrested by the Police in the full glare of other members of staff of the Branch, customers and members of the public, many of whom had brought out their mobile phones to take pictures and make recordings of all that transpired with no other intent than to circulate in social media to a wider audience for resultant blackmail in future.

27. Before my arrest, when all the incidence was ongoing, I told the Branch Operations Manager of the Ita Eko Business Office Branch of the 1st Respondent, Mr. Daramola Ayoola to play the Closed-Circuit Television (CCTV), also known as video surveillance, covering the Automated Teller Machines(ATM)’ Loading point and Automated Teller Machines(ATM) since I know as a staff that there are functional designated CCTV covering the entire Bank premises, so we could see what went wrong, but he refused.

28. That same day, 1st day of February 2019, the Branch Operations Manager of the Ita Eko Business Office Branch of the 1st Respondent, Mr. Daramola Ayoola surreptitiously requested I accompany him somewhere and upon chaperoning me outside the Banking Hall in full public glare, I was accosted by Six (6) Armed Officers and men of the Special Anti- Robbery Squad of Magbon Police Station under the authority of the 2nd Respondent as supervised by the Branch Operations Manager of the Ita Eko Business Office Branch of the 1st Respondent, Mr. Daramola Ayoola, who accosted me, arrested me and took me to their Police Station at Magbon, Abeokuta.

29. At the Police Station, I was made to understand by the Police Officers that they had been informed by the Branch Operations Manager of the Ita Eko Business Office Branch of the 1st Respondent, Mr. Daramola Ayoola that I was the culprit, as I was subjected to undue intimidation, intensive and rigorous interrogation and continuous threats and torture.

30. Further to the above, the Officer in Charge at the Police Station at Magbon, Abeokuta directed the Police officers to torture me whilst sparing my colleague, Odunayo Fatoki, who was equally brought to the Police Station whilst commanding that I provide my Bank Verification Number for prompt blocking/blacklisting of all my Bank Accounts.

31. I was also coerced to confess to the crime of stealing the missing sum of N1,000,000.00 (One Million Naira) only.

32. Amidst the continuous threats and intimidation, I was forced to write a statement at the said Magbon Police Station. I was further threatened to admit to stealing the money, but I declined admitting to a crime I did not commit, which further infuriated the Police Officers aggravating my torture.

33. While at the Police Station, I was subjected to all manner of inhuman treatment; I was made to sit on the floor, walk around barefooted; locked in a cell overnight with other inmates like a common criminal despite my pleas for contacting my legal representatives in seeking justice, exposed to harsh weather, put in fear of rape/assault, battled with mosquitoes and other insects, traumatized with neither sleep nor respite in sight, amongst others.



34. Further, I was denied access to my relatives who visited but were not granted access to see me until after they had been extorted by the officers at the Police Station at Magbon, Abeokuta.

35. On the 2nd of February 2019, being the next day which I appeared like an eternity, I was brought out of the cell in the morning and driven by Policemen of the Police Station at Magbon, Abeokuta to my place of residence, which happens to be the home of my sister and her husband, parading me there in my neighbourhood at 2 Alapa Community Estate, Ile-Ise Awo, Abeokuta, Ogun State, and before my relations simply to conduct a search at my residence.

36. The entire house was searched without the Police showing my sister, her family or myself a Search Warrant. Upon conclusion of the search, nothing incriminating was found by the police and I was driven back to the police station and put behind the counter.

37. Later in the afternoon, the Branch Operations Manager of the Ita Eko Business Office Branch of the 1st Respondent, Mr. Daramola Ayoola, later arrived at the station, he went past me straight into the office of the Officer-in-charge. Thereafter, I was called into the office of the Officer-in-charge and told that I would be released. I was released to my sister and her husband at late in the evening only after they parted with the sum of N60,000.00 (Sixty Thousand Naira) only for my bail.

38. The morning after, being Sunday, February 3, 2019 I was unable to get up from my bed, shattered due to the agonizing experience of the previous days, and I subsequently took ill and fainted which resulted in my being rushed to the hospital where I was eventually resuscitated.

39. Precisely, after I left the Police Station, I was placed on admission at the nearby hospital- Mercy Group of Clinic, Panseke Abeokuta where I spent five days since upon making partial recovery, enough to move about, I had to abruptly leave the said hospital to resume work in order to properly apply for twenty(22) days leave at the Ita Eko Business Office Branch of the 1st Respondent. The evidence of the Doctor’s report, medications and hospital bills from Mercy Group of Clinic, Panseke Abeokuta are attached and marked as Exhibit J & G 2.

Ok

In a useless country useless things happen

ebenhazard:
In a useless country useless things happen

Exposed! REAL REASONS STELLA AGBAJE IS SUING UBA FOR 150MILLION NAIRA


40. In a desperate bid to escape from the stigma and shame of the neighborhood where I was taken to search my sister's house, I left for Ibadan, being the family house of my parents where I had to further consult another doctor since I was still not better.

41. The Doctor at Kola Adekola Clinic, Ibadan who attended to me prescribed some drugs whilst placing me under observation and regular medical checkups. The Prescription Sheet from Kola Adekola Clinic, Ibadan is attached and marked Exhibit J & G 3.

42. After the ordeal, I became so traumatized that I developed severe difficulty in breathing. For a very long time I could only breath easily with the aid of an inhaler and I made several frequent visits to the hospital for check-ups, tests and treatments and was placed on medication to restore me to full health.

43. Despite not having fully recuperated, I returned to work hoping to salvage my reputation, however, no mention was made of the incident neither was there any comment on the purportedly missing funds from any quarter of the 1st Respondent confirming my strong belief that there was no reasonable and probable cause for making the report to the Police.

44. The effects of the calamitous event to my extended family particularly my sister and her family whom I live with, and to my person include shock, loss of my reputation amongst my peers, neighbours, and the general public having knowledge of this incidence particularly the fear of circulation in the social media of the event by witnesses on the fateful day which exacerbates the risk of trauma I daily experience.

45. I now always carry the emotional, mental, psychological, and psychic baggage/scars with a tag of ‘thief’, seemingly following me about.

46. Further to the above, the following are some of the other effects:

(a) Inability to form close satisfying relationships;
(b) Experiencing terrifying memories such as nightmares and flashbacks;
(c) Outright avoidance of social media;
(d) Emotional numbness;
(e) Avoidance of public gatherings, all banking institutions, objects, scenes, or events that are reminders of the calamity;
(f) Disposition to soliloquizing and loss of touch with present;
(g) Intermittent chest pain;
(h) Difficulty in breathing;
(i) Fear of blackmail on social media

47. The above-named manifestations are inappropriate and disproportionate to reality and are a nagging cause for concern to me.
48. Even with the best psychological treatment and other professional help I sought, this has not abated as I now always carry the emotional, mental, psychological, and psychic scars, since that fateful day in February 2019.

49. Regrettably, since the sad occurence when I was taken to the Police Station till now, not one word has been said about the alleged missing N1,000,000.00 or the outcome of any investigation carried out as to erase my now blemished record, profile and personality.

50. Until the unfortunate incident, I worked diligently for the 1st Respondent over a 12 years period without blemish of any kind and do not in any way deserve the kind of dehumanizing and inhumane treatment meted out to me.

51. Quite contrary to its code of ethics and professionalism, the 1st Respondent has failed to live up to its responsibilities pertaining to the just and fair discharge of its duties to me. A copy of the Code of Ethics and Professionalism in UBA & Information Confidentiality is attached and marked as Exhibit J&G 4.

52. Till date, there has been no word from the 1st Respondent which creates doubt as to whether any money was missing in the first place which means I was made to suffer for no just cause.

53. No written apology has been tendered for the traumatic experience I was made to go through and no proper step has been taken to compensate me for the trauma and humiliation I suffered in the hands of the Respondents.

54. I later engaged the Law Firm of Jireh & Greys Attorneys to write a letter on my behalf to the 1st Respondent, to express my displeasure at the way I was arrested, harassed, detained and tortured. The copy of the said letter to the 1st Respondent dated February 13, 2019, received by the Bank on February 14, 2019 is hereby attached and marked as Exhibit “J&G 5”.

55. The office of the President, Federal Republic of Nigeria, the office of the Vice President, the National Human Rights Commission (NHRC), the Police Service Commission, the Inspector General of Police, the National Deposit Insurance Corporation (NDIC) and the Central Bank of Nigeria (CBN) were all served with a copy of the said letter. Copies of the response from NHRC and CBN are attached and marked ‘Exhibits J&G 6 & 7’ respectively.

56. Despite the interventions of the NHRC and CBN in their respective letters referred to above, the 1st Respondent still failed to take any step to meet with me or my lawyers to fashion out a way to finally resolve the matter.

57. My solicitors had to write further letters to the CBN and NHRC and further reminders to the 1st Respondent before the 1st Respondent took a step in an attempt to meet me or my Solicitors. Copies of the letters are attached and marked ‘Exhibits J&G 8 (i), (ii), (iii), (iv) & (v)’.

58. When the situation became too worrisome for me and I could not cope with working with the 1st respondent as I was constantly under surveillance and looked at with suspicion by colleagues since the 1st Respondent failed to clear the air on the issue of the purportedly missing sum of money, I had no choice but to tender my resignation letter on July 29, 2019.

59. To further compound my woes, the 1st Respondent on November 5, 2019 deducted the sum of N25,962.63 (Twenty-Five Thousand, Nine Hundred and Sixty-Two Naira, Sixty-Three Kobo) from my account under the guise of what they referred to as ‘Net Indebtedness’ when in fact I never owed the 1st Respondent any debt.
D. Reliefs Sought By Applicant
60. Till date, the Respondents have not made moves to remedy the wrong done to me, which is tantamount to a violation of my Fundamental Human Rights as enshrined in the Constitution of the Federal Republic of Nigeria 1999 (as amended).

61. I eventually had no other choice than to resign from my position with the Bank as a result of the traumatic experience and the dent to my career in the Banking sector spanning over a decade; regrettably in order to further intimidate me, compound my woes and deprive me of my entitlements, my letter of resignation is still pending and yet to be acknowledged by the 1st Respondent.

62. The 1st Respondent in a bid to browbeat me into a state of helplessness proceeded on 5th of November, 2019 to empty my UBA Account No. 1011357499 by debiting same of my remaining balance of the sum of N25,962.63 (Twenty-Five Thousand, Nine Hundred and Sixty-Two Naira, Sixty-Three Kobo) for no reason.

63. This application is not frivolous as the 1st Respondent’s did not deem it fit that I appear before any internally constituted disciplinary authority to determine my culpability before spearheading my harassment and torture.

64. It will be in the interest of justice to grant this application.

65. I depose to this affidavit in good faith, conscientiously believing same to be true and in accordance with the Oaths Act.

……………………
DEPONENT
Sworn to at the Federal High Court Registry, Abeokuta,
this ____ day of ___________ 2020


BEFORE ME


COMMISSIONER FOR OATHS

She is suing United Bank for Africa, UBA for One Hundred and Fifty Million naira (N150m) for damages.

Following closely

Na who I go ask?

DejiPlug:


Exposed! REAL REASONS STELLA AGBAJE IS SUING UBA FOR 150MILLION NAIRA


40. In a desperate bid to escape from the stigma and shame of the neighborhood where I was taken to search my sister's house, I left for Ibadan, being the family house of my parents where I had to further consult another doctor since I was still not better.

41. The Doctor at Kola Adekola Clinic, Ibadan who attended to me prescribed some drugs whilst placing me under observation and regular medical checkups. The Prescription Sheet from Kola Adekola Clinic, Ibadan is attached and marked Exhibit J & G 3.

42. After the ordeal, I became so traumatized that I developed severe difficulty in breathing. For a very long time I could only breath easily with the aid of an inhaler and I made several frequent visits to the hospital for check-ups, tests and treatments and was placed on medication to restore me to full health.

43. Despite not having fully recuperated, I returned to work hoping to salvage my reputation, however, no mention was made of the incident neither was there any comment on the purportedly missing funds from any quarter of the 1st Respondent confirming my strong belief that there was no reasonable and probable cause for making the report to the Police.

44. The effects of the calamitous event to my extended family particularly my sister and her family whom I live with, and to my person include shock, loss of my reputation amongst my peers, neighbours, and the general public having knowledge of this incidence particularly the fear of circulation in the social media of the event by witnesses on the fateful day which exacerbates the risk of trauma I daily experience.

45. I now always carry the emotional, mental, psychological, and psychic baggage/scars with a tag of ‘thief’, seemingly following me about.

46. Further to the above, the following are some of the other effects:

(a) Inability to form close satisfying relationships;
(b) Experiencing terrifying memories such as nightmares and flashbacks;
(c) Outright avoidance of social media;
(d) Emotional numbness;
(e) Avoidance of public gatherings, all banking institutions, objects, scenes, or events that are reminders of the calamity;
(f) Disposition to soliloquizing and loss of touch with present;
(g) Intermittent chest pain;
(h) Difficulty in breathing;
(i) Fear of blackmail on social media

47. The above-named manifestations are inappropriate and disproportionate to reality and are a nagging cause for concern to me.
48. Even with the best psychological treatment and other professional help I sought, this has not abated as I now always carry the emotional, mental, psychological, and psychic scars, since that fateful day in February 2019.

49. Regrettably, since the sad occurence when I was taken to the Police Station till now, not one word has been said about the alleged missing N1,000,000.00 or the outcome of any investigation carried out as to erase my now blemished record, profile and personality.

50. Until the unfortunate incident, I worked diligently for the 1st Respondent over a 12 years period without blemish of any kind and do not in any way deserve the kind of dehumanizing and inhumane treatment meted out to me.

51. Quite contrary to its code of ethics and professionalism, the 1st Respondent has failed to live up to its responsibilities pertaining to the just and fair discharge of its duties to me. A copy of the Code of Ethics and Professionalism in UBA & Information Confidentiality is attached and marked as Exhibit J&G 4.

52. Till date, there has been no word from the 1st Respondent which creates doubt as to whether any money was missing in the first place which means I was made to suffer for no just cause.

53. No written apology has been tendered for the traumatic experience I was made to go through and no proper step has been taken to compensate me for the trauma and humiliation I suffered in the hands of the Respondents.

54. I later engaged the Law Firm of Jireh & Greys Attorneys to write a letter on my behalf to the 1st Respondent, to express my displeasure at the way I was arrested, harassed, detained and tortured. The copy of the said letter to the 1st Respondent dated February 13, 2019, received by the Bank on February 14, 2019 is hereby attached and marked as Exhibit “J&G 5”.

55. The office of the President, Federal Republic of Nigeria, the office of the Vice President, the National Human Rights Commission (NHRC), the Police Service Commission, the Inspector General of Police, the National Deposit Insurance Corporation (NDIC) and the Central Bank of Nigeria (CBN) were all served with a copy of the said letter. Copies of the response from NHRC and CBN are attached and marked ‘Exhibits J&G 6 & 7’ respectively.

56. Despite the interventions of the NHRC and CBN in their respective letters referred to above, the 1st Respondent still failed to take any step to meet with me or my lawyers to fashion out a way to finally resolve the matter.

57. My solicitors had to write further letters to the CBN and NHRC and further reminders to the 1st Respondent before the 1st Respondent took a step in an attempt to meet me or my Solicitors. Copies of the letters are attached and marked ‘Exhibits J&G 8 (i), (ii), (iii), (iv) & (v)’.

58. When the situation became too worrisome for me and I could not cope with working with the 1st respondent as I was constantly under surveillance and looked at with suspicion by colleagues since the 1st Respondent failed to clear the air on the issue of the purportedly missing sum of money, I had no choice but to tender my resignation letter on July 29, 2019.

59. To further compound my woes, the 1st Respondent on November 5, 2019 deducted the sum of N25,962.63 (Twenty-Five Thousand, Nine Hundred and Sixty-Two Naira, Sixty-Three Kobo) from my account under the guise of what they referred to as ‘Net Indebtedness’ when in fact I never owed the 1st Respondent any debt.
D. Reliefs Sought By Applicant
60. Till date, the Respondents have not made moves to remedy the wrong done to me, which is tantamount to a violation of my Fundamental Human Rights as enshrined in the Constitution of the Federal Republic of Nigeria 1999 (as amended).

61. I eventually had no other choice than to resign from my position with the Bank as a result of the traumatic experience and the dent to my career in the Banking sector spanning over a decade; regrettably in order to further intimidate me, compound my woes and deprive me of my entitlements, my letter of resignation is still pending and yet to be acknowledged by the 1st Respondent.

62. The 1st Respondent in a bid to browbeat me into a state of helplessness proceeded on 5th of November, 2019 to empty my UBA Account No. 1011357499 by debiting same of my remaining balance of the sum of N25,962.63 (Twenty-Five Thousand, Nine Hundred and Sixty-Two Naira, Sixty-Three Kobo) for no reason.

63. This application is not frivolous as the 1st Respondent’s did not deem it fit that I appear before any internally constituted disciplinary authority to determine my culpability before spearheading my harassment and torture.

64. It will be in the interest of justice to grant this application.

65. I depose to this affidavit in good faith, conscientiously believing same to be true and in accordance with the Oaths Act.

……………………
DEPONENT
Sworn to at the Federal High Court Registry, Abeokuta,
this ____ day of ___________ 2020


BEFORE ME


COMMISSIONER FOR OATHS

She is suing United Bank for Africa, UBA for One Hundred and Fifty Million naira (N150m) for damages.

okay

I wish you success

DejiPlug:


Exposed! REAL REASONS STELLA AGBAJE IS SUING UBA FOR 150MILLION NAIRA


40. In a desperate bid to escape from the stigma and shame of the neighborhood where I was taken to search my sister's house, I left for Ibadan, being the family house of my parents where I had to further consult another doctor since I was still not better.

41. The Doctor at Kola Adekola Clinic, Ibadan who attended to me prescribed some drugs whilst placing me under observation and regular medical checkups. The Prescription Sheet from Kola Adekola Clinic, Ibadan is attached and marked Exhibit J & G 3.

42. After the ordeal, I became so traumatized that I developed severe difficulty in breathing. For a very long time I could only breath easily with the aid of an inhaler and I made several frequent visits to the hospital for check-ups, tests and treatments and was placed on medication to restore me to full health.

43. Despite not having fully recuperated, I returned to work hoping to salvage my reputation, however, no mention was made of the incident neither was there any comment on the purportedly missing funds from any quarter of the 1st Respondent confirming my strong belief that there was no reasonable and probable cause for making the report to the Police.

44. The effects of the calamitous event to my extended family particularly my sister and her family whom I live with, and to my person include shock, loss of my reputation amongst my peers, neighbours, and the general public having knowledge of this incidence particularly the fear of circulation in the social media of the event by witnesses on the fateful day which exacerbates the risk of trauma I daily experience.

45. I now always carry the emotional, mental, psychological, and psychic baggage/scars with a tag of ‘thief’, seemingly following me about.

46. Further to the above, the following are some of the other effects:

(a) Inability to form close satisfying relationships;
(b) Experiencing terrifying memories such as nightmares and flashbacks;
(c) Outright avoidance of social media;
(d) Emotional numbness;
(e) Avoidance of public gatherings, all banking institutions, objects, scenes, or events that are reminders of the calamity;
(f) Disposition to soliloquizing and loss of touch with present;
(g) Intermittent chest pain;
(h) Difficulty in breathing;
(i) Fear of blackmail on social media

47. The above-named manifestations are inappropriate and disproportionate to reality and are a nagging cause for concern to me.
48. Even with the best psychological treatment and other professional help I sought, this has not abated as I now always carry the emotional, mental, psychological, and psychic scars, since that fateful day in February 2019.

49. Regrettably, since the sad occurence when I was taken to the Police Station till now, not one word has been said about the alleged missing N1,000,000.00 or the outcome of any investigation carried out as to erase my now blemished record, profile and personality.

50. Until the unfortunate incident, I worked diligently for the 1st Respondent over a 12 years period without blemish of any kind and do not in any way deserve the kind of dehumanizing and inhumane treatment meted out to me.

51. Quite contrary to its code of ethics and professionalism, the 1st Respondent has failed to live up to its responsibilities pertaining to the just and fair discharge of its duties to me. A copy of the Code of Ethics and Professionalism in UBA & Information Confidentiality is attached and marked as Exhibit J&G 4.

52. Till date, there has been no word from the 1st Respondent which creates doubt as to whether any money was missing in the first place which means I was made to suffer for no just cause.

53. No written apology has been tendered for the traumatic experience I was made to go through and no proper step has been taken to compensate me for the trauma and humiliation I suffered in the hands of the Respondents.

54. I later engaged the Law Firm of Jireh & Greys Attorneys to write a letter on my behalf to the 1st Respondent, to express my displeasure at the way I was arrested, harassed, detained and tortured. The copy of the said letter to the 1st Respondent dated February 13, 2019, received by the Bank on February 14, 2019 is hereby attached and marked as Exhibit “J&G 5”.

55. The office of the President, Federal Republic of Nigeria, the office of the Vice President, the National Human Rights Commission (NHRC), the Police Service Commission, the Inspector General of Police, the National Deposit Insurance Corporation (NDIC) and the Central Bank of Nigeria (CBN) were all served with a copy of the said letter. Copies of the response from NHRC and CBN are attached and marked ‘Exhibits J&G 6 & 7’ respectively.

56. Despite the interventions of the NHRC and CBN in their respective letters referred to above, the 1st Respondent still failed to take any step to meet with me or my lawyers to fashion out a way to finally resolve the matter.

57. My solicitors had to write further letters to the CBN and NHRC and further reminders to the 1st Respondent before the 1st Respondent took a step in an attempt to meet me or my Solicitors. Copies of the letters are attached and marked ‘Exhibits J&G 8 (i), (ii), (iii), (iv) & (v)’.

58. When the situation became too worrisome for me and I could not cope with working with the 1st respondent as I was constantly under surveillance and looked at with suspicion by colleagues since the 1st Respondent failed to clear the air on the issue of the purportedly missing sum of money, I had no choice but to tender my resignation letter on July 29, 2019.

59. To further compound my woes, the 1st Respondent on November 5, 2019 deducted the sum of N25,962.63 (Twenty-Five Thousand, Nine Hundred and Sixty-Two Naira, Sixty-Three Kobo) from my account under the guise of what they referred to as ‘Net Indebtedness’ when in fact I never owed the 1st Respondent any debt.
D. Reliefs Sought By Applicant
60. Till date, the Respondents have not made moves to remedy the wrong done to me, which is tantamount to a violation of my Fundamental Human Rights as enshrined in the Constitution of the Federal Republic of Nigeria 1999 (as amended).

61. I eventually had no other choice than to resign from my position with the Bank as a result of the traumatic experience and the dent to my career in the Banking sector spanning over a decade; regrettably in order to further intimidate me, compound my woes and deprive me of my entitlements, my letter of resignation is still pending and yet to be acknowledged by the 1st Respondent.

62. The 1st Respondent in a bid to browbeat me into a state of helplessness proceeded on 5th of November, 2019 to empty my UBA Account No. 1011357499 by debiting same of my remaining balance of the sum of N25,962.63 (Twenty-Five Thousand, Nine Hundred and Sixty-Two Naira, Sixty-Three Kobo) for no reason.

63. This application is not frivolous as the 1st Respondent’s did not deem it fit that I appear before any internally constituted disciplinary authority to determine my culpability before spearheading my harassment and torture.

64. It will be in the interest of justice to grant this application.

65. I depose to this affidavit in good faith, conscientiously believing same to be true and in accordance with the Oaths Act.

……………………
DEPONENT
Sworn to at the Federal High Court Registry, Abeokuta,
this ____ day of ___________ 2020


BEFORE ME


COMMISSIONER FOR OATHS

She is suing United Bank for Africa, UBA for One Hundred and Fifty Million naira (N150m) for damages.

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