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The Family Head Ojora Royal Family 16, Ojora Palace, Ijora-Lagos. Dear Sir, RE: PURPORTED ATTEMPT TO FORCIBLY TAKE OVER DEVELOPED PROPERTY LYING AND SITUATE AT 114/128 0JO ROAD AJEGUNLE LAGOS IN VALID POSSESSION/OWNERSHIP OF OUR CLIENT IN GESTAPO AND UNLAWFUL MANNER DEPRECATED BY LAW. We act as Solicitors to the Surviving Children of ANTHONY EZEUDU and CHRISTOPHER OKOLI represented MRS JONES-NDUKA ANTHONIA EZEUDU(Nee- Ezeudu) and MR. GODWIN OKOLI both of No 114/128 0jo Road, Ajegunle Lagos Hereinafter jointly refered to as “Our Clientʺ and your cusomary tenant in respect of the above mentioned parcel of land and we have their express unrequivocal instruction to write you in respect of the above subject matter Our client relably informed us with available document at their disposal,we have no cause to disbelieve them that the land constituting the subject matter of this letter was granted to their deceased father as customary tenant on or around 1955 upon whIch a Tenant Bungalow was erected pursuant to building approval obtained on same couple with corresponding payment of annual rent in fulfillment of the customary obligation of our client's precedessor-in-title during his lifetime and after is demised one of his children continue to honoured the obligation of payment of the annual rent until his untimely deathwhich subsequently created a vacum in the payment of the said annua rent. Attached herein are marked as Annexture A, B and C are copies of receipts issued by Chief Ajibola L.ODUNSI Ojora and The Ojora Chieftaincy Family Councl in acknowledgement of payment of annual rent on the land validly occupy by our client as your lawful customary tenant. Predicated on the subsisting customary tenancy of our clients as encapsulated by payment of annual rent, our client has EXCLUSIVE POSSESION and OCCUPATION to the land in issue upon which their building was erected with rents payment tenants in occupation till date and their right to EXCLUSIVE POSSESSION/OWNERSHIP of the land and building therein cannt be overridden or defeated by any subsequent grant by your family notwithstanding the alodial title of your family to large expanse of land at Ijora and Ajegunle including the land of our client. Whilst our client is not in anyway challenging your family title to the land granted to them as their overlord, it is the contention of our client that their land and and property cannot be unlawfully re-prossessed or forcefully taken over in gestapo manner deprecated by law,more especially when our client have not committed any GRAVE ACT to warrant this unjustifiable and condmable approach amounting to SELF-HELP REMEDY. Against the above stated position of settled law our client is however surprise, shocked and greatly embarrassed when sometime in the second week of march 2024 some persons who identified themselves as member of Ojora Family and their cohorts claiming to have the authority of his Royal Highness forcefully caused this inscription to the following “THIS LAND BELONGS TO OJORA ROAL FAMILY,16, OJORA PALACEʺ to be posted on the front wall of our client house in the absence any COMPETENT ORDER OF COURT. Moreover, we are further reliably informed that the above act of actionable trespass was followed up by the recent invitation of our clients sitting tenants to the palace of His Royal Highness by the same members of Ojora Family with warning to the tenants to desist from further payment of rents to our client as their recognized landlord. Our client claims sequel to this fact is that the present action of the family is Condemnable capricious and amount to actionable TRESPASS to the EXCLUSIVE POSSESSORY RIGHT/OCCUAPTION of our client which possession has not been Validly determined by due process to warrant the threat, harrassment and avoidable Intimidation of our client. BE ADVISED that whilst our client respect and acknowledge the allodial family title to the entire land mass in Ijora/Ajegunle including the land in issue our client shall however use the instrumentality of law and due process to resist any act of TRESSPASS in violation of the EXCLUSIVE RIGHT/POSSESSION/OWNERSHIP of their property and sitting tenants as the itemized acts perpetrated by the family member are at a variance with customary terms and conditions and the SELF-HELP REMEDY being employed by the family has been deprecated by the Supreme Court in the popular case GOVERNOR OF LAGOS STATE & ORS VS OJUKWU 2 ORS (1986) LPELR-31869(SC). BE WARNED that at the risk of repetition whilst our client is not challenging your Over lordship position, our client shall however employed the instrumentality of the law To abate any further act of harassment, intimidation actionable trespass and illegal Self-help remedy targeted at forceful and Gestapo/brazen taken over of land/property In their valid occupation and possession having not committed any grave act of Misbehavior to justify the act and behavior of the family. Without prejudice to the validity or otherwise of the challenged acts of few of the Family members who have been indecently using the name of his Royal highness, it is Our instruction to inform you that our client's is amenable to amicable ADR Resolution of the issues necessitating questionable act of the family including payment Of accumulated annual rent occasioned by the sudden death of the person paying same In the past so that cordial and friendly overlord and customary tenant relationship Subsisting between the parties can be continued unhindered devoid of litigation provided Our client is given the opportunity to be heard through the ADR process proposed. BE FURTHER INFORMED that our client as last resort shall be constrained to Approach a court of competent jurisdiction to defend their possessory and Occupational right against the family should the family fail and neglect to key into the Opportunity provided by ADR processes for amicable resolution of this matter. We shall appreciate timely consideration of our proposal for amicable resolution of this Matter in the interest of our client and innocent third party interest involved as Represented by the sitting tenants in the premises. Yours faithfully, PP: LANRE OLIYIDE & CO OKUNOLA ADENIYI ESQ.
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