NBA CRISIS: He illegally Appointed ECNBA Members to Manipulate NBA Election – Four NBA Branch Chairmen drags NBA President, Osigwe SAN to Court, Hires Okutepa SAN, Yomi Aliyu SAN and 5 other SANs

Fiery Senior Advocate of Nigeria, J. S. Okutepa, SAN, alongside Yomi Aliyu, SAN, is leading a formidable legal team of five other Senior Advocates of Nigeria and several senior lawyers in representing four Nigerian Bar Association branch chairmen and members of the National Executive Council (NEC) in a high-stakes legal battle that has already shaken preparations for the 2026 National Officers’ Election of the Nigerian Bar Association.

The suit, filed before the Oyo State High Court sitting in Ibadan, challenges the legality of the Electoral Committee of the Nigerian Bar Association (ECNBA) constituted to conduct the July 2026 NBA national election. The claimants in the suit are Ibrahim Lawal, Esq., Raymond Oki, Esq., Omotan Olusola Ogunmodede, Esq., and Chief Gabriel Ojo Adekunle Ijalana, Esq., all of whom are chairmen of NBA branches and members of the NBA National Executive Council.

The defendants listed in the suit include the Incorporated Trustees of the Nigerian Bar Association, the NBA President Afam Josiah Osigwe, SAN, the Body of Benchers, and the General Council of the Bar represented by the Attorney General of the Federation. Also joined as defendants are members of the Electoral Committee including Aham Ejelam, SAN, Ibrahim Aliyu Nassarawa, Esq., Muhamad M. Nuhu, Esq., Uju Okafor, Esq., and Ume Maduka, Esq.

The claimants are asking the court to determine whether, under the Constitution of the Nigerian Bar Association (as amended in 2025), the NBA President has the power to appoint members of the Electoral Committee of the NBA (ECNBA), or whether such powers reside exclusively in the National Executive Council of the association.

According to the originating summons filed on February 18, 2026, the claimants contend that Section 10(3) of the NBA Constitution expressly confers the power to appoint the chairman and members of the ECNBA on the National Executive Council of the NBA. They argue that the purported appointment of the 5th to 9th defendants by the NBA President, Afam Josiah Osigwe, SAN, was unconstitutional, ultra vires and of no legal effect.

The claimants further argue that the subsequent adoption of the presidential report at the National Executive Council meeting held on November 20, 2025 did not amount to a valid constitutional appointment of the members of the ECNBA because the issue of appointing the committee was not part of the agenda of the meeting and NEC did not independently exercise its constitutional powers to appoint the committee members.

In the affidavit deposed to by Ibrahim Lawal, Chairman of the NBA Ibadan Branch, the claimants alleged that the NBA President lacks the constitutional authority to appoint the ECNBA and that the action amounted to a violation of the NBA Constitution.

Lawal stated that the National Executive Council of the NBA is a broad decision-making organ comprising national officers, past presidents and general secretaries of the association, chairmen and secretaries of NBA branches across the country, and other members co-opted by NEC. According to him, the requirement that NEC appoints the ECNBA is intended to ensure transparency, independence and balanced scrutiny in the process.

The affidavit further states that the constitutionally prescribed period within which the ECNBA should have been appointed by NEC, not later than December of the year preceding the election year, has already elapsed, thereby creating what the claimants describe as a constitutional dilemma in the electoral process of the association.

Beyond the constitutional questions raised, the claimants also made serious allegations of bias against the NBA President. In the affidavit, the deponent alleged that Afam Josiah Osigwe, SAN has openly endorsed a preferred candidate for the forthcoming 2026 NBA presidential election and publicly declared that he could not be neutral in the election.

The affidavit further referenced an alleged statement made by the NBA President during the National Executive Council meeting held in Maiduguri on February 5, 2026 where he reportedly stated that he had preferred candidates for the election.

The claimants also cited what they described as a similar incident during the election process of the NBA Section on Public Interest and Development Law (SPIDEL) in December 2025 at Uyo, Akwa Ibom State. According to the affidavit, the NBA President allegedly truncated the electoral process that had been initiated by the SPIDEL Electoral Committee and replaced it with appointments of his preferred candidates and associates.

The affidavit claims that the development prompted the resignation of the chairman of the SPIDEL Electoral Committee, Kunle Edun, SAN, in protest. It also referred to statements issued by candidates whose nominations were allegedly discarded following the intervention.

The claimants further alleged that the appointment of the current ECNBA members follows a pattern of unconstitutional appointments designed to manipulate the NBA election process through control of the electronic voting system used in previous elections.

According to the affidavit, successive NBA elections have been challenged in court over alleged manipulation of the electronic voting system and repeated calls for independent audit of the system have not been granted by past NBA administrations.

The claimants therefore contend that allowing the present ECNBA to conduct the 2026 election would threaten their right as members of the association to participate in a free, fair and credible election.

They are asking the court to declare that the appointment of the 5th to 9th defendants as members of the ECNBA is illegal, invalid and unconstitutional, and to restrain them from acting in that capacity or taking any steps towards the conduct of the 2026 NBA National Officers’ Election.

They are also seeking an order restraining the NBA President from participating in the constitution of the Electoral Committee or taking any role in the conduct of the election on the ground that he has allegedly exhibited bias in favour of a particular aspirant.

In addition, the claimants are asking the court to invoke the doctrine of necessity to mandate either the Body of Benchers or the General Council of the Bar through the Attorney General of the Federation to constitute a fresh Electoral Committee to conduct the election so as to avoid a constitutional vacuum that could disrupt the NBA electoral process.

The legal team representing the claimants is one of the most formidable seen in recent litigation within the legal profession. Apart from J. S. Okutepa, SAN and Yomi Aliyu, SAN, the team includes Kazeem A. Gbadamosi, SAN, Soji Olowolafe, SAN, Seun Ajayi, SAN, R. O. Balogun, SAN, and Tunji Ogunrinde, SAN, alongside other counsel including Ibrahim Mukhtar, Taiwo Adedeji, Tope Alabi, Ejuro Uruejoma, and R. O. Solahudeen.

Meanwhile, the Oyo State High Court presided over by Justice G. A. Opayinka has already granted an interim order restraining the 5th to 9th defendants from parading themselves as chairman, secretary or members of the ECNBA or participating in any process relating to the conduct of the 2026 NBA election pending the determination of a motion on notice for interlocutory injunction.

The court also restrained Afam Josiah Osigwe, SAN from taking any steps toward the constitution or composition of the Electoral Committee or interfering in the conduct of the 2026 NBA National Officers’ Election pending the hearing of the motion.

The case has been adjourned to March 12, 2026 for the hearing of the motion for interlocutory injunction.

 

CLAIMS OF THE CLAIMANTS

ORIGINATING SUMMONS

LET THE DEFENDANTS;

Within 30 days after service of this summons on you, inclusive of the day of such service, cause an appearance to be entered for you to this summons, which is issued upon the application of the Claimants, IBRAHIM LAWAL, ESQ. and RAYMOND OKI, ESQ. whose Address is C/O her Counsel Messrs TUNJI OGUNRINDE SAN & CO. for the determination of the following questions:

1. Whether, having regard to the provisions of Section 6(6)(b) of the Constitution of the Federal Republic of Nigeria, 1999 (as amended) vis-à-vis the provisions of Section 10(3) of the Constitution of the Nigerian Bar Association, (as amended in 2025), the powers to appoint members of the Electoral Committee of the Nigerian Bar Association (ECNBA) which was expressly and specifically conferred on the National Executive Council of the Nigerian Bar Association can validly be exercised by the 2nd Defendant in contravention of the provisions of the said NBA Constitution and in such a manner to deny the Claimants the right to vote in a free and fair election devoid of bias and manipulation of the electoral process. Flowing from Question 1 above are the following Questions;

2. Whether upon a proper construction of the provisions of Section 10(3) of the Constitution of the Nigerian Bar Association, (as amended in 2025), the purported appointment of the 5th – 9th Defendants by the 2nd Defendant as members of the Electoral Committee of the Nigerian Bar Association (ECNBA) for the conduct of the 2026 NBA National Officers election and/or approval confirmation of the said appointment by the National Executive Council of the NBA at its meeting held on 20% December, 2025, are not ultra vires, unconstitutional and of no legal effect whatsoever.

3. Whether in view of Section 9(5)(iv) and Paragraphs 5 and 6 of Part II to the 2nd Schedule to the Constitution of the Nigerian Bar Association, (as amended in 2025), the 2nd Defendant as President of the Nigerian Bar Association who has the responsibility under the NBA Constitution to provide direction and leadership to all the Committees of the Association including the Electoral Committee of the Nigerian Bar Association (ECNBA) charged with the responsibility to be neutral, impartial and to conduct free and fair election into the National Offices of the Association, ought not to be neutral and avoid any exhibition of bias and partiality in favour of any aspirant or candidate for election into National Offices of the Association.

4. Whether, in view of the provisions of Section 10(3) and paragraph 7 of Part IV of the 2nd Schedule to the Constitution Of the Nigerian Bar Association, (as amended in 2025) and considering that election into National Offices of the Nigerian Bar Association Election is due to be held in the month of July, 2026; whether the National Executive Council of the Nigerian Bar Association can validly exercise its constitutional powers to appoint members of the Electoral Committee of the Nigerian Bar Association (ECNBA) outside the constitutionally prescribed period.

5. Whether in view of the provisions of Section 10 (2) & (3) of the Legal Practitioners Act, Cap L11, LFN 2004 and having regard to the fact that by virtue of Section 10(3) of the Constitution of the Nigerian Bar Association (as amended in 2025), the due appointment of the members of the ECNBA for the conduct of the 2026 NBA National Officers election has become impracticable owing to lapse of the constitution all prescribed period for doing same, also considering that the Constitution of the Nigerian Bar Association, (as amended in 2025) and the Legal Practitioners Act did not provide any remedy for such situation; whether the special circumstances created thereby which is capable of preventing the conduct of the said 2026 NBA National Officers election does not warrant the invocation of the doctrine of necessity to ensure the appointment of members of the ECNBA by the 3rd Defendant and/or 4 Defendant to oversee the conduct of the 2026 NBA National Officers election and ensure that no vacuum is created by the constitutional lapse.

UPON the resolution of the above questions, the Claimants pray this Honourable Court for the following reliefs:

1. A DECLARATION that by the provisions of Section 6(6)(b) of the Constitution of the Federal Republic of Nigeria, 1999 (as amended) vis-à-vis the provisions of Section10(3) of the Constitution of the Nigerian Bar Association, (as amended in 2025) the powers to appoint members of the Electoral Committee of the Nigerian Bar Association (ECNBA) for the conduct of elections into National Offices of the Association cannot validly be exercised by any other person not being the National Executive Council (NEC) which is the body expressly conferred with the powers to so appoint members of the ECNBA by the said NBA Constitution.

2. A DECLARATION that by the provisions of Section 10(3) of the Constitution of the Nigerian Bar Association, (as amended in 2025) the 2nd Defendant being the President of the Nigerian Bar Association cannot validly exercise powers not conferred on him by the NBA Constitution to purportedly appoint members of the Electoral Committee of the Nigerian Bar Association (ECNBA) for the conduct of elections into National Offices of the Association contrary to the provisions of the NBA Constitution.

3. A DECLARATION that the purported ratification or approval/confirmation by the National Executive Council of the NBA at its meeting held on 20th December, 2025 of the appointment of the members of the Electoral Committee of the Nigerian Bar Association (ECNBA) made by the 2nd Defendant amounts to a violation and non-compliance with the provisions of Section 10(3) of the Constitution of the Nigerian Bar Association, (as amended in 2025) which mandatorily imposed the responsibility to appoint members of the ECNBA on the National Executive Council.

4. A DECLARATION that the purported appointment of the 5th to 9th Defendants by the 2nd Defendant as Chairman, Secretary and members of the Electoral Committee of the Nigerian Bar Association for the conduct of the 2026 NBA National Officers election is ultra vires i llegal, invalid and of no effect whatsoever.

5. A DECLARATION that by the provisions of Section 10(3) and paragraph 7 of Part IV of the 2nd Schedule to the Constitution of the Nigerian Bar Association. (as amended in 2025) and in view of the fact that elections into National Offices of the Nigerian Bar Association Election is due to be held in the month of July, 2026; the constitutionally prescribed period within which the National Executive Council of the Nigerian Bar Association NEC) Ought to validly exercise its constitutional powers to appoint members of the Electoral Committee of the Nigerian Bar Association (ECNBA) to conduct the 2026 NBA National Officers election has elapsed and the said powers cannot C be validly exercised by NEC outside the constitutionally prescribed period.

6. A DECLARATION that the constitution of the Electoral Committee of the 1st Defendant consisting of the 5th – 9th Defendants by the 2nd Defendant who has consciously or unconsciously shown bias in the election constitutes a denial of the right of the Claimants to participate in a free, fair and credible election of the 1st Defendant and a breach of the Constitution of the Association which he has subscribed to.

7. AN ORDER of this Honourable Court restraining the 5th – 9th Defendants from parading themselves or otherwise acting as Chairman, Secretary or members of the Electoral Committee of the Nigerian Bar Association (ECNBA) or from taking any steps or acting in any manner whatsoever towards the conduct of the 2026 NBA National Officers election.

8. AN ORDER of this Honourable Court restraining the 2nd Defendant who has exhibited unrestrained bias in favour of an aspirant to the office of the NBA President in the 2026 NBA National Officers election, from taking any step or participating in the process of constituting the members of the Electoral Committee of the NBA or taking any part whatsoever in the conduct of the said election.

9. AN ORDER of this Honourable Court mandating the 3rd and/or 4th Defendants to constitute the Electoral Committee of the Nigerian Bar Association and to generally monitor and oversee the free, fair and transparent conduct of the 2026 Nigerian Bar Association National Officers election.

10.AND FOR SUCH ORDERS OR FURTHER ORDERS that this Honourable Court may deem fit to grant in the circumstances.

This Summons was taken out by Messrs by  J. S. OKUTEPA, SAN, CHIEF YOMI ALLIYU, SAN, KAZEEM A GBADAMOSI, SAN, SOJI OLOWOLAFE, SAN, SEUN AJAYI, SAN, R. O. BALOGUN, SAN, TUNJI OGUNRINDE, SAN, IBRAHIM MUKHTAR, ESQ. TAIWO ADEDEJI, ESQ., TOPE ALABI, ESQ., EJURO URUEJOMA, ESQ. R. O. SOLAHUDEEN, ESQ. whose address is TUNJI OGUNRINDE SAN & CO. YEKOGUN CHAMBERS, of 14, SANUSI AKERE STREET, OLUYOLE ESTATE, IBADAN, OYO STATE, NIGERIA.

This case was filed on the 18th of February 2026

 

AFFIDAVIT IN SUPPORT OF ORIGINATING SUMMONS

I, IBRAHIM LAWAL ESQ, Adult, Male, Nigerian of Aare Afe Babalola Bar Centre, NBA House, Iyaganku, Ibadan, Oyo State do hereby make oath and state as follows:

1. That I am a Legal Practitioner, a member of the Nigerian Bar Association who has the right to vote in the Association’s elections.

2. That I am currently the Chairman of the Nigerian Bar Association, Ibadan branch and also a member of the National Executive Council of the Nigerian Bar Association (NBA- NEC) by virtue of which I am conversant with the facts of this case.

3. That I am aware that the 2nd, 3rd and 4th Claimants are currently the respective Chairmen of Ilesa, Ikare and Owo branches of the Nigerian Bar Association and also members of the National Executive Council of the Nigerian Bar Association (NBA-NEC).

4. That the facts to which I herein depose in this Affidavit are, except otherwise stated, facts within my personal knowledge and I have the permission and authorities of the 2nd, 3rd and 4th claimants to depose to this affidavit.

5. That know the Ist Defendant as a registered professional association of Legal Practitioners in Nigeria.

6. The 2ad Defendant is the President of the Nigerian Bar Association and responsible for the general administration of the Association.

7. The 3rd Defendant is the body of legal practitioners of highest distinction in the Nigerian Legal Profession with powers to carry out oversight function over the Nigerian Bar Association, particularly as it relates to disciplinary, regulatory and succession issues.

8. The 4h Defendant, the Honourable Attorney General of the Federation, is being joined in his capacity as Chairman and in representative capacity of the General Council of the Bar, a body responsible for issuing regulations on professional conduct and ethics for Nigerian lawyers and also involved in management of the general affairs of the 1s Defendant,

9. The 5th Defendant is he person purportedly appointed by the 2nd Defendant as the Chairman of the Electoral Committee of the Nigerian Bar Association (ECNBA) for the conduct of the 2026 NBA National Officers election which is due to be held in the month of July, 2026.

10.The 6th Defendant is the person purportedly appointed by the 2nd Defendant as the Secretary of the Electoral Committee of the Nigerian Bar Association (ECNBA) for the conduct of the 2026 NBA National Officers election which is due to be held in the month of July, 2026.

11.The 7th to 9th Defendants are persons Purportedly appointed by the 2nd Defendant as members of the Electoral Committee of the Nigerian Bar Association (ECNBA) for the conduct of the 2026 NBA National Officers election which is due to be held in the month of July, 2026 pursuant to the Constitution of the Nigerian Bar Association, (as amended in 2025).

12. That I know that another cycle of Election of the National Officers of the Nigerian Bar Association is scheduled to hold in July, 2026 where by the Constitution of the NBA, I have the right to vote and be voted for in a free and fair election.

13. That I know that the Constitution of the Nigerian Bar Association established an independent body to be known as the Electoral Committee of the Nigerian Bar Association (the ECNBA) to oversee the conduct of elections into the National Offices of the Association. A copy of the Constitution of the Nigerian Bar Association (as amended in 2025) is hereby attached and marked as Exhibit A.

14. That I am also aware that the Constitution of the Nigerian Bar Association made provisions for the appointment of the Chairman and Members of the Electoral Committee of the Nigerian Bar Association (the ECNBA) to be made by the National Executive Council of the Nigerian Bar Association (the NBA-NEC).

15. That contrary to the provisions of the Constitution of the Nigerian Bar Association, as amended in 2025) the 2nd Defendant being the President of the Nigerian Bar Association purportedly appointed the 5th – 9th Defendants as Chairman, Secretary and Members of the Electoral Committee of the Nigerian Bar Association for the purpose of conducting the 2026 NBA National Officers election which is due to be held in the month of July, 2026.

16. That following the said purported appointment of the 5th to 9th Defendants, the 2nd Defendant by his Presidential Report/speech at the quarterly meeting of the National Executive Council of the Nigerian Bar Association held on 20th November, 2025 conveyed the said appointment to the NBA-NEC.

17. That the NBA NEC at its said quarterly meeting adopted the said Presidential Report/speech containing the appointment of the 5th – 9th Defendants as made by the 2nd Defendant to oversee the conduct of the 2026 NBA National Officers election which is due to be held in the month of July, 2026.

18. That I know that the 2nd Defendant lacks the powers under the Constitution of the Nigerian Bar Association, (as amended in 2025) to appoint the 5th 9th Defendants as the Chairman, Secretary and members of the Electoral Committee of the Nigerian Bar Association.

19. That I am also aware that under the Constitution of the Nigerian Bar Association, (as amended in 2025) the power to appoint the Chairman and members of the Electoral Committee of the Nigerian Bar Association resides in the National Executive Council (NBA-NEC).

20. That I know that the NBA-NEC is an important and reputable decision making organ of the Nigerian Bar Association with wide membership spread cutting across different interests and demography within the Nigerian Bar Association with its membership comprising the following: a. National Officers. b. All past Presidents and General Secretaries. c. All chairmen and secretaries of registered Branches. d. Chairmen and Secretaries of Sections and Fora e. Other deserving members not exceeding 150, co-opted by the National Executive Council.

21. That the appointment of th Members of the ECNBA by the NBA-NEC ensures that the process of the appointment is subjected to a balanced scrutiny by a neutral and independent organ of the Association and devoid of mundane considerations or whims and caprices of any single individual.

22. That I am aware that the NBA NEC at its quarterly meeting held on 20th November, 2025 did not appoint the 5th- 9th Defendants as members of the Electoral Committee of the Nigerian Bar Association but merely adopted the NBA President’s Report/speech wherein the 2nd Defendant conveyed to NBA NEC his appointment of the 5th- 9th Defendants as members of the ECNBA.

23. That I know that apart from adopting the NBA President’s Report/speech wherein the 2nd Defendant conveyed to NBA NEC his appointment of the 5th- 9th Defendants as members of the ECNBA, the NBA NEC did not by itself appoint the 5th – 9th Defendants as required by the NBA Constitution as the appointment of the members of the ECNBA was not part of its agenda for the said quarterly meeting of 20th November, 2025. The minutes containing he agenda of the NBA NEC quarterly meeting held on 20th November, 2025 is hereby attached as Exhibit B.

24. That I know for a fact that the NBA NEC’s adoption of the NBA President’s Report wherein the 2nd Defendant conveyed his appointment of the 5th – 9th Defendants as members of the ECNBA does not amount to appointment in compliance with the relevant provisions of the Constitution of the Nigerian Bar Association, (as amended in 2025).

25. That I am aware that the appointment of the 5th – 9th Defendants as members of the ECNBA by the 2nd Defendant who has no such powers under the NBA Constitution is a gross violation of the Constitution of the Nigerian Bar Association, (as amended in 2025).

26. That the NBA Constitution mandates the NBA-NEC to appoint the Chairman and members of the ECNBA at a period not later than the month of December of the year preceding the election year.

27. That the NBA National Officers election is due to be held in the Month of July, 2026 to elect new National Officer to take over from the incumbent National Officers whose tenure is due to end in August, 2026.

28. That I know that the Chairman and members of the ECNBA for the conduct the 2026 NBA National Officers election ought to have been duly appointed by the NBA-NEC at a time not later than the month of December, 2025.

29. That the time prescribed by the NBA Constitution for the members of the ECNBA to be duly appointed by the NBA-NEC has since elapsed without an appointment or valid appointment of the members of the ECNBA in compliance with the NBA Constitution.

30. That I am also aware that the appointment of the 5th – 9th Defendants by the 2nd Defendant in violation of the NBA Constitution was intended to appoint persons who can serve the whims and caprices of the 2nd Defendant to manipulate the NBA 2026 election in favour of the 2nd Defendant’s preferred candidate.

31. That I know for a fact that the conduct of successive NBA National Officers elections over the years have consistently ended up in litigation over widespread manipulation f the electronic voting system to favour a preferred candidate. Copies of Court processes filed to challenge the outcome of successive NBA elections are hereby attached as Exhibit C.

32. That despite several litigations challenging the outcome of successive NBA elections and repeated demands for an audit of the electronic voting system, successive NBA administrations and the ECNBA appointed by the successive NBA Presidents in violation of the NBA Constitution have refused to allow an independent audit of the electronic voting system in a manner that clearly suggest attempt at cover-up.

33. That the appointment of the 5th – 9th Defendants by the 2nd Defendant in violation of the, provisions of the NBA Constitution follows a pattern of illegal appointment of members of the ECNBA to serve the whims and caprices of the NBA President who appointed them to manipulate the NBA election in favour of their preferred candidates.

34. That the 2nd Defendant being the President of the Nigerian Bar Association and who ought to be neutral and non-partisan has exhibited unrestrained bias and open endorsement of his preferred candidate for the NBA 2026 election using official platforms of the Nigerian Bar Association to promote his preferred candidate.

35. That I am aware that one of such instances where the NBA President exhibited pubIic endorsement of his preferred candidate and used the official platform of the Association to promote the said candidate was during the “Unbarred Party” organized by the Nigerian Bar Association at the 2025 Annual General Conference of the Association held in Enugu which provoked a lot of reactions and condemnation from members of the Association on social media platforms.

36. That I also know that the 2nd Defendant openly declared at the NBA-NEC meeting held On 5th February, 2026 at Maiduguri that he cannot be neutral in the forthcoming 2026 NBA National Officers Election as he has his preferred candidates. The said open declaration by the 2nd Defendant is reported in the publication of 7th February, 2026 by The Nigeria Lawyer authored by Unini Chioma is hereby attached as Exhibit D.

37. That the appointment of the 5th to 9th Defendants by the 2nd Defendant in violation of the NBA Constitution was made in furtherance of the 2nd Defendant’s intention to ensure that the 2026 NBA election is manipulated in favour of his preferred candidates.

38. That I am aware that the 2nd Defendant has a penchant for undermining the NBA Constitution and manipulating established processes of the Nigerian Bar Association, to suit his whims and caprices and to unduly favour his preferred candidates and cronies.

39. That I know that at the NBA Section on Public Interest and Development Law (NBA- SPIDEL) Conference held in Uyo, Akwa Ibom State, between 1st – 5th December, 2025 the 2nd Defendant truncated the election process that was set in motion by the NBA- SPIDEL Election Committee to elect the new executive of the Section in order to pave way for him to appoint his preferred candidate and cronies into the executive of the NBA- SPIDEL.

40. That the 2nd Defendant ensured that duly nominated and screened candidates for the said NBA-SPIDEL election but who were not his preferred candidates including one Dr. Anne Uruegi Agi who was nominated unopposed, were discarded and replaced by the anointed candidates and cronies of the 2nd Defendant.

41. That the decision of the 2nd Defendant to truncate a democratic process of election by the NBA-SPIDEL Electoral Committee and to appoint his preferred candidates prompted the resignation of the Chairman of the NBA-SPIDEL Electoral Commitee, Mr. Kunle Edun, SAN in protest.

42. That I am aware that some of the duly nominated and screened candidates for the said NBA-SPIDEL election such as Dr. Anne Uruegi Agi and one Barbara Tosan Onwubiko, Esq whose election were truncated by the 2ad Defendant issued Statements to detail how the 2ad Defendant disrupted and truncated the said election and appointed his preferred candidates and cronies. The statement contained in the publications of December 9, 2025 by BarristersNG.com is hereby attached as Exhibit E.

43. That I am aware that the 6th Defendant who was purported]v appointed as the Secretary of the ECNBA to conduct the 2026 NBA National Officers Election, has demonstrated his readiness and willingness to do the bidding of the 2nd Defendant as he was the person directed by the 2nd Defendant to announce the individuals appointed by the 2″d Defendant as the appointed executive member of the NBA-SPIDEL following the truncation of the election process.

44. That the 2nd Defendant has demonstrated that he cannot be trusted to provide a level playing field for all candidates who will contest the 2026 NBA National Officers election as he has avowed his lack of neutrality and shown the capacity to manipulate and disrupt electoral process to favour his preferred candidates.

45. That given the roles played by the 2nd and 6th Defendants in truncating the NBA-SPIDEL election, they have demonstrated that the ECNBA appointed by the 2nd Defendant in violation of the NBA Constitution, (as amended in 2025) is intended to serve the bidding of the 2nd Defendant to manipulate the 2026 NBA Election in favour of the 2nd Defendant’s preferred candidates.

46. That my right to vote in a free and fair election devoid of bias and manipulation of the electoral process and outcome will be gravely affected if the unconstitutional appointment of the 5th – 9th Defendants by the 2nd Defendant as Chairman, Secretary and members of the ECNBA is allowed to stand.

47. That as a member of NBA-NEC, the purported appointment of the 5th-9th Defendants by the 2nd Defendant deprived me of the right to participate in the appointment of the Chairman and members of the ECNBA to conduct the 2026 NBA National Officers election.

48. That I know that the only way a free, fair and transparent election can be conducted in the NBA 2026 National Officers’ election is by ensuring that the ECNBA appointed by the 2nd Defendant in contravention of the NBA Constitution, (as amended in 2025) is restrained from conducting the said election.

49. That it will be in the interest of justice to restrain the 5th to 9th Defendants from acting or taking any step whatsoever towards the conduct of the 2026 NBA National Officers election and to mandate a neutral and independent body such as the 3rd Defendant to conduct the said election.

50. That the intervention of this Honourable Court is necessary in the circumstance to avert uphold the sanctity and binding nature of the 1st Defendant’s Constitution and to avert an impending constitutional crisis in the affairs of the 1st Defendant.

51. That unless and except this Honourable Court intervenes, my right as member of the association to participate in the choice of candidates in a free and fair contest will be threatened, endangered or even be denied.

52. That I depose to this affidavit conscientiously believing the contents to be true and correct and in accordance with the Oath Act LFN 2004.

Sworn to at the High Court of Oyo State Registry, Ibadan This 19th day of February 2026