IN
THE HIGH COURT OF JUSTICE OGUN STATE OF NIGERIA
IN
THE SANGO-OTA JUDICIAL DIVISION
HOLDEN AT SANGO-OTA
AFFIDAVIT ON HOW METAL WAS INSERTED INTO MY VAGINA
AT AGBARA POLICE STATION, AGBARA, OGUN STATE
I,
QUEEN AKINDELENI, Female, Nigerian,
Christian, of Anu Oluwa Complex, Jolu Road, Sango-Ota, Ogun State, do make oaths
and states as follows:
1.
That I was the suspect in the CASE OF COMMISSIONER OF POLICE VS. QUEEN
AKINDELINI, with CR. NO.921/2009
and CHARGE NO. MAA/23C/2009 by
virtue of which I was familiar with the facts of the case, and all that happened
in the cause of investigation, detention and release
thereafter.
2.
That I depose to this Affidavit with consent of my
children Charles Ighovoyiwi and Esther Ighovoyiwi
3.
That I was a property developer and seller of
building materials at Edu Agbara, Ogun State prior to my arrest, detention and
injuriously torture sometimes in October, 2009.
4.
That the allegation made against me was that I was responsible for the death of
Mr. Ayodele Akindeleni whose where about could not be ascertain at the time when
the matter was reported at Agbara Police Station, Agbara, Ogun State.
5.
I went to Agbara Police Station, Agbara,Ogun State,
myself on the 12th of October 2009 to report the matter after I was
threatened by the family of Mr. Ayodele Akindeleni that they will kill me and my
Children, Charles Ighovoyiwi and Esther Ighovoyiwi, if I did not tell them the
where about of Mr. Ayodele Akindeleni.
6.
That after I made the compliant on the threat to my
life and the lives of my children, I was not permitted to leave the Police
Station, and as my children came one after another to look for me, they were
also arrested.
7.
That they expected me to make a confessional
statement that I killed Mr. Ayo Akindeleni, after his family member, James
Akindeleni, came to complain.
8.
That the D. P. O. of Agbara Police Station at that
material time told the team investigating the case that they should not call the
case murder case, but rather missing of Mr. Ayo
Akindeleni.
9.
That my son Charles was the first person to come
and look for me after he came back from school and it was the heavy noise of his
cry that made me knew he was around.
10.
That Charles later told me and I believe it to be
true that it was the back of a gun that was used to hit him at his legs.
11.
That I did not know anything about the
disappearance of Mr. Ayodele Akindeleni, neither was I responsible for his
alleged death.
12.
That on a Saturday I was taken to one bush to go
and see one skeleton/Carcass they called the carcass of Mr. Ayo Akindeleni.
13.
That the next day which was Sunday the team of
Police Officers who investigated the case at Agbara Station, excluding DCO 1,
whose name I did not know, and the D. P. O., came to station and took me
out.
14.
That the team of Police Officers who investigated
the case at the Police Station ,Agbara, Ogun State, tortured me with cruelty
that I must confess that I killed the alleged deceased
person.
15.
That I can only remember the first names of two out
of the team of Police Officers who were involved in this case at Agbara Police
Station, Agbara, Ogun State; the first names are Shadrach ( DCO 2) and Raphael.
16.
That Shadrach gave me one straight metal with four
corners, which looked like window aluminium to carry and tell him whether it was
heavy or not.
17.
That I told him the metal was heavy and he took it
from me and Shadrach started using it to beat me repeatedly on the left side of
my body from up to down.
18.
That later the three other Police Officers joined
him (Shadrach), they beat me with the metals in their hands and led me to the
Barrack (the Police residence within the premises), as I was struggling to climb
the veranda Shadrach used the metal in his hand to strike me hard at my back, I
fell down immediately and could not stand.
19.
That as
they were doing these I was screaming and wailing with pain that was beyond
description.
20.
That I was
held into a bathroom.
21.
That I was asked to remove my under wear (pant).
22.
That the team of Police Officers who investigated
the case asked a female officer, whose name I could not remember, to insert the
metal which Shadrach gave her into my vagina.
23.
That the Female Police officer asked me to be
screaming as if she has inserted it and I did as she instructed
me.
24.
That the Female Police officer told them that she
had inserted the metal into my vagina but I did not
confess.
25.
That Shadrach came to the bathroom and took the
metal from the female officer and tried to perceive it smell/odour to confirm if
it was truly inserted into my vagina.
26.
That he (Shadrach) discovered that the metal was
not inserted into my vagina, he took it himself and held me with force to the
ground, with my legs wide opened and forcefully inserted the metal into my
vaginal.
27.
That as he (Shadrach) inserted it (the metal) I
screamed with the whole of my strength and I felt as if life had gone out of
me.
28.
That
immediately he removed the metal I faintly saw a heavy rush of blood out of my
vagina, but was weak and helpless.

29.
That I was
held and partially carried back to the passage of the Police Station, Agbara
where I was laid on the floor.
30.
That as I
was there on the floor blood continued to flow and I discovered that I
eventually fainted, because I woke up and I saw myself soaked with
water.
31.
That when the D. P. O. of the Police Station saw
me, he was surprised and asked whether they tortured me and they responded that
they did not torture me.
32.
That I was not attended to by anyone and I started
smelling.
33.
That about four days later a man was invited to
examine me and they later brought drugs for me to use.
34.
That I discovered that with the drugs I was given
the flow of blood reduced.
35.
That I discovered that urine was just leaking out
of my vagina and I could not control it at all.
36.
That my daughter Esther Ighovoyiwi who was twelve
(12) year old at the material time was arrested on the same allegation at Agbara
Police Station, Agbara, Ogun State by the team of Police Officers who
investigated the case.
37.
That while Esther Ighovoyiwi was in detention,
though only for that day when she came to look for me, at Agbara Police Station,
she was severally slapped and inhumanly assaulted, by Shadrach, to the extent
that she became sick and had her ears discharged pos uncontrollably under
groaning pain.
38.
That Esther
Ighovoyiwi was eventually released on bail after her arrest and brief detention,
which I knew, was unlawful.
39.
That my son Charles Ighovoyiwi who was Fourteen
years old (14) at the material time was arrested, detained and tortured by the
team of Police Officers who investigated the case.
40.
That the team of Police Officers that Investigated
the case in Agbara Police Station, Agbara beat up Charles Ighovoyiwi, using sticks on him and even
threatened to kill him with gun.
41.
That Charles Ighovoyiwi spent one month and twenty
nine days in detention at Agbara Police Station, Agbara without being charged or convicted of any
crime.
42.
That Charles Ighovoyiwi told me and I verily
believed him that after I was transferred to Nigeria Police Force, State
Headquarters,Elewe Eran, Abeokuta, Ogun State he was released by the influence
of one man, whose name he did not know.
43.
That I was later transferred to Nigeria Police
Force, State Headquarter, Elewe Eran, Abeokuta, Ogun State.
44.
That the Police Officers who were equally part of
the investigating team at the Nigeria Police Force, State Headquarter, Elewe
Eran, Abeokuta, knew I was tortured and blood and urine was flowing from my
vagina.
45.
That the senior officer, whose name I did not know,
summoned the team of Police Officers who investigated the case at Agbara Police
Station and he asked me to identify the person that inserted metal into my
vagina.
46.
That I identified the person as Shadrach.
47.
That I was
not provided with medical attention at Elewe Eran, Nigeria Police Force
Headquarters, Abeokuta throughout my stay there.
48.
That I was transferred to the Nigerian Prison
Service, Ibara, Abeokuta, from the Nigeria Police Force Headquarter, Elewe Eran,
Abeokuta on the 1st day of January, 2010.
49.
That I was transferred or took into the Prison
Custody, Nigerian Prison Service, Ibara, Abeokuta, Ogun State, with blood
stained clothes and I was walking
half-bent and I had to lean on someone, sometimes standing objects and walls to support
myself.
50.
That the staff of the Nigeria Prison Service,
Ibara, Abeokuta, Ogun State at the material time witnessed my
ordeal.
51.
That the staff of the Nigeria Prison Service,
Ibara, Abeokuta, Ogun State at the material time, including the medical
personals at the Prison’s Clinic knew that my vagina was releasing urine
uncontrollably and I had chronic pains in my back, bones and other parts of my
body.
52.
That I was given treatment in the Clinic of the
Nigeria Prison Service, Ibara, Abeokuta, Ogun State, and I was referred to
Federal Medical Centre, but there was no money for my treatment.
53.
That I was not taken to any Hospital for treatment
outside the Nigeria Prison Service, Ibara, Abeokuta, Ogun
State.
54.
That I was
interviewed by delegates from Citizens’ Right Department, Ministry of Justice,
Oke Mosan, Abeokuta, Ogun State, while in the custody of Nigeria Prison Service,
Ibara, Abeokuta, Ogun State.
55.
That I was also interviewed by one Barr. Ashaolu
Joshua Olabowale , sometimes in July, 2010, who I identified as a member of the
National Youth Service Corps because of the NYSC uniform he wore at the welfare
Department, Nigeria Prison Service,
Ibara, Abeokuta.
56.
That Barr. Ashaolu Joshua Olabowale told me and I
very believed him to be true that he was serving with Ministry of Justice Ogun
State as 2010/2011(BATCH A) member.
57.
That Barr. Ashaolu Joshua Olabowale told me that he
was interested in my case.
58.
That on subsequent visit to the Nigeria Prison
Service, Ibara, Barr. Ashaolu Joshua Olabowale told me and I verily believe him
to be true:
a.
That he was handling my case personally, but was
supervised by a senior State Counsel at the Citizens Right Department, Ministry
of Justice, Ogun State.
b.
That he went to the Registry of the Ministry of
Justice, Ogun State, requested for the Case File of C. O. P. Vs. Queen
Akindeleni and it was found.
c.
That in the case file he saw the
following:
I.
That the title of the Case is Commissioner of
Police Vs. Queen Akindeleni;
II.
That the CR No. is
921/2009;
III.
That the Charge No. is
MAA/23C/2009;
IV.
That I was arraigned at the Chief Magistrate Court
Agbara;
V.
That the officers of the Nigeria Police Force
revealed in the Case File are ASP Peter Aremu, DSP. Olufemi Olabode, Inspector
Raymond Obigbara, Sgt SDP Olaide Lawal, W/CPL Philomona Imharia, etc. ;
VI.
That facts about the detention and subsequent
release on bail of my Children were contained in the case file, particularly
Esther Ighovoyiwi.
VII.
That the main evidence or exhibit revealed in the
case file was the carcass/skeleton of a human being that was seen in a
bush.
VIII.
That there was no proof or investigation on whether
the missing man, alleged to have died was actually dead.
IX.
That there was no investigation to find out whether
the alleged carcass/skeleton was that of a Mr. Ayodele Akindeleni alleged to be
killed by me, Mrs. Queen Akindeleni.
X.
That no scientific means of identification was
adopted to prove that the alleged Carcass/skeleton was that of the man, Mr.
Ayodele Akindeleni alleged to be dead.
XI.
That the advice of the Director of Public
Prosecution, Ministry of Justice, Ogun State, was clear and
unambiguous.
XII.
That the advice was to the effect that “ Mrs. Queen Akindeleni Could not be linked
with the offence alleged ,therefore, should not be charged”

59.
That I was released on 2nd of
September,2010 by the Order of the Chief Magistrate Court, Agbara based on the
Advice of the Director of Public Prosecution, Ministry of Justice, Ogun
State.

60.
That I was made to understand that the allegation
against me was frivolous, baseless and lacks merit, particularly considering the
facts and evidence of the police.
61.
That I know that I and my children suffered for
what we did not know about.
62.
That after
my release from the Prison Custody Barr. Ashaolu Joshua Olabowale took me to the
Federal Medical Centre, Idi Aba, Abeokuta, where I was examined at the
Department of Obstetrics & Gynaecology and I was asked to run several
tests.
63.
That my
Hospital Card number is 80626.
64.
That after the medical examinations and tests were
carried out, Barr. Ashaolu Joshua applied for my Medical
Report.
65.
That the Medical Report dated 28th
October, 2010 signed by Dr. D. O. Awonuga was given to him. The said Medical
Report of Mrs. Queen Akindeleni is hereby attached and marked as “EXHIBIT
A”.


66.
That among other health issues, I was confirmed to
have Vesico-Vaginal Fistula (VVF),
which it main symptom is continuous involuntary discharge of
urine, because of the abnormal openings in the internal parts of my
genital/vagina caused by the metal the Police Officer inserted into my Vagina.
67.
That I was scheduled to undergo further examination
which I was preparing for when I lost contact with Barr. Ashaolu Joshua
O.
68.
That all my efforts to get him proved abortive,
because I left the place where I was squatting and I was not using a mobile
phone.
69.
That I did
not hear from him or see him till the end of his stay in
Abeokuta.
70.
That I went to the Citizen’s Right Department,
Ministry of Justice, Abeokuta, Ogun State and I was told to go and treat myself
because they cannot take up the matter for me.
71.
That I was told by one of the Doctors that examined
me that my case requires a major repair surgery and I know it must be very
expensive.
72.
That I could not go for the final examination and
treatment because I had no money.
73.
That I called Barr. Ashaolu Joshua O. with my
mobile phone on the 10th of September, 2012 after I saw his mobile
phone number in my Holy Bible where I wrote it.
74.
That I told him am still living with my situation
and it is even worst now, because I ooze foul odour and release urine
involuntarily, apparently an effect of a ruptured bladder occasioned by the
inhuman torture I suffered in the hands of the Investigating Police Officer at
Agbara Police Station, Ogun State.
75.
That because I could not afford to treat myself in
Abeokuta and to avoid the way I am being openly embarrassed by the way I smell,
the way I am rejected and avoided, I relocated to a village in Ogun State, where
I now farm to survive.
76.
That I who
was a business woman before, had taken a long walk from Agbara POLICE DETENTION
TO ELEWE ERAN, ABEOKUTA POLICE DETENTION TO NIGERIA PRISON SERVICE CUSTODY TO
ABEOKUTA TOWNSHIP AS WONDERER AND NOW IN A VILLAGE IN OGUN STATE LIVING ALONE,
APPARENTLY WAITING FOR MY END.
77.
That I have been kicked out of the public, I have
to withdraw because I am often rejected and avoided.
78.
That I have lived with continuous flow of urine
from my Vagina and have used cloths among others as sanitary pad to pack my
genital/vagina for more than one thousand (1000) days.
79.
That the trauma of the barbaric acts still
frightens me.
80.
That the V.
V. F., general body and internal pains and other health issues confirmed in
my body after examinations still remain untreated.
81.
That I cannot travel a long distance.
82.
That this injustice left my children, Charles
Ighovoyiwi and Esther Ighovoyiwi with a bitter and dreadful story, which they
will live with for the rest of their lives.
83. That Charles Ighovoyiwi, who was a student of Tech 1, Technical College Igbesa, Ogun State missed all school activities for a whole school term.
84.
That
Esther Ighovoyiwi (age 12) who was a student of Edu Agbara Community Secondary
School had to leave school and fend for herself.
85.
That now
they are drop out and have no hope of going back to school.
86.
That
Esther had to become a mother when she never wanted.
87.
That I
wanted nothing in my case, but justice.







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