The National Chairman
Peoples Democratic Party (PDP)
Plot 1970, Michael Okpara Street
Wadata Plaza, Wuse Zone 5
FCT, Abuja.

Attention: H.E. Sen. Dr. Iyorchia Ayu
My Highly Distinguished Chairman Sir,


We act as Solicitors to Dr. Adedipe Dauda Ewenla (hereinafter referred to as Our Client) and we have his instructions to petition your esteemed office on the above subject.

Pardon us for encroaching on your very tight space by writing you this letter. Being a loyal party member, our client has no alternative other than to exploit all party avenues at ventilating his concerns and grievances on this topical issue through your office. The exigencies of the moment, coupled with the unusual silence by our party on the mischiefs at the acclaimed inconclusive primaries compelled this one.

The Independent National Electoral Commission (INEC) Supervised the primary election and Police.DSS. Civil Defense Corp’s in the House of Representatives held in Alimosho Local Government Area at Sugarland Hotel, off Onilewura Street, Liasu Road, Egbe, Lagos on Sunday, 22nd May, 2022 and to the best of our clients knowledge, information and belief, the said election was peaceful, and also in substantial conformity and compliance with the provisions of the Electoral Act.

Pointedly sir, eight (8) aspirants contested in the primary elections. The scores recorded by each aspirant at the said primary election are provided hereunder as follows:

S/N Name Party Scores/Votes
Abdulhazeez Akinsanya PDP 11
Adedipe Dauda Ewenla PDP 20
Modiu Ladega PDP 1
Peter Kolawole PDP 1
Abimbola Animashaun PDP 0
Chisoba Remi Ozuba PDP 0
Lateef Olanrewaju PDP 0

We have deliberately highlighted the above scores to show that the election was hitch-free and devoid of election malpractice or violence. Be that as it may, the INEC representative still went ahead to declare the election inconclusive. Despite the announcement of results, INEC curiously announced that the election was inconclusive for no just cause. This decision was abruptly reached by the INEC representative owing to his failure to abide by the election guidelines. It is important to note that an election can only be declared inconclusive where a winner does not emerge at the first ballot.

Our client believes that the primary election had been conducted and completed in accordance with the provisions of the Constitution. Therefore, INEC has no alternative or discretion other than to announce the final result of the election and declare our client as the winner. With much respect to INEC under your very distinguished Chairmanship, the reasons given by INEC for declaring the election as inconclusive are alien to the Constitution and, therefore, unconstitutional.
With further respect to INEC, INEC is enjoined to declare a winner of an election, based on lawful votes cast. Thus, the cancelled results by INEC, for whatever reasons, and assuming without conceding that INEC could legitimately cancel such results, amount to unlawful votes. In effect, INEC cannot declare a well conducted election as inconclusive based on unlawful votes.

Notably, 35 delegates were poised for the election. Having declared the results and/or votes cast at the election therefore, one cannot come to term as to why the same election would be declared inconclusive for the simple and calculated reason that there is a shift in the number of delegates who were to cast their votes at the election. For now, INEC will find it hard to exonerate itself from the spate of inconclusive elections.

Arising from the foregoing, our client demands that you use your very high and exalted office to do what the law expects your Commission to do, that is, announce the final result of the election forthwith, and declare our client as the winner of the primary election. Mr. Chairman sir, this is a rather simple and straight-forward matter which does not need any delay, foot-dragging or procrastination. It is a constitutional imperative. Put in another way, INEC has a bounden duty to declare our client as the winner of the election.

Again, it is the duty of INEC to champion the actualization of a free and fair election. In this wise, we most humbly advise and caution that the party should be minded of the activities of some mischief-makers who are out to decimate the name and image of our party in the most undemocratic manner. INEC is not empowered to declare any election inconclusive, once the constitutional threshold for victory has been met. However, if our electoral process is as transparent and fair as it should be, there should be no reason for this apprehension.
Mr. Chairman sir, we are ready and prepared to further articulate and defend this position of our client, either with you or your Executive members, and/or with you and your party Legal Advisers and consultants whatsoever or howsoever called at any time or forum chosen by you. But one point must be made clear, that is, our client is not ready or prepared to trade off or compromise his mandate as the choice of his people. Our client also does not want to believe that he is being discriminated against for whatever reason.

Please accept the assurances of our committed and value-driven professional service.

Yours faithfully,
For: Okenile LP

Akinwole Okenile, Esq.
Cc: (1) All National Working Committee Members (NWC)
(2) PDP, Lagos State Chapter
(3) PDP, Alimosho Local Government Chapter




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