RE- PETITION ON WARRI FEDERAL CONSTITUENCY DELINEATION; UIY LEGAL ADVISER BARR. ONESIOSAN S OGHOLAJA JOIN ISSUES WITH HON. BARR. JEFFREY PERE OROMONI

ONESIOSAN S. OGHOLAJA ESQ
(AWIGBALAGBALA)
NO. 5, TONY AKOMA STREET, GAS ROAD UBEJI IN WARRI SOUTH LOCAL GOVERNMENT AREA OF DELTA STATE NIGERIA.
TEL: 08106954400, 08054290636. EMAIL: ogholajason@gmail.com

17/11/2025.
The Chairman,
Independent National Electoral Commission ( INEC),
Plot 436, Zambezi Crescent,
Maitama District,
Abuja,
Nigeria.

Sir.

RE- THE LEGAL IMPLICATIONS OF THE NON- RELEASE OF THE FINAL FIELDWORK REPORT ON WARD AND POLLING UNIT DELINEATION AND THE CONTINUOUS VOTERS REGISTERATION AND OTHER ELECTORAL ACTIVITIES IN WARRI FEDERAL CONSTITUENCY; A CLARION CALL TO DISREGARD DISTORTED FACTS AND SELF SERVING NARRATIVES.

INTRODUCTION:
The above subject matter refers.
Our attention have been drawn to a Letter dated 14th November 2025 that is credited to one Hon. (Barr). Jeffrey Pere Oromoni of 2 Lotiebiri Street, Ogbe- Ijoh, Warri South West Local Government Area of Delta State and the said Letter carries the above subject matter.

Ordinarily it is not in our character to respond to crass displays of falsehood, hoodwinking of facts and parochial application of both statutory and judicial authorities as was copiously done in the Letter under discourse but as Emissaries of the rule of law and truth, we have the sacred responsibility of correcting crooked facts hence this joinder.

We write as concerned stakeholders, truthful Citizens and the Legal Advisor of the Ugbarajo Itsekiri Youth (UIY)- the apex Youth Body in Warri Kingdom in Delta State of Nigeria that represent the collective conscience of all Itsekiri Youths in particular and the whole of Warri Kingdom in general.

BARR. JEFFREY PERE OROMONI MISCONCEPTIONS:
The Supreme Court pronouncement in the case of Hon. George Timinimi &Ors v. independent National Electoral Commission (INEC) ( SC. 413/2016) is not the first and only judicial pronouncement as it concerns electoral matters in Warri federal Constituency as Barr. Jeffrey Pere Oromoni wants the World to believe. The unequivocal fact of the matter is that judgement of in Hon. George Timinimi case was clandestinely gotten by deceit, false representation and unholy/unprofessional alliance between the Ijaws and Officials of INEC. The correct facts are as follows:

1. In the year 2003, the Federal High Court gave Judgement in favour of the Itsekiris against INEC in Suit No: FHC/B/109/97 Between: Dr. Joseph Otumara & 8 ors vs. INEC & 4 Ors. INEC refused to obey the judgement hence INEC and its top Officials had been under the threat of committal for contempt.

2. Between 2003 and 2011, INEC cleverly hatched and sustained one of the biggest legal scams in human history when it conspired with the Ijaws in 2011 to secretly and willing urge the Ijaws to Institute an action against INEC over the same subject matter in Which the Itsekiris had already obtained judgment and the suit was exclusively between the Ijaws and INEC; neither the Itsekiris Who are the overwhelming majority in Warri Federal Constituency and the only ethnic nationality with significant political presence in all 3 Warri Local Government Council Areas were aware and/or joined to the suit.

3. That the later suit was what the Ijaws as the only set of Appellants, and INEC as the only Respondent prosecuted in the Supreme Court to obtain the judgment of the Supreme Court which is now being paraded by the Ijaws and INEC and ironically the Urhobos who did not even know how, where and why the suit was Instituted.

4. That even as late as 2021 before the said judgment was delivered, T.M. Inuwa, SAN, Legal Adviser and Head of the Legal Team, INEC wrote a comprehensive brief in September in which he advised INEC to comply with the judgment in favour of the Itsekiris. The brief was titled ‘BRIEF ON IMPLEMENTATION OF THE COURT ORDERS AND JUDGMENT ON THE WARD STRUCTURE FOR WARRI SOUTH LOCAL GOVERNMENT AREA OF DELTA STATE OF NIGERIA IN SUIT NO. FHC/B/109/97 – MR. JOSEPH OTUMARA & 8 ORS. V. INEC DATED 10 TH SEPTEMBER, 20211’

5. That as it turned out, T.M. Inuwa, SAN only used the said Proposal for settlement the Memorandum to buy time to enable INEC and the Ijaws obtain the Supreme Court Judgment behind the back of the Itsekiris.

6. That even after the Supreme Court Judgment was obtained by the above concealment of facts from the Supreme Court, INEC did not stop at that; it called for an augural meeting between the Ijaws and the Urhobos to constitute the Committee to manage the delineation of the Wards in the guise of obeying the Supreme Court said Judgment which was obtained by INEC and the Ijaws with the Urhobos being led in by the nose after the case had been pursued by INEC and Ijaw for 18 years and Judgment obtained.

7. That the mischief did not stop there, INEC, Ijaw and now the Urhobos midwifed the setting up of a Delineation Committee behind the Itsekiris making an Ijaw Professor, Rhoda Gumus Chairman of the Committee with the Secretary also being of Ijaw ethnic extraction.

8. The product of the grand conspiracy and the it many atrocities was efficiently mid-wifed by INEC which gave birth to the Proposal.
From the illustration above, it is incontrovertible that without the knowledge of the Honourable Judges that sat on the Panel that decided Hon. George Timinimi case, the Ijaw People and INEC used the Supreme Court as an instrument of injustice against the Itsekiri People in the light of the Warri Federal Constituency delineation matter.
it is a trite pillar of our constitutional jurisprudence that ‘ The Court will not allow such that is manifestly unjust and that which portray the law as an instrument of injustice’ ( Nullus commodum capere protest de injuria sua propria) see the cases of Supreme Court case of Owodunni v. Owodunni ( 1991) 8 NWLR ( Pt. 210) p. 391 at 421. The above principle of law was quoted in approval in the cases of Oceanic Bank International Plc v. Brokenn Agro Allied Industries Ltd (2008) LPELR- 4671 (CA), Umezinne v. Ag. Fed (2019) 11 NWLR (PT 1683) 358 at 377 paras G and the case of Enekwe v. I.M.B ( Nig.) Ltd (2006) 19 NWLR (PT. 1013) 146 at 181 paras A-B.

The question Barr. Jeffrey Pere Oromoni should answer is; why did the ijaw people and INEC clandestinely obtained judgement in Hon. George Timinimi case when the judgment of court in Suit No: FHC/B/109/97 Between: Dr. Joseph Otumara & 8 ors vs. INEC & 4 Ors was not put to the notice of the Honourable Judges at the Supreme Court?.

SOME OF THE ORCHESTRATED IRREGULARITIES IN THE INEC PROPOSED REPORT ON THE DELINEATION EXERCISE IN WARRI FEDERAL CONSTITUENCY
Despite the mountain load of irregularities, obvious corruption and other foul practices that culminated into the process that raise to supreme Court judgement in Hon. George Timinimi case, the Itsekiri People are not against the decision of the supreme Court in Hon. George Timinimi case however the Itsekiri People are totally against the INEC proposal on the delineation of Warri Federal Constituency as the said Proposal is married with stentorian irregularities, fraud and other sundry malpractices.

Pursuant to several studies that were conducted on the INEC proposal on the delineation exercise in Warri federal Constituency, many cases of orchestrated irregularities were observed. The Scope of the report entails using the coordinates provided by INEC in her proposed Ward delineation to verify the actual location and name of the said coordinate and unit as established by INEC, using Google Earth map on the Internet and hard copy of Delta State, Warri and Shell maps.
The overall observation shows a deliberate fraud in the entire delineation process and the total lack of compliance to INEC’s own guidelines in the execution of ward delineation. The following facts were uncovered:

• creating and renaming of aboriginal And Legal Communities. (INEC has no power to create Communities)

• Duplication Of Communities.

• creation of fictitious Communities to form units that make up wards.

• importation of Communities from outside the three Warri Local Government Areas (For Example Communities From Burutu, Bomadi, Ughelli South, Udu In Delta State And Also Communities From Edo And Ondo States).

• Illegal boundary adjustment (INEC took over the job of boundary adjustment).

• Manufacturing Of Voting Units Outside the voter’s register, one can not tell where INEC manufacture these new Units And Wards from since NONE of such units existed in any voter Register.

• The use of the same coordinate for multiple unites in different Wards in different Local Government Areas.

• Many of the wards created and renamed for the ijaws and Urhobos were done from land mass and communities of itsekiri, that were renamed.

• Forest and river were pinned in the coordinates provided by INEC as voting units to form wards.

• INEC assumed population of different wards in the Warri federal constituency outside of the figures captured by the last conducted censor as we are yet to conduct a new censor that should report a change in the population of the area.

• INEC assumed voting strength outside the voter register as only registered voters who are of voting age form the valid voting population of any geography in Nigeria.

• INEC against its own guidelines split wards with less than fifty units into two and up to four wards in some cases as we have observed while wards with over fifty and hundred units remained the same and unchanged.

• majority of the new wards created by INEC Failed to meet the required number of units, voting strength or voter register record of INEC to make a Ward.

• Wards created on our lands and communities can not be renamed with strange names that are not in existence but should be name with the aboriginal names of the communities making up the units of such Wards.

THE LEGAL MISNOMER INVOLVING PROF. RHODA GUMUS PARTICIPATION IN THE DELINEATION
COMMITTEE:
The fact that an Ijaw Woman chaired the Delineation Committee raises the fundamental question of fairness and the likelihood of bias. It is our candid submission that legal principle of Nemo judex in causa sua ( you can not be the judge in your case) that is enshrined in Section 36 of the 1999 Nigeria Constitution as amended see the cases of Federal Polytechnic, Ede V. Oyebanji (2012) LPELR-19695 (sic); Gyang V. COP, Lagos State (2014) 3 NWLR (Pt. 1395) 547 at 558; Assams V. Ararume (2016) 1 NWLR (Pt. 1493) 368 at 388-389 H-B; Akinwale V. Nigerian Army (supra); Akaniyene & ors V. Etim (2013) All FWLR (Pt. 709) 1167 at 1184 para B; National Union of Electricity Employees V. Bureau of Public Enterprises (2010) 7 NWLR (Pt. 1194) 538 at 570 paras B-C.

Furthermore the principle of likelihood of bias was also violated when Prof Rhoda Gumus was allowed to Chair the delineation committee. See THE SECRETARY, IWO CENTRAL LG. v. ADIO (2000) 8 NWLR (PT. 667) 115 at 135 G, ONIGBEDE v. BALOGUN (2002) 6 NWLR Pt. 762 Pg.1, this Court referred to ADEFULU v. OKULAJA (1998) 5 NWLR Pt. 550 Pg. 435
Another question that Barr. Jeffrey Pere Oromoni should answer is: whether he would accept the INEC proposal that is marred with such irregularities as enumerated above assuming he is an Itsekiri?

PRAYER:
It is against the background of the above mentioned that we humbly request you to disregard the letter of Barr. Jeffrey Pere Oromoni as same is self serving and a calculated attempt to finalize long orchestrated illegality against the Itsekiri People of Warri Federal Constituency.

For a holistic understanding of all the issues that affects the INEC proposal on the delineation of Wards and polling units in the Warri Federal Constituency we humbly refer you to an erudite expositions that are contained in the literal masterpiece titled: the Siamese Twin and Warri Federal Constituency that is co-authored by Chief Robinson Ariyo, Esq (Egogo of Warri Kingdom) and Jolone Ikomi, Esq. Through the Book, the duo of Chief Robinson Ariyo Esq and Jolone Ikomi Esq gave stellar narration and a deep insight of the many atrocities of INEC as it concerns the Warri Federal Constituency.

As Lord Hewart said in the case of R vs. Sussex Justices ex parte McCarthy ‘justice must be seen to be done’.

We demand that justice must be seen to be done in this matter as the Itsekiri Nation will no longer tolerate INEC utter disregard for the rule of law, fraudulent activities and the institutionalized bias on the Itsekiri People as reflected in the INEC proposal on the delineation exercise in the Warri Federal Constituency- in their righteous might, We are determined and within the ambits of the Law, we shall continue to resist INEC gargantuan fraudulent activities in the Warri Federal Constituency.

We are confident that INEC injustice against the Itsekiri People of Warri Federal Constituency will not be sustained as the Itsekiri Nation will collectively outlast all her adversaries including establishments like INEC.
We shall legally resist any attempt to annex Itsekiri Nation Land.

Yours Faithfully

ONESIOSAN S. OGHOLAJA ESQ
( Legal Advisor, Ugbarajo Itsekiri Youths)

CC:

The Nigerian Senate

House of Representatives, Federal Republic of Nigeria

The National Security Adviser to the President

The United Nations Electoral Assistant Division (UNEAD)

The European Union Election Observation Mission (EU- EOM)

The African Union Election Observation Mission (AU- EOM)

The ECOWAS Electoral Assistance Unit

The Commonwealth Secretariat ( Democracy and Electoral Affairs Division )

The United States Embassy, Abuja