ANSWER AND CROSS PETITION

1. The 1st respondent in answer to the petition in these proceedings says: …........
2. The 1st respondent admits paragraphs 1 ,2, 3, 4, 5, 6, and 7 of the petition
3. The respondent/cross petitioner denies paragraphs 8 and 9 of the petition.
4. The petitioner /respondent avers in response to paragraph 8 of the petition that the petitioner has willfully denied him his conjugal rights for no just reason.
5. Whereof the respondent/ cross-petitioner asks the Court to dismiss the petition of the petitioner.
CROSS-PETITION
6. The respondent/ cross- petitioner pleads facts in paragraphs 1- 7 of the Petition.
GROUNDS FOR THE CROSS-PETITION
7. The respondent petition the Court for a decree of nullity of marriage between the respondent and the petitioner on the grounds that:
   
   1. Both the petitioner and the respondent are within the degree of consanguinity and affinity as the petitioner is the respondent’s niece.
   2. The marriage was void ab initio as it did not comply with the requirements of a valid marriage.
CONDONATION, CONNIVANCE AND COLLUSION
8. The respondent/cross-petitioner has not condoned or connived at the ground specified above and is not guilty of collusion in presenting this answer.
9. The respondent/ cross-petitioner seeks the following Orders:
   
   1. A decree for nullity of marriage between the respondent and the petitioner
   2. Annual maintenance of #250,000 from the petitioner

DATED THE 2 DAY OF APRIL 2012

This Answer was settled by AnietieEkong, Legal Practitioner filed on the 2 day of April 2004 by AnietieEkong on behalf of the respondent, whose address for service is at Group eight Chamber Law School Lagos Campus.

ANSWER UNDER PROTEST

The respondent in answer to the petition in this proceeding, objects to thejurisdiction of the above named Court upon the ground that the marriage betweenthe petitioner and the respondent was only a church blessing synonymous to acustomary marriage and not under the Marriage Act.

The respondent therefore asks the Court to strike out the petition as it lackedjurisdiction on the matter.

DATED THE 2 DAY OF APRIL 2012

This Answer was settled by AnietieEkong, Legal Practitioner filed on the 2 day of April 2004 by AnietieEkong on behalf of the respondent, whose address for service is at Group eight Chamber Law School Lagos Campus.

VERIFYING AFFIDAVIT

I, Mr Paul Baba, Nigeria citizen, Female, Christian, Medical Doctor, residing at 12 Asokoro Road Maitama Abuja, make oath and state as follows:

1. That I am the 1st Respondent/ cross-petitioner in this suit.
2. That I verify the facts stated in my cross-petition by virtue of my personal knowledge of same.
3. That the statements set forth in paragraph I to 9 of my answer and cross-petition are true and correct to the best of my knowledge, information and belief.

CERTIFICATE RELATING TO RECONCILIATION

I, AnietieEkong Esq. Certify that I am the solicitor representing the respondent /cross-petitioner and that I have brought to the attention of the respondent /cross-petitioner the provisions of the Matrimonial Causes Act relating to reconciliation of the parties to a marriage and the approved marriage guidance organizations reasonably available to assist in effecting a reconciliation between the petitioner and the respondent/ cross-petitioner and the possibility of a reconciliation either with or without the assistance of such organization.

DATED THE 2 DAY OF APRIL 2012