THE ELECTION TO THE OFFICE OF THE PRESIDENT FRN/GOVERNOR LAGOS STATE/ NASS FOR LAGOS NORTH SENATORIAL DISTRICT HELD ON THE 28TH OF MARCH, 2015

THE PETITION OF DR. GOODLUCK JONATHAN OF OTUEKE IN BAYELSA NORTH LOCAL GOVERNMENT AREA OF BAYELSA STATE, AND THE PEOPLES DEMOCRATIC PARTY, WHOSE NAMES ARE/IS SUBSCRIBED:

1. Your 1st petitioner Dr. Goodluck Jonathan was a candidate at the above election (or claims to have had a right to contest or be returned at the above election). He was validly nominated by his political party, your 2nd petitioner, for the Presidential/Governorship/NASS/SHA election. AND your 2nd petitioner is a registered political party that participated in the above election and sponsored your 1st petitioner.


2. And your petitioners state that the election was held (or was scheduled to hold on) on Saturday the 28th of March, 2015, when the following were scored (depending on your grounds for challenging the election, you may add: despite the fact that there was no election in some parts of the federation/state/constituency):
   
   NAME PARTY VOTES
   i) Goodluck Jonathan PDP 200
   ii) Mohammed Buhari APC 500
   iii) Sule Lamido ANPP 12
   iv) Nasir El-Rufai HOPE 09
   Mohammed Buhari was declared winner of the election and returned elected by the 3rd Respondent (you may add: though there was no election on the said date)



GROUNDS FOR THE PETITION

3. Your petitioners state that the grounds on which they rely for the petition are as follows (NOTE that the ground(s) must be one or more of those specified in section 138(1)(a)-(d) of Electoral Act as amended. You can couch them as follows):
   
   1. That the 1st respondent was not qualified to contest the election in the first place
   2. The return of the 1st Respondent as winner of the election for the office of President of FRN/Governor of Lagos state/Senator representing …/etc held on the 28th of March, 2015 was invalid by reason of a substantial non-compliance with the provisions of the Electoral Act 2010 as amended
   3. That the election was marred by corrupt practices such as forgery, over-voting, under-aged voting and falsification of result.
   4. That the 1st respondent was not duly elected by a majority of the lawful votes cast (as no lawful vote was cast in … polling unit(s), state, LGA, etc)
   5. If applicable, you can add the last ground that though the 1st petitioner was validly nominated by the 2nd petitioner, the 1st petitioner was unlawfully excluded from the election by the 5th Respondent



FACTS IN SUPPORT OF THE GROUNDS FOR THE PETITION

4. Your petitioners state that the facts in support of the grounds for the petition are as follows:
   
   1. Here state all the facts and surrounding circumstances. Just like facts in divorce petition (state everything that happened. Note that you can use sub paragraphs)
   2. ………………………………………………………
   3. ………………………………………………………
   4. ………………………………………………………



PRAYERS

5. WHEREOF your petitioners prays this Court/Tribunal for the following:
   
   1. A DECLARATION that the 1st Respondent, Mohammad Buhari, was not duly elected and returned as winner of the election to the office of ___________ held on the 28th of March, 2015
   2. A DECLARATION that the election to the office of ________________ held on the 28th of March, 2015 is null and void
   3. AN ORDER FOR A BYE ELECTION into the office of ____________ on a date to be fixed by the 5th Respondent.
   
   

   OR OR OR

   4. A DECLARATION that the 1st Respondent, Mohammad Buhari, was not duly elected and returned as winner of the election to the office of ___________ held on the 28th of March, 2015 having failed to secure a majority of the lawful votes cast at the election
   5. A DECLARATION the 1st petitioner is the winner of the election to the office of ___________ held on the 28th of March, 2015 having secured/polled a majority of the lawful votes cast as the said election.


6. ADDRESS FOR SERVICE
   
   >
   1. 1st Petitioner
      DR GOODLUCK JONATHAN
      No 5 Otueke Market Road,
      Bayelsa North,
      Bayelsa
      
      Occupier: Dr. Goodluck Jonathan
   
   
   2. 2nd Petitioner
      PEOPLES DEMOCRATIC PARTY (PDP)
      Plot 34, Wuse Zone 4
      Abuja
      
      Occupier: Peoples Democratic Party (PDP)
   
   
   3. 1st Respondent
      GENERAL MOHAMMED BUHARI (Rtd)
      No 3 Kasuwan Nama Village
      Katsina South
      Katsina State
      
      Occupier: General Mohammed Buhari (Rtd)
   
   
   4. 2nd Respondent
      ALL PROGRESSIVE CONGRESS (APC)
      Wadada House
      Wuse Zone 4
      Abuja
      
      Occupier: All Progressive Congress (APC)
   
   
   5. 3rd Respondent
      Independent National Electoral Commission
      INEC National Headquarters
      Wuse Zone 2,
      Abuja
      
      Occupier: Independent National Electoral Commission (INEC)