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THE ARROGANT IMMATURITY OF THE EUROPEAN UNION Failed projection in travel Ugly Tales Of Abuja Ghettos HOME OF RICHES AND POWES A final word to the cabal in Kaduna How Seme Customs enforced vehicle importation ban Football Prediction in Nigeria and Betting As a Source of Employment Returnee Graduates Disturb As Employers Reject Foreign Degrees The World Through The Lens Of Alternative History The Case Of The Three Abba Kyari Donald Trump's Toxic Masculinity How Donald Trump turned Ted Cruz into a laughingstock Joey's Monday Musings: Is Fela Kuti still relevant in this digital age of Nigerian music? Cancellation Of Post Utme, A Blessing To Our Educational System Moms and dads! Porn shall not be our norm Are most Nigerian artists original? BROKEN RIB (AGAINST DIVORCE) How can Nigeria deal with its recession? The Man Who Named His Dog Buhari Nigeria is Ranked No. 1 In Scrabble Understanding Your Shipping Cost SHOPTOMYDOOR INTENDS TO TACKLE DELIVERY CHALLENGES IN AFRICA CORRUPT EFCC BOSS WHO ARRESTED BLOGGER ABUSIDIQU DEMANDS FOR TWO DIRECTORS AS SURETIES TO SET HIM FREE Being Christian shouldn?t make you a bad dresser Gov. Amaechi Tackles Youths Unemployment Should Sports Not Be A Part Of Okonjo Iweala (Entertainment Industry) Economy Diversification Drive Should Sports Not Be A Part Of Okonjo Iweala (Entertainment Industry) Economy Diversification Drive HP Mobile Authentication Helps Protect Customers Against Counterfeits NIGERIA TODAY Ibis Hotel to Extend Equity in Nigeria, Offer Promo to Customers Looting of treasury at the top SUBSIDIES ON PETROL Youthful magnate extends Midas touch to lifestyle mag . OK! 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Signs Agreement to Provide First Class Services Nigerian Authorities Execute Seizure of Fake Printing Supplies for HP Printers celestial church- thy joy of thy lord unto we all How to monitor entire keystrokes using key logger software Governor Rochas: Declare State Of Emergency in State Public Schools Imo State: Dissolution of LGA council and matters arising Imo State: Owelle Rochas Not A Miracle Worker Imo State Government: Save Amala/Ntu Secondary School from Total Rot We welcome you, Nigeria! THE DIVINE MERCY (FREE AUDIO PRAYER) The road to stardom..................No room for mistakes. THE NIGERIA OF MY DREAMS (PART 1) Access important data from formatted hard drive data THE RESILIENCE THAT PAID OFF! Ohakim’s Empowerment Application Form (Per Ward): A Real or False Bait? What will happen to the killers,the muslims in the north? 2011 Imo Gubernatorial Polls: Governor Ohakim Beyond Electorates Redemption Profile of Warisenibo (Hon.) Dakuku Adolphus Peterside April 2011 Polls: Princewill Commends Rivers’s People and Prof. Jega RIVERS GUBER 2011: AMAECHI, SEKIBO OR OMEHIA: WHO IS EASY CHOICE FOR THE RIVERS STATE PEOPLE? Nigeria: Is there any hope for the poorest of the poor? PPA Winds up Door to Door Electoral Campaign Exercise; as Princewill Urges Voters to Convert Overwhelming Support to Physical Votes on Election Dates Hon. Chief Peterside Dakuku and His Triumphant Entry into Andoni Kingdom Hon. Chief Peterside Dakuku and His Triumphant Entry into Andoni Kingdom 2011: THE NATIONAL ASSEMBLY TO BE REINVIGORATED AS GOV AMAECHI UNLEASHES HIS FIRST ELEVEN ON THE HAPLESS OPPOSITION IN RIVERS STATE 2011: THE PRINCIPLE OF “ANYA-NELI”, CHIEF BARR. EZEBUNWO NYESOM WIKE AND THE POLITICAL FUTURE OF RIVERS STATE – AN OVERVIEW OF AN INSIDER Have you lost your important files and folders? $5,000,000. interswitch ATM Card ARE AFRICANS RELIGIOUS PEOPLE OR FETISH INHABITANTS? DO THEY HAVE A UNIFYING RELIGION AND CULTURE? TOWARDS A PEDAGOGICAL RESPONSE! part 4 Opobians in Diaspora Drum Support for Hon. Dakuku Peterside ARE AFRICANS RELIGIOUS PEOPLE OR FETISH INHABITANTS? DO THEY HAVE A UNIFYING RELIGION AND CULTURE? TOWARDS A PEDAGOGICAL RESPONSE! Part 3 Port Harcourt rally stampede is heartbreaking - Princewill ARE AFRICANS RELIGIOUS PEOPLE OR FETISH INHABITANTS? DO THEY HAVE A UNIFYING RELIGION AND CULTURE? TOWARDS A PEDAGOGICAL RESPONSE! part 2 ARE AFRICANS RELIGIOUS PEOPLE OR FETISH INHABITANTS? DO THEY HAVE A UNIFYING RELIGION AND CULTURE? TOWARDS A PEDAGOGICAL RESPONSE! part 1 Hon. Dakuku Peterside: The House of Representative Candidate and His Political Movement Nigeria: The Ban on Commercial Motorcyclists Princewill Pays Homage to his Father, Urges Kalabari Natives to Vote for Amaechi Dr. Dawari George: Truth about the House of Representatives candidate It's in you; oh Citizen. Niger/Delta: Militancy or Criminality a Genuine Cause for Agitation? Niger/Delta: Militancy or Criminality a Genuine Cause for Agitation? Inec Urged To Extend Registration Days 2011 Election: The Odd Favors Goodluck Jonathan Over Nuhu Ribadu Praise For Dr Dalhatu Tafida From A Global Group Goodluck Jonathan Triumphs In Pdp Party Primary Online Marketing APGA, WHICH WAY? Atiku Abubakar’s Desperation and His Politics of Entitlement Igbos and the 2011 Elections Goodluck Jonathan Global Campaign Team disappointed over Choice of Atiku as Consensus Candidate Internet usage by country: Nigeria has more per capita internet users than India And They Lived Happily Everafter.... Poll: Jonathan Could Beat Atiku in 2011 PDP Presidential Primaries Goodluck Jonathan Campaign Team Concentrate on Jonathan's Voter Registration Drive U.S. Interests in Nigeria’s Financial Reform Success Global Diaspora CampaignTeam Lauds Dr Dalhatu Tafida contributions towards Dr Goodluck Jonathan 2011 Dr Goodluck Jonathan’s Use of Social Media Campaign WHAT SHOULD CHRISTIAN DO ABOUT THE PLIGHT OF THE POOL IN OUR SOCIETY AND IN OTHER PART OF THE WORLD ARE HOMOSEXUAL CHRISTIANITY GENUINE: SHOULD WE ACCEPT THEM TO CHURCH? WHAT IS CHRISTIAN VIEW ABOUT ABORTION IS THERE ANY HARM IN SEX BEFORE MARRIAGE? IS IT A DIRECTIVE FROM GOD THAT THE CHURCH SHOULD BE SILENT ON POLITICAL AFFIARS? WHAT IS CHRISTIANITY STAND ON RACIAL PREJUDICEAND SECURITY REVENGE? THINKING THROUGH THE REALITY OF MORAL ISSUES IN OUR GENERATION Pornography Use in a Marriage The Question of Love, Sex in Marriage COMPOSITION OF ADULTERY THE MENACE OF SECRET SOCIETIES IN NIGERIA Nigeria @ 50: What happened to the ‘Giant of Africa’? Happy Birthday Nigeria….. CELESTIAL CHURCH OF CHRIST-IMOLE KRISTI DE LATI BA WA GBE NINU IJO MIMO 2011: WHITHER YOUTH CANDIDATES A well fed slave and a hungry free man: who is better the field were glory does not stay (Poem) Beauty and Persnality What I wish I had known before coming to the USA. Hannibal was black In support of Zoning system of government A MESSAGE OF HOPE A MWA SHOULD WE BELIEVE IN GOD ? Undelete data from faulty data storage media LIFE AFTER DIVORCE Kpako Husband CONFIRMED!!! HOW I MADE $250 IN 24HOURS WITH MY LIBERTY RESERVE ACCOUNT IN DEFENCE OKADA MEN PROSTITUTION A SOCIAL MENACE ONE MILLION YOUTH MARCH AT KEBBI FOR WHAT? Why Nigeria Crashed Out of The World Cup failed marriages Open letter to Alhaji Sani Yerima Nurturing Effective and Elective Democracy in Nigeria Death of the zoning system: A muted grief The Niger Delta Question IBB AT YOUR SERVICE EDMARK INTERNATIONAL HAS CHANGED NIGERIANS FINANCIALLY AN ATRIBUTE TO OUR DEAR PERSIDENT tribute to our dear president How ThisDay Newspapers 'Scandalized' President Obama's Nigerian Nominee 2011: What if it is Babangida again? THY GOOD SHERPERD- OLUSHOAGUTAN RERE where to keep your problem This Graveyard called Nigeria The Paedophiles in our midst State of the Nation and a Credible 2011 Elections: Matters Arising Yar’Adua-Jonathan Political Muddle: What Lies Ahead? Dear Bishop Oyedepo Gospel of Wickedness – The Hypocrisy and Falsehood of Helen Ukpabio – Part 2. Gospel of Wickedness – The Hypocrisy and Falsehood of Helen Ukpabio – Part 1. Nigeria Mass Media - The Fourth Estate of Graft LIFE AND TESTIMONY Emenogu, world number four, eyes WBC crown A SEALED PRAYER Life after death Responding to Mr Dodo's letter The Stampede for N4million naira on namywedding,com Illogicality and Absurdities: Open letter to Turai Yar’adua EARTHQUAKE REVIEF MISSION Emmanuel TV Haiti Earthquake Relief Team RELAX… AND ENJOY YOUR WINE. A VITAL TOOLS TO THE WORLD BEHOLD! TB JOSHUA’S NEW MYSTERY LADY The dangers of heterodoxy – Open letter to Evangelist Helen Ukpabio T.B JOSHUA IS NOT BUILDING IN GHANA NIGERIA LEADERSHIP CRISES: THE PAUL DIKE OPTION TB JOSHUA IS GREECE'S BIGGEST THREAT IN SA WORLD CUP – GREEK NATIONAL NEWSPAPER A later to my brothers and sisters! HAITI and NIGERIA: Case studies in failure of Human Management of natural resources. The End of Plenty: Nigeria’s “Malthusian Curse” A Letter to the America President from a Nigerian Why I Will Not Support Prof. Chukwuma Soludo Barack Obama: Man of the Year 2009 Labyrinth of Leadership: Nigeria’s Peculiar Mess (penkelemesi) studying abroad is not a child`s play Nigeria, Niger Delta Violence and the Biafra Connection: A Political Discourse By Chris Onyema The Parody of Nigerian Education and the Alternative Search for Foreign Certificate: Whither the Hope of a Better Future? (Part I) GREAT MEN AND HISTOTRY 2011: Ibrahim Shekarau as President What we must tell the President Nigeria: when is the relieve coming? (2) THE AFRICA CHALLENGE...A Message to the President addressed to the Nigerian Youths at the UNITED NATIONS on Aug 7th 2009 Arabic Inscription or Hausa Verbiage: Between Manipulative Interpretations and Subjective Impulse The Many Faces of Helen Ukpabio Nigeria: When is the relieve coming? The Intrigues of Naming: A Dissectional Response to the ‘Boko Haram’ Butchery The Intrigues of Naming: A Dissectional Response to the ‘Boko Haram’ Butchery Curtailing the excesses of Evangelist Helen Ukpabio Fraud Alert! INTERSWITCH SCAM EMAILS ON THE LOOSE, BEWARE! Who Is TB Joshua's Mentor? THE TRIBAL EMANCIPATION OF NDI IGBO FROM NORTHERN DOMINATION; part 3 Tony Patrick a.k.a. TP-Rhymes Selfless Service Niger Delta Crisis: Nigeria Loses N6, 264 Trillion! MOTHER'S DAY: THE MYTH BEHIND THIS DAY! Withdrawal of Andy Uba's Supreme Court Case Anambra State Political Issues: This Is My Stand (Part II) KA SISE LATI LE RE IJOBA ORUN --- OMO IJO MIMO---CELESTIAL CHURCH OF CHRIST Anambra State Political Issues: This Is My Stand Dividends Of Unemployment Mental Colonialism RE: REBRANDING NIGERIA IMAGE PROJECT; WE ALL MUST SUPPORT AND CONTRIBUTE TOWARDS A TRIBAL EMANCIPATION OF NDI IGBO FROM NORTHERN DOMINATION-Part 2 Anambra State and The One-Term Governor Syndrome (Part II) i miss her sorry baby Make Quick Money with less Stress VISION 2020 AND NIGERIA'S ECONOMY, THE WAY FORWARD Satellite Internet Access Lamit Company launches a new network solution for improving the internet connection A-Z of Cyber Fraudsters & Preventive Tips We dont have ambbasador in China but a foolish goat GOODNESS IN MAN. WORDS WRITTEN IN BLOOD THE LOVE BETWEEN OBJ AND ATIKU Some Articles deserve not to be published. Obama: The President With Many Firsts Our Ambassador in china is very stupid What can be done about being Nigerian? TOWARDS A TRIBAL ENMACIPATION OF NDI IGBO FROM NORTHERN DOMINATION- Part 1 Burden Of Proof In Election Petitions We Know The Way Their Racism, Our Tribalism LEGITIMATE AND ILLEGITIMATE WORRY YOU ARE TIMELESS TO ME. Why I Want McCain To Win How Race Colors American Presidential Election Nigeria, afer the Beijing games. Do we ever have a Government? Help Nigerians in China out b4 too late. BIG TROUBLE FOR NIGERIANSIN CHINA Nigeria@48 Wake-up Nigeria 1ST NIGERIAN GERMAN SECURITY CONFERENCE 2008 ABUJA BETWEEN PHYSICIANS AND THEIR FATALLY WOUNDED PATIENTS THE SOCIAL AND PHILOSOPHICAL FUNCTION OF LANGUAGE FOREIGN NATIONALS USING NIGERIAN PASSPORTS MODERN MAN AND SCIENTIFIC SOPHISTICATION IN THE THIRD MILLENNIUM "ONWA ASATO' OR "ILO MUO" FESTIVAL IN NRI MARITAL TRAGEDIES AMONG NIGERIANS IN DIASPORA (PART I) war aganist women HOW OBAMA CAN WIN IN NOVEMBER TAX EVASSION IN LAGOS? 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FATHERHOOD AND FAMILY FROM AN ASIAN PERSPECTIVE Western Architecture versus Tropical Architecture: Why you shouldn't import your house plan from Europe/America FATHERHOOD FROM AFRICAN PERSPECTIVE MBADINUJU'S TRAVAILS SUDANESE PLANE CRASH: A CHALLENGE TO AFRICAN AVIATION INDUSTRIES Intrigues: The Nigeria Supreme Court and the Rotimi Amaechi's Judgment IGU ARO NDI IGBO Invitation to attend Harris Phillips' highly subsidized seminars for June and July 2008 ATTEND FREE SEMINARS TILL THE END OF JUNE!!! Anambra State: On the Road to Greatness ANAMBRA STATE: ON THE ROAD TO GREATNESS ABSENT FATHERS: Its Impact on the Family PHCN IS KILLING PEOPLE IN BOLORUNPELU TOWN IKOTUN LAGOS NIGERIA Letter to my friend oversea Major Bid To Internationalize Nigerian Contemporary Poetry. YES, NIGERIAN WRITINGS TODAY ARE RUDDERLESS Professor Tony Afejuku of the Department of English, University of Benin, a poet, critic and an activist, once said in an interview with a Nigerian newspaper (Vanguard), that Nigerian writings today are rudderless. NIGERIAN PRESIDENT'S CHIEF PUBLICIST DEVISES CREDIBILITY RUBBISHING SCHEME FATHERHOOD: HISTORICAL, SOCIOLOGICAL AND ANTHROPOLOGICAL PERSPECTIVE The Obasanjo Years of Locust (1999 To 2007) is our Collective Guilt UPSURGE ON ONLINE PUBLISHING IN NIGERIA PROFILE AND POETRY OF COMRADE CHIDI ANTHONY OPARA Niger Delta Conference!!!! 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BUSINESS OPPORTUNITY(Do You Have The Courge To succeed) TRIBUTE TO CYPRIAN EKWENSI DWELLING IN THE SECRET PLACE OF THE LORD ABOUT EJIKE OGBONNAYA WE NEED THIS KIND OF PERSON IN THIS WORLD BREAKING NEWS! Kebbi Gubernatorial Election Nullified Says FRCN, Kaduna THERE IS A BATTLE CALLED LIFE "Succeeding successfully" Equal opportunity Bald Men Need Natural Hair Care Products Too! How to save your hair and your valuable time removing Fusion, Braids, Weaves, Hair Extensions and Dreadlocks! Laugh your ribs out. Call this comedian STOP AUTHORITY STEALING GROUP PLANS EPIC FILM ON AWO, TWENTY YEARS AFTER HIS DEATH ''PILLAR''OF CORRUPTION! 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Knowledge Management PRESIDENT YAR'ADUA NEEDS TO DEAL-WITH INTRIQUES AND POWER-PLAY WE NEED A CHANGE IN OUR SOCIETY TO STOP THE TERIFYING PAINS OF OUR FUTURE MOTHERS IN NIGERIA AND ALL OVER AFRICA (''CIRCUMCISION'') INFORMATION TECHNOLOGY GROWTH IN ETHIOPIA 7 ways to choose an effective career IS ABORTION REALLY MURDER? EFCC ACTIONS China/Africa relation, a new hide and seek. YAR'ADUA NEEDS TO BE CAREFUL OF GENERAL OBASANJO!! AMEN FOUNDATION CATARACT SURGERIES FOR LAGOS STATE Housa man and police officer The godfathers red eyes 30 days in power The go-slow president The cop and the chop Something to ponder Never again I will miss Obasanjo THE ROOT OF REALITY: IN SUPPORT OF MILITANCY Ka sowo po, ka sowo po, Pelu ife mimo King Ogbidi Okojie of Uromi OBASANJO IS STILL RULING NIGERIA NIGERIA WILL BE GREAT AGAIN THE ANATOMY'S SECRET PRINCIPLES OF SUCCESS Nigerias Post 2007 Elections: A Time for Healing Process and National Reconciliation Majors Offered at Rochville University Rochville University Nigeria as Nigerians are the happiest people in the world 19,May 2007.Fear of safety Port Harcourt Nigeria:Bari-arakpalap Esan Youth Rebirth Movement Appeal for the Release of Hostages! Ghana Beckons! Nigeria Rebirth NIGERIAN ELECTORAL PROCESS: DIM LIGHT AT THE END OF THE TUNNEL Nigeria and same sex bills Nigeria and Choices 2007 Between Babalakins Airport Terminal and Dukes Tinapa Nigerias Drug War: Dora Akunyili A Champion at home and abroad They can do much better the Exodus of Corruption Purposeful Living /What on ewarh are you here for ?!! Discussions on Nigeria 1 Success Series 1 yoruba movies IGBALA DE LONI FUN GBOGBO ENYIN IJO -MIMO The Rivers of Our Dream: Commentary Combating Corruption Corruptly: The Nigerian Experience OMO IJO MIMO (CELESTIAL CHURCH OF CHRIST ) RONUPIWADA What a shameless people?What a shameless country? Africas Political &Economic liberation BEYOND THEIR ANTICS Group swipes at Opponents of Omehia, says he is the right candidat Omehia's Candidature - A Blessing to PDP... CGG DRAMATIC IRONIES home away from home A TERRIBLE BEAUTY THE NIGER_DELTA: A CRADLE OF VIOLENCE MEND vs. POLICE ONSLAUGHT In Defense Of The Outcast One Dishonesty in Census: what's The Upper Limit? IN DEFENCE OF SANGUINARY GODS The relevance of emotional intelligence in business Why the nice men hurts everybody Malleable pornography is a poison to Youth morals Bringing back life into the family Preventing violent behaviour in children DEVELOPING AN APPEALING LOOK Superior should not count people but count on people CELESTIAL MEMBERS ARE U READY TO MEET JESUS ----IF SO--THIS IS WHAT IS REQUIRED FOR U CELESTIAL MEMBERS TO DO-LISTEN TO HIM-GOD ALMIGHTY THE BRUTAL KILLING,TORTURE AND ARREST OF BIAFRAINS WORD OF THE LORD FOR CELESTIAL MEMBER TO LEARN FROM ABOUT THE LORD MARGINALISATIO OF IGBO RACE AND THE STRUGGLE FOR THE SOVEREIGN STATE OF BIAFRA. What If You And Your Friend Love The Same Person? Tell Your Partner Why You Love Them. Love - Can You Change Your Partner? TAIWO AKINKUNMI- AN HERO WITHOUT HONOR Happy New Year!- Let It Go For 2007... Desparity against the nigeria woman Desparity in judgement Desparity against todays nigeria wo osa mwen na ramwen LIFE SAVING INFORMATION FULFILL YOUR PROMISE LAGOS NA WA!!! New Thing in Nkanu land HEALTH CARE FOR THE POPULACE Tears Of My People oba of lagos Lest We Forget: Lest we forget: Challenging the Heart of Africa Project CELESTIAL CHURCH OF CHRIST-- 0R0 OLUWA KO SI YIN Gen. Buhari is the best choice for Nigeria in 2008 ANALYTICAL DISCOURSE ON THE NIGERIAN WOMAN THE EAGLES GATHER FOR IBB NIGERIA - THE PEOPLE AND THE LEADERS IJO MIMO-- THE WAY FORWARD-CHRIST IS THE HEAD OF THE CHURCH GOVERNOR DONALD DUKE: SAINT OR SINNER? Glory Emeh and RSG Aviation Fraud WHO CORRUPTED THE PUBLIC SERVICE? FASCISM: THE EKITI EXAMPLE THE FESTAC WE ONCE KNEW Nigeria Triple 'C' Syndrome: Diagnositic Appraisal of our Body Polity The Value of Friend, they worth more than you realize? Role Models: Who and Why are you imitating? Overcoming Shyness All about Bliss and why its not a good Idea Deregulation of morality No Visible Alternative Leadership for 2007 - Nigerians in the Diaspora Declares Politics in High Places: Aberant of the Mainstream Opportunity Cost of $125 Million PTDF Fund: Forgone Conclusion Sanctity of Democratic Choice retrenchment NIGERIA LEFT nigerian students' movement who corrupted the public service Nigerian Independence Day Celebration in The Hague. ABC Health Guide for Nigerians Travelling to the U.K DININE TUNR ARUND Ghana Beckons!! thank you ohafia-agba A day with Adewale Ayuba Governor Idris has donewell but people still lay complains War Against Terror - UK Prime Minister, Tony Blair Speaks on Terrorism in Niger Delta NIGERIANS NEED A KEGITE LEADER AS THE NEXT NIGERIA PRESIDENT KEGITES MEMBERS DECLARED SHAME Nigerian Universities In Shambles INFERNO IN ASO VILLA FRIEND' S FAMILY DECONGESTING THE MIND FEAR OF SUCCESS RUMOURS- THE OFFICE VIRUS PAYING ATTENTION TO THE OTHER SIDE WHAT IS THE PROBLEM WITH THESE PUBLIC OFFICERS Introducing LBE HelpDesk the serenity of the niger delta; a review commissioner's sack; why hon. Ambaowei must stay endless tears of niger delta : poems post-UME screening: matters arising Bayelsa as an educational brand Quality E-Books and Softwares with Master Resale Rights the nigerian girl making waves in the uk for her continent! Quality E-Books and Softwares with Master Resale Rights The Future of Immigration in the West ACHIEVERS ARE DREAMERS celestial church of christ pillarand the ground of truth--1tim,3-14-15 Adeyinka Makinde, author of Dick Tiger, interviewed on Global Talk Radio A superlative performance- our heroine on the world stage A day with Olusesan Ekisola pioneer GM, Raypower THE KALEIDOSCOPE OF PRINCE TONYE PRINCEWILL Ma sise lo, ma se wa isimi COOPERATING WITH COLONIAL COOPERATION. NA WA FOR YABA MARKET. Difference between Online Education VS. Traditional Education Divergent Perspectives on the Niger Delta Question Black Prime Minister Not In My Lifetime Declares UK First Black Female Parliamentarian, Diane Abbott Private Soldier Lectures Nigerian Commander-in-Chief UK Prime Minister speaks out on terrorism in Africa Addressing Nigeria's Economic Problems and the Islamist Terrorist Threat Obasanjo pls we need your attention. Lets Make Nigeria Great THE BAD EGGS OF THE NIGERIAN FOOTBALL ASSOCIATION RE: Obasanjo: Nigerians ll Decide My Successor we are one in christ-celestial member--LOVE- IS THE WORD AND WORSHIP IS THE WAY;- THE CYBER INVESTIGATOR PART 1 CHIEF AUDU OGBE IN RETROSPECT Interview Transcript of appearance on 'Garvey's Children' Boxing: Rousing the Nigerian Giant THE APATHY OF FREE MEN AND THE CONSPIRACY OF SILENCE THE NIGER-DELTA: A CRADLE OF VIOLENCE Interview Transcript of appearance on 'Just About Books' Remembering Rex Lawson THIRD TERM: THE COLOSSAL FAILURE OF A BAD IDEA; AN INVESTIGATION NEEDS TO BE CONDUCTED TO SEE WHO GOT WHAT AND WHY. THE NEXT GOVERNMENT HAS A FIDUCIARY DUTY TO CONDUCT AND INVESTIGATION INTO EFFORTS TO ABROGATE OUR CONSTITUTION; LET THE CHIP FALL WHEREEVER discuss the development of fishey in nigeral Tetuila thrills America CALL FOR GENDER EQUALITIES!!! GOD BLESS NNAMANI Beyond Third Term: The untold story... EMOTIONS AND LOVE AFFAIRS cry of help THE NEW AFRICAN ORDER - The times, they are a-changing We must Stop the Government The Iran Question and Nigeria DISCUSS IN DETAILS THE HISTORY OF AGRICULTURE IN NIGERIA FROM THE COLONIAL ERA TO THE PRESENT DAY, POINTING OUT CLEARLY ALL AGRICULTURAL PROGRAMMES. The worrisome Lagos-Ibadan traffic Hope for Niger Delta Conference on CURBING YOUTH RESTIVENESS IN THE NIGER DELTA Held on the 29th April 2006 in Rotterdam, The Netherlands. I want your comments The Ambush of Ambition SAY NO TO OBJ THIRD TERM BID internet secrets to money making LET UNITE AND WORSHIP THE TRUE GOD TOGETHER MEMBERS OF (C.C.C.)WORLDWIDE THE NIGERIA POLICE: VICTORS OR VILLAINS THIRD TERM SYNDROME THE IMMINENT DEATH OF A NATION The Messiah illusions of 'scramble democrats' Beyond elections: Niger Delta in perspective Ngige, welcome home from great conquest AFTER THE BATTLE WHAT NEXT Wake up Nigeria The Delta Murder At Dawn Jelili Omotola (1941-2006) In Amsterdam, Nigerian deportee help up our flight for one hour THE WORLD'S NUMBER 1 BLACK BOOK! NIGER DELTA/SLAVE COAST = GARDEN OF EDEN= BLACK PROGRESS? African Union Defined THE DOUBLE VICTIMS OF DEPRAVITY Constitutional Review Obasanjo sliding into a pariah? A Dream of Nigeria: Critical Published Essays 2002 To 2005 Ali Farka Toure (1939-2006) AFRICA - AMERICA DOUBLE STANDARD RELATIONSHIP The Witch of Web-design, the Young Humanitarian and the Scientific-poetic Soul Conference Annoucement!!!!!! Third Term Dilemma A heart for HIV orphans Niger Delta: The Need for Immediate and Urgent International Intervention Ritual Taste In Nigeria. THE NIGER DELTA: A TERRIBLE BEAUTY A TIME TO KILL CRAZY MORALITIES THIRD TERM AGENDA??? THIRD -TERM AGENDA: ANOTHER MANIFESTATION OF THE ELITES' RECURRING CONSPIRACY Do Sumthing! International THE SCANDALOUS ADVOCATES FOR THIRED TERM THE SCANDALOUS ADVOCATES FOR TERM LATELY I HAVE BEEN STARING AT THE MIRROR MOURINHO SHOULD LEARN HOW TO ACCEPT DEFEAT Speech by M. Dominique de Villepin, Minister of Foreign Affairs, to the United Nations Security Council, New York 19.03.2003 NIGERIA AND RELIGIOUS INTOLERANCE. Where is our toil? (a poem) Sorrowful tale (A poem) The beauty and lure of cultism A bad man with good intentions Waltz into darkness Diatribe ans counter diatribe Nigeria: The holocaust agenda The principle of 'chop chop' politics Project Nostradamus The imminent death of a nation The Contenders: Illusions of genuine betrayal Adieu Nigeria Nigeria: Evaluation of the year 2005 Why do we hate him? The Politics of Higher Education UNIONIZING THE NIGERIA POLICE FORCE: THAT THE QUESTION BE NOW PUT So Tafa Balogun is a free man? Words of Wisdom CONSTITUTIONAL AMENDMENT, NOT SOVEREIGN NATIONAL CONFERENCE, IS PATHWAY TO A REFORMED POLITY What has happened to America's Jesus? Insights of Accreditation Six Things Africans Living Abroad Must Note! BEKO IS DEAD: Ace activist succumbs to death after recent battle with ill-health: Soyinka Sad. 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Written by: Detroit, Michigan

Recently, Federal Courts in the United States have begun adjudicating civil liability for human rights violations committed in another country under the two - century old Act, the Alien Tort Claims Act and the recently enacted Torture Victims Protection Act. Application of International Human Rights Law in U.S legal System

The Alien Tort Claims Act (ACTA) was adopted in 1789 as part of the original Judiciary Act. In its original form, it made no assertion about legal rights; it simply asserted that '[t]he district courts shall have original jurisdiction of any civil action by an alien for a tort only, committed in violation of the law of nations or a treaty of the United States" For almost two centuries, the statute lay relatively dormant, supporting jurisdiction in only a handful of cases. As the result of increasing international concern with human rights issues, however, litigants have recently begun to seek redress more frequently under the ATCA. These suits produced several important decisions interpreting the meaning and scope of the 1789 Act.

For example, in Filartiga v. Pena-Irala, the U. S Court of Appeals held that deliberate torture perpetrated under the color of official authority violates universally accepted norms of international human rights law, and that such a violation of international law constitutes a violation of the domestic law of the United States, giving rise to a claim under the ATCA whenever the perpetrator is properly served within the borders of the United States

Another significant Act, The Torture Victims Protection Act was passed by the Congress in1991. In passing the Torture Victim Prevention Act [TVPA], Congress expressly ratified the U.S Court of Appeal's holding in Flatiga which was decided under the Alien Tort Act that the United States courts have jurisdiction over suits by aliens alleging torture under color of law of a foreign nation, and carried it significantly further. While the Alien Tort Claims Act expressed itself in terms of a grant of jurisdiction to the district courts, the Torture Victims Protection Act :

makes clear that it creates liability under U.S. law where under "color of law, of any foreign nation" an individual is subject to torture or "extra judicial killing," and

extends its remedy not only to aliens but to any "individual," thus covering citizens of the United States as well. The TVPA thus recognizes explicitly what was perhaps implicit in the Act of 1789 - that the law of nations is incorporated into the law of the United States and that a violation of the international law of human rights (at least with regard to torture) is ipso facto a violation of U.S. domestic law
The Torture Victim Protection Act provides that claimants under "this Act" must exhaust available remedies in the place in which the conduct giving rise to the claim occurred

The number of cases that were decided under the Alien Tort Act, even after 1992 when the Torture Victim Protection Act was enacted, indicates the fact that the Torture Victim Protection Act does not supersede or override the provisions of Alien Tort Act. As stated above, the 2nd Circuit in Kadic v Karadzi, supra recently expanded jurisdiction under the Alien Tort Act. Karadzi was decided in 1996, four years after the enactment of the Torture Victim Protection Act

At the very best, what the Torture Victim Protection Act does is to present another alternative law for claimants. In essence, a claimant may elect to bring his case under the Alien Tort Act or choose to bring his action under the Torture Victim Protection Act.

The complaints of torture, degrading and inhumane treatment, wrongful death and violation of rights to life and liberty constitute crimes against humanity under international law

Crimes against humanity recognized by international law also include murder, arbitrary detention and persecution on political or other grounds. Each of these crimes against humanity has been recognized as crimes under international law and codified in international conventions or other international instruments, either expressly or impliedly. Some of these instruments include Article G(c) of the charter of the International Military Tribunal at Nuremberg (1945), Article 18 of the U.N. Draft Code of Crimes Against the Peace and Security of Mankind (1996), and Article 7 of the statute of the International Criminal Court (1998).

In addition to international conventions and statutes defining the acts of murder, deportation or forcible transfer of population, imprisonment or other sever deprivation of physical liberty in violation of fundamental rules of international law, torture, persecution, and other inhumane acts as crimes against humanity, these acts are also recognized as crimes against humanity under international customary law. This was articulated by Article VI(c) of the International Law Commission's Principles of International Law and recognized in the Charter of the Nuremberg Tribunal.

ii.) Universal jurisdiction over crimes against humanity

Crimes against humanity are subject to universal jurisdiction. This principle has been recognized under international law since the establishment of the International Military Tribunal of Nuremberg, which had jurisdiction over crimes against humanity regardless of where they were committed. The Jus Cogens nature of crimes against humanity.

Crimes against humanity and the norms, which regulate them form part of jus cogens (fundamental norms). As such, they are preemptory norms of general international law that, as recognized in Article 53 of the Vienna Convention of the Law of Treaties (1969), cannot be modified or revoked by treaty or national law. The article provides that "a preemptory norm of general international law is a norm accepted and recognized by the international community of states as a whole as a norm from which no derogation is permitted and which can be modified only by a subsequent norm of general international law having the same character."

Indeed, as the International Court of Justice recognized in Barcelona Traction, Light and Power Company Ltd, Judgment (ICT. 1972 Report, p.32) the prohibition in international law of crimes against humanity, is an obligation erga omnes which all states have a legal interest in ensuring its implementation

The above legal interest permits any state to exercise universal jurisdiction over persons suspected of committing these crimes against humanity . As a result, a number of states have enacted legislation permitting their courts to exercise universal civil or criminal jurisdiction over crimes committed against humanity. An example is the Alien Tort Claims Act 28 U.S.C. Section 1350 of the United States and the Torture Victims Protection Act.

However, the failure to incorporate international law as crimes against humanity within domestic criminal or civil law of a state does not excuse that state from international responsibility to bring to justice those responsible for inflicting such crimes. According to the U.N. Committee against torture, there exists "a general rule of international law which should oblige all states to take effective measures to prevent torture and to punish acts of torture"

iii) The Federal District Court in the U.S has subject matter jurisdiction to adjudicate complaints of torture by foreign complainants by virtue of the Alien Tort Claims Act [ATCA]

The principal exception to the general rule, that U.S. courts do not have jurisdiction over suits whose parties and subject matter are wholly foreign, is the Alien Tort Claims Statute, 28 U.S.C.A. 1350. The statute provides:

"The District Courts shall have original jurisdiction of any civil action by an alien for a tort only, committed in violation of the law of nations or a treaty of the United States."

By virtue of the foregoing provision, the statute provides, therefore, a private right of action concerning violation of (i) jus cogens (internationally recognized norms) or (ii) of treaty of the United States

The Alien Tort Act was exhaustively discussed as a viable jurisdictional vehicle in Filatiga v Pena-Irala (630 F.2d 876, 2d Cir. 1980). In that case, Dr. Joel Filatiga, a Paraguayan citizen and dissident, obtained a $10 million judgment against Paraguayan police official Pena-Irala who was served with the process in Brooklyn, N.Y. . Filartiga testified that Pena-Irala killed Filartiga's son by torture. The court found subject matter and personal jurisdiction under the Alien Tort Act for violations of the law of nations. The court ruled that the right to be free from torture is "now among" the list of fundamental rights conferred by the international law for purposes of the Alien Tort Statute. The court held inter alia:

"Appellee submits that even if the tort alleged is a violation of modern international law, federal jurisdiction may not be exercised consistent with the Articles III of the constitution. The claim is without merit. Common law courts of general jurisdiction regularly adjudicate transitory tort claims between individuals over whom they exercise personal jurisdiction, wherever the tort occurred. Moreover, as part of an articulated scheme of federal control over external affairs, Congress provided, in the First Judiciary Act, 9 (b), 1, Stat. 73, 77 (1989), for federal jurisdiction over suits by aliens where principles of international law are in issue. The constitutional basis for Alien Tort Statute is the law of nations, which has always been part of the federal common law. It is not extra ordinary for a court to adjudicate a tort claim arising outside its territorial jurisdiction.... we believe it is sufficient here to construe the Alien Tort Statute, not as granting new rights to alien, but simply as opening the federal courts for adjudication fo the rights already recognized by international law."

According to the court in Filartiga, the parity of suits successfully maintained under the Alien Tort Statute is readily attributable to the statute's requirement of alleging a "violation of the laws of nations" at the jurisdictional threshold. The court had little difficulty concluding that 1350 incorporated the "law of nations" as it evolved over time and not simply as it existed when the Alien Tort Statute was enacted in 1789. Most other authorities have agreed. See Tel-oren v Libyan Arab Republic, 726 F.2d 774, 777, 820 (D.C. Cir. 1984); Amerada Hess Shipping Co. v Agentine Republic, 830 F. 2d 421 (2d Cir. 1987), rev'd on other grounds

On the cause of action requirement, the Filartiga Court rejected the Defendant's argument that, even customary international law provides certain human rights protection for individuals, it does not grant them private cause of action to redress violation of those rights. The Filartiga court in rejecting that argument critically implied that the existence of a private right of action was a choice of law issue, not a question of federal jurisdiction

Jurisdiction under the Alien Tort Act was recently expanded by the second circuit in Kadic v Karadzic, 70 F. 3d 232 (2 Cir. 1995), reh'g denied, 74 F.3d 377, cert. Denied. 116 S. Ct. 2524(1996). Croat and Meshon citizens of Bosnia-Herzegovina against defendant, Radovan Karadzic, brought suit in Karadzic. Karadzic was personally served with process while visiting in New York as an invitee of the United Nations. The second circuit ruled that the Alien Tort Act conferred jurisdiction for violation of law of nations committed by those acting under color of law to commit genocide, war crimes and crimes against humanity. (Id at 241-44). The court further observed that the content of the law of nations must be judged, "not as it was in 1789, but as it has evolved and exists among the nation of the world today." (Id at 238, quoting Filartiga, 630 F.2d at 881)

Deliberate torture perpetuated under color of official authority violates universally accepted norms of international law of human rights, regardless of the nationalities of parties, and thus, whenever an alleged torturer is found and served with court process by an alien within the borders of the United States, U.S.C.A. 1350 provides federal jurisdiction.

Official torture constitutes cognizable violation of law of nations for purposes of the Alien Tort Act. In the same vein, allegations of "official" conduct sufficient to establish jurisdiction under the Alien Tort Claims Statute do not automatically implicate act of state doctrine so as to bar adjudication of claims.

iv) No Sovereign Immunity for crimes committed against humanity, which were clearly not within the scope of sovereign authority

Some critics of both Acts have argued that the act of state doctrine is a bar to personal jurisdiction of U.S courts and that Act of State Doctrine and the Foreign Sovereign Immunities Act preclude courts in the U.S from enquiring into the validity of the public acts of a recognized sovereign committed within its own territory. Under controlling precedent however, the Act of State Doctrine does not immunize perpetrators from liability for human rights violations committed under the color of law particularly when the perpetrator has vacated the sovereign position

To constitute an act of state, the conduct must have been committed by an official of a sitting government and recognized by the United States at the time of the lawsuit. If another government, in other words, has replaced the perpetrator or the government responsible for the act, the Act of State Doctrine has no applicability. Kirkpatrick, 493 U.S. at 409, Sabbatino, 376 U.S. at 428, Republic of Philliphines v Marcos, 862 F.2d. 1355, 1360 (9th Cir. 1988)(en banc)(dismissal unwarranted unless adjudication will result in "hostile confrontation" with foreign state). Thus in Jimenez v Aristeguieta, 311 F.2d 547, 552 (5th Cir. 1962), cert. denied, 373 U.S. 914 (1963), a former Venezuelan head of state was held not protected by the Act of State Doctrine against claims of murder, torture and other crimes. This was because such crimes could never be part of the sovereign functions of a head of state.

Again, In Banco Nacional de Cuba v. Sabbatino, 37 U.S 398, 428 (1964) the U.S Supreme Court laid a precedent on the act of state doctrine which suggested that U.S courts may review acts of foreign sovereign when there is a great degree of codification or consensus concerning a particular area of international law. It is a fact that there is high degree of consensus regarding the international law prohibiting torture and other cruel, inhuman or degrading treatment of individuals by government.

In Republic of Phillippines v Marcos, illegal acts committed by former Philippine president Marcos were held not immune from suit because "courts have no difficulty in distinguishing the legal acts of a deposed ruler from his acts for personal profits that lack basis in law." 862 F.2d 1361

It is also trite that those responsible for torture, murder and other crimes against humanity cannot invoke immunity or special privileges as means of avoiding criminal or civil responsibility. The fundamental rule of international law that there is no immunity under international law for heads of state and public officials for crimes against humanity has long been established. It is simply a specific example of the general rule of international law recognized in the Treaty of Versailles of 28 June of 1919 that immunities of heads of state under international law have limits, particu-larly when crimes under international law are involved. Article 7 of the Nuremberg Charter expressly provided:

"The official position of defendants, whether as head of state or responsible officials in government department, shall not be considered as freeing them from responsibility or mitigating punishment."

In its judgment, the International Military Tribunal at Nuremberg declared: "crimes against international law are committed by men, not by abstract entities, and only by punishing individuals who commit such crimes can provisions of international law be enforced" (see Telford Taylor, The Anatomy of the Nuremberg Trials (New York: Alfred A. Knopf 1992). The Tribunal further held that "the authors of these acts cannot shelter themselves behind their official position in order to be freed from punishment in appropriate proceedings"(Ibid; p.41-42)

The principle of individual civil or criminal responsibility of heads of state for crimes against humanity is part of international law, hence, the U.S legal system

The principles articulated in the Nuremberg Charter and judgments have long been recognized as part of international law. The U.N. General Assembly endorsed "the principles of international law recognized by the charter of the Nuremberg Tribunal and the judgment of the Tribunal" in G.A. Res. 95(1) of 11 December 1946

The U.N. International Law Commission has explained why the rule that heads of states and public officials are not immune when they commit crimes under international law is an essential part of the international legal system:

The Commission states that:

"Crimes against the peace and security of mankind often require the involvement of persons in position of governmental authority who are capable of formulating plans or policies involving acts of exceptional gravity and magnitude. These crimes require the power to use or to authorize the use of the essential means of destruction and to mobilize the personnel required for carrying the use of these crimes. A govern-ment official who plans, instigates, authorizes or orders such crimes not only provides the means and the personnel required for carrying out the crime, but also abuses the authority and power entrusted to him. He may therefore, be considered to be even more culpable than the subordinate who actually commits the criminal act. It would be paradoxical to allow the individuals who are, in some respects, the most responsible for the crimes covered by the [Draft Code of Crimes Against Peace and Security of Mankind] to invoke the sovereignty of the state and to hide behind immunity that is conferred on them by virtue of their positions particularly since these heinous crimes shock the conscience of mankind, violate some of the most fundamental rules of international law and threaten international peace and security." (1996 Report of the International Law Commission at p. 39)

It therefore, necessarily follows that the international law rule that heads of state and government officials are not immune from criminal or civil prosecution applies to international courts and U.S courts as demonstrated by the Alien Tort Claims Act and the Torture Victims Protection Act. By so doing, the Alien Tort Act vests jurisdiction for crimes against humanity on federal district courts and divests heads of state and government of any immunity protection afforded by Foreign Sovereign Immunities Act. See In re Estate of Ferdinand Marcos, 25 F.3d 1467(9th Cir. 1994) (holding that Foreign Sovereign Immunities Act did not prevent jurisdiction over the estate of the former president of the Philippines for alleged acts of torture and wrongful death since those acts were not official acts committed within the scope of his authority. Other national courts had upheld similar position. See for example, District Court of Jerusalem, Attorney General of the Government of Israel v Eichmann, 36 Int'l. L. Rep. [1961], 5, Para. 30; Trial of the nine Military Commanders who had ruled Argentina between 1976 and 1982, Argentinean Federal Court of Appeals, Judgment on 9 December 1985 and Argentinean Supreme Court of Justice, Judgment 30, December 1986: Trial of former president General Luis Garcia Meza and his collaborators on multiple violations, Bolivian Supreme Court of Justice, Judgment on 21 April 1993; Honecker case: Bverfg (Third Chamber of Second Senate), order on 21 February 1992, Dt Z 1992, 216)

The Alien Tort Claims Act and the Torture Victims Protection Act are congressional acts. Federal courts treat the acts as incorporating rules of international law as federal rules of decision in which Plaintiffs may base their claims for monetary damages. In addition, there is a line of federal cases to the effect that some rules of customary international law have the status of federal common law in the United States. The rules most likely to have this status would be specific rules protecting basic human rights, such as the rule against torture, inhuman and degrading treatment.

v.) The Nigerian political situation and its consequences on international human rights litigation

We must admit that the major problem that Nigeria has faced since independence, and especially in the last twenty years, has been one of leadership. This problem is not limited to Nigeria but the entire African continent. Apart from a few countries such as Botswana, the entire African continent has a leadership crisis today. Only the incredulous or dishonest Africans would deny this fact. From Cote d'Ivoire to Zimbabwe, from Nigeria to Zambia, despotism seems to have reached new heights in the 1980s. Governments, military or civilian, have become increasingly autocratic, corrupt, and unaccountable to the people. Africans are often swift on blaming all their problems on the catchy and convenient excuse of "foreign imperialism." But an honest analysis of the situation in various African countries puts the blame inexorably on African leaders. The crises of economic decline, the dept burden, falling educational standards, unemployment, crime, violence, disease, especially the devastation of HIV, can all be blamed on irresponsible African leadership.

(Prof. Kofi Egbo, "The African Leadership Crisis," in The African Informer, Dec. 2002).

The specific case of Nigeria is particularly perplexing because whatever goes on in Nigeria has far-reaching implications for the entire African continent. Whether we realize it or not, many Africans look up to Nigeria as 'big brother.' As in every African family, if big brother is a buffoon, the family is doom because the younger siblings would not be any better.

The Shagari administration from 1979 to 1983 was, to put it mildly, inept and corrupt. But Nigeria never had it as bad until the military regimes of Generals Ibrahim Babangida, Sani Abacha and Abdusalami Abubakar from 1985 to 1999. Under the three, corruption was institutionalized; there was blatant looting of the national treasury, which has crippled the Nigerian economy till date. Worse still, state-sponsored terrorism of the citizenry became the order of the day. Time will fail me to enumerate each in this presentation but we cannot fail to remember the cold-blooded unlawful murders of Dele Giwa, Alhaja Kudirat Abiola, Pa Alfred Rewane, and the hanging of writer Ken Tsaro-Wiwa and his eight Ogoni environmental activists. Under General Abdusallami Abubakar who succeeded Abacha (and, by the way, was part of the decision-making bodies of the previous regimes), Chief M. K. O. Abiola, Nigeria's president-elect was murdered while still in detention.

In spite of some 16 years of a reign of terror by these individuals against the Nigerian people, the politicians who took over power from the military in 1999 seem to be oblivious to these realities. Today in Nigeria, in spite of the promises of President Olusegun Obasanjo to route out corruption, the politicians are more concerned about what they can siphon from the national treasury than righting what has gone wrong in Nigeria.

As lawyers, all of us here would agree the so-called 1999 Constitution was an imposition by the military. Many Nigerians acquiesced to it, if that was the easiest way to get the military to relinquish power. But, rather than listen to the clamor of a majority of Nigerians for popular constitution based on a Sovereign National Conference, the presidency and National Assembly are each tinkering with an illegal constitution to suit their individual purposes. President Obasanjo appointed a commission to "review" the constitution his first year in office; most Nigerians have never heard or seen the recommendation of that commission. Recently, the National Assembly, which obviously has wind of that commission's recommendations, appointed its own commission whose recommendations set term limits on the president and governors but not on legislators. Is that what Nigerians are asking for in the name of a Sovereign National Conference?

Two years ago, some states in Northern Nigeria proclaimed Sharia Law, a de facto rebellion against the Nigerian nation-state, or what a colleague has labeled as "secession from Nigeria." It is not my intention to raise any sectional emotions, but if we must call a spade a spade, hasn't any objective member of this august gathering wondered about the timing of the proclamation of Sharia Law in the states that have adopted it? My humble submission is that Sharia is being used as political tool rather than as an expression of true religious conviction.

Toward the 2003 elections, the same people who have wrought so much havoc on Nigeria are rearing their heads shamelessly to run for office. The same sycophants who led Nigeria to civil war between 1967 and 1970, the same sycophants who beat the drums of self-succession for Babangida and Abacha, the same sycophants are at it again "drafting" the same people to run for office. Perhaps more frightening is the determination of many incumbent politicians to retain their positions by any means possible, including violence. It is no secret that politicians finance the escalating violence in Nigeria. Some state governors are openly recruiting and arming the teeming jobless youths to murder their opponents and family members. The governor of a certain state who has seen the handwriting on the wall that he has no chance of winning the next election is boastfully campaigning on the platform that whether the citizens of his state vote for him or not, he is going to win re-election. As ludicrous as such a campaign against him may sound to us from here, the governor must be taken seriously; he knows what he is talking about.

At this juncture, it is necessary for each of us gathered here to pause to reflect on two sets of questions: 1. Not how, but WHY has Nigeria, the self-proclaimed "Giant of Africa," sunken to this level of anarchy and decay? WHY do successive Nigerian rulers feel so invincible and audacious? WHY do the same people keep recycling themselves in power? 2. Can anything be done about it?

The answer to the first set of questions is simple: As ignorant as many of us may view these miscreants, they have mastered the collective psyche of Nigerians. They know that our collective memory is very short indeed. They know that if they murdered each Nigerian's mother, there will still be some orphaned Nigerian sycophants who would hero-worship them for killing their mothers. But more importantly, they know that a majority of Nigerians would be too squeamish to even weep at their mother's funeral!

But, there is a beacon of hope. A growing number of Nigerians are beginning to ask hard questions and are taking action. In February 2000, a group of Nigerian political activists lit a little match that is growing into a towering inferno. They were able to work with a few other courageous Nigerians as plaintiffs to file a suit in the United States against five former Nigerian rulers for their actions while in power. The former rulers are General Muhammadu Buhari, General Ibrahim Babangida, Chief Ernest Shonekan, and General Abdusallami Abubakar. As a result of an international media blitz which warned the Nigerian leaders that they would be served summonses if they came to the US for a so-called Abdusallami Abubakar Distinguished Lecture at Chicago State University, the first three abstained. However, General Abubakar, with the usual arrogance he is used to in Nigeria, showed up and was promptly served a summons. For Abubakar, what some of his colleagues in Nigeria assured him was just simply noise making by Nigerian "taxi drivers and janitors" has turned out to be a huge nightmare.

It is no longer a secret that I am leading the team of attorneys for the plaintiffs in the case. And so, it is pertinent to mention here that some of the loudest initial critics who questioned the tenability of the suit were my Nigerian colleagues of the bar practicing here in the US. Whether out of lack of awareness or conscientious cynicism, some questioned the basis on which a suit could be brought against a "foreign Head of State in a US court for acts committed outside the US." Some scoffed that the suit was DOA (Dead on Arrival). As you all probably know, the case is now about two years old and it is very unlikely that Abubakar will be exonerated from the complaint against him. It is more likely that he would be held liable by the U.S Court.

There are a number of lessons to be learned from this action. First, as I have discussed earlier, the basis of the case is the US Alien Tort Act, which permits such a suit. Second, history has proved that all tyrants are cowards when confronted with the appropriate force; mere threats of summonses were enough to keep the three former Nigerians from coming to the U.S. Third, I predict a floodgate of similar suits in the near future. In fact, activists in some states in Nigeria have put their current governors and legislators on notice about similar actions against them.

The last lesson is one I feel is of significance to this gathering and it relates to the second question I posed earlier: Can anything be done about the situation? To answer that question, I would like to quote a short but highly instructive sentence from Professor Wole Soyinka's The Open sore of a Continent:

"Every thinking inhabitant of a given national space must surely, at some moment or the other of his existence, reflect upon the significance, or none, of his or her own identity as it relates to the existing or historical definitions of that space."
(Wole Soyinka, The Open Sore of a Continent, Oxford University Press, 1996).

So, while I am not advocating for every one of us to become a "freedom fighter" or political activist, we as Nigerian American lawyers should use our position and knowledge in ushering in and ensuring a true and sustainable democracy and respect for human rights in Nigeria. At the very least, such peaceful actions will serve as salutary caution to future Nigerian leaders about the universality of human rights violations and crimes against humanity. This is the challenge before us as Nigerian American lawyers.

vi) Problems and prospects

The U.S Court of Appeals in Wiwa v Shell, a case that involved civil suits brought against Shell Oil Company for the executions of several Nigerians, including prominent author, Ken Saro Wiwa, arising out of disputes over the development of oil resources in the homeland of Ogoni people summarizes the problems often encountered by Plaintiffs as follows:

" One of the difficulties that confront victims of torture under color of a nation's law is the enormous difficulty of bringing suits to vindicate such abuses. Most likely, the victims cannot sue in the place where the torture occurred. Indeed, in many instances, merely returning to that place would endanger the victim. It is not easy to bring such suits in the courts of another nation. Courts are often inhospitable. Such suits are generally time consuming, burdensome, and difficult to administer. In addition, because they assert outrageous conduct on the part of another nation, such suits may embarrass the government of the nation in whose courts they are brought. Finally, because characteristically neither the plaintiffs nor the defendants are ostensibly either protected or governed by the domestic law of the forum nation, courts often regard such suits as "not our business."
The good news however, is that the U.S Court of Appeals further held in Wiwa's case that "the new formulations of the Torture Victim Protection Act convey the message that torture committed under color of law of a foreign nation in violation of international law is "our business," as such conduct not only violates the standards of international law but also as a consequence violates our domestic law. In the legislative history of the TVPA, Congress noted that universal condemnation of human rights abuses "provide[s] scant comfort" to the numerous victims of gross violations if they are without a forum to remedy the wrong. This passage supports plaintiffs' contention that in passing the Torture Victim Prevention Act, Congress has expressed a policy of U.S. law favoring the adjudication of such suits in U.S. courts. If in cases of torture in violation of international law our courts exercise their jurisdiction conferred by the 1789 Act only for as long as it takes to dismiss the case for forum non-conveniens, we will have done little to enforce the standards of the law of nations.

KAYODE OLADELE, is the plaintiff counsel in the civil case against General A. Abubakar in a US Court.

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