M & P LAW GREEN CHAMBERS: Ajayi Olubukola Seun vs Adeniyi Risikat Awero: Petitioner’s Petition

MATRIMONIAL CAUSES ACT, 1990

IN THE HIGH COURT OF OSUN STATE,

HOLDEN AT IKIRUN

SUIT NO: ………………

SUPPLEMENTARY PETITION FOR DECREE OF DISSOLUTION OF

MARRIAGE

BETWEEN
AJAYI OLUBUKOLA SEUN PETITIONER

AND

ADENIYI RISIKAT AWERO RESPONDENT

To: The above named High Court

Date of Petition: ………………. day of …………………, 2024.
The petitioner, AJAYI OLUBUKOLA SEUN by his supplementary
petition, petitions the court for a Decree of Dissolution of Marriage
against the respondent, ADENIYI RISIKAT AWERO on the additional
ground that:

1. The Respondent has exhibited a pattern of cruelty, frequent mood

swings, and a lack of cooperation and support. The Respondent has
consistently failed to satisfy the Petitioner’s sexual needs,
displaying aggression, deceitfulness, and an apparent disinterest in
the marriage. For at least five years immediately preceding the
filing of this Petition, the Respondent has remained withdrawn and
distant, making it intolerable for the Petitioner to continue living
with her. Consequently, the Respondent does not object to a Decree
being granted in accordance with Section 15 (1) and 2 (a) and (c) of
the Matrimonial Causes Act, 1990.

2. The Petitioner, having regard to the Provisions of Order VII rule

10 and rule 11 Sub-rule (6), reaffirm the content of the Petition
and stated as follows

MARRIAGE
3. The petitioner, AJAYI OLUBUKOLA SEUN, then a bachelor
married the Respondent ADENIYI RISIKAT AWERO then a
Spinster at the Ifako Ijaye Local Government Marriage Registry,
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Lagos State, on 9th day of April, 2015 in accordance with the

Marriage Act.

4. That the surname of the Respondent immediately before the

Marriage was ADENIYI.

BIRTH OF THE PETITIONER & RESPONDENT

5. That the Petitioner was born on 9TH DAY OF JUNE, 1984 and the
Respondent was born on 15th November, 1985.

DOMICILE OF THE PETITIONER AND THE RESPONDENT

6. The Petitioner and the Respondent are within the meaning of the
Matrimonial Causes Act domiciled in Nigeria. The facts on which the
court will be asked to find that the Petitioner and the Respondent
were domiciled in Nigeria are as follows: - they lived together after
the marriage at Oke Aro, Otemuyin, Ogun State later moved to 18
Murphy Street, Iwo road, Ibikunle area, Osogbo, Osun state before
finally resides at Dagbolu area, Osogbo, Osun State.

COHABITATION
7. After the marriage, the Petitioner and the Respondent lived
together as husband and wife at Dagbolu area, Osogbo, Osun State.
8. That Cohabitation had ceased to exist between the Petitioner and
the Respondent sometimes between 12th day of December, 2022
and they do not have any further intention to cohabit again.

CHILDREN
9. Particulars relating to children to whom Order V Rule 8 of the
Matrimonial causes Rules applies are as follows:

There are two children of the marriage:

a.) The 1st child of the marriage, Ajayi Diamond Oluwasemilore
who was born on 8th of January, 2016 (now 8 years old).
b.) The 2nd child of the marriage, Ajayi Verynice
Oluwadunmininu who was born on 7th of June, 2018 (now 6
years old)

PREVIOUS PROCEEDING
10. Since the marriage there has not been any proceeding in court
between the Petitioner and the Respondent.

HISTORY OF THE MARRIAGE

11. The facts/history relied upon by the Petitioner as constituting the
grounds specified below in paragraphs 1-3 is as summarized above.
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GROUND FOR PETITION

12. That the marriage has broken down irretrievably in accordance
with Section 15(1) & (2)(a) and (c) of the Matrimonial Causes Act,
1990

CONDONATION, CONNIVANCE & COLLUSION

13. The Petitioner has not condoned or connived at the grounds
specified above and is not guilty of collusion in presenting this
petition.

PROPOSED ARRANGEMENT FOR CHILDREN

14. Irrespective of all the issues between the Petitioner and the
Respondent, the Petitioner will continue to pay monthly allowance
only for the up keep of the child of the marriage.

ORDER SOUGHT
15. The Petitioner seeks the following Orders:
a.)A Decree of Dissolution of the Marriage between the Petitioner
and the Respondent on the grounds stated in paragraphs 1-3
above on the premise that the marriage has broken down
irretrievably.
b.)An order of this honorable court granting custody of the two
children of the marriage to the Petitioner.
c.) AND For Such Further Orders or other Orders as this honorable
court may deem fit to make in the Circumstance.

This Petition was settled by:

________________
Muyiwa Okedoye Esq

Filed on the ____ day of ________________, 2024 by Abbey Titilayo (Mrs.)

on behalf of the Petitioner whose address for service is C/O of his
solicitor M&P Law Green Chambers Arry Plaza, Suite 7&8, Opp Hezzy
Garden, Niyi Ibikunle Area, Osogbo Osun State.

ON NOTICE TO:
Respondent
ADENIYI RISIKAT AWERO
Awosuru Alekuwodo, Osogbo,
Osun State.
Tel:08110960270
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IN THE HIGH COURT OF OSUN STATE,

HOLDEN AT IKIRUN

SUIT NO: ………………

BETWEEN
AJAYI OLUBUKOLA SEUN PETITIONER

AND

ADENIYI RISIKAT AWERO RESPONDENT

To: ADENIYI RISIKAT AWERO

NOTICE OF PETITION

1. TAKE NOTICE that a petition has been presented to the above-

named court by AJAYI OLUBUKOLA SEUN of Murphy Street,
Iwo road, Ibikunle area, Osogbo, Osun state instituting
proceedings for Decree of Dissolution of the Petitioner’s marriage
with the Respondent.

2. A sealed copy of the petition is delivered to you with this Notice.

3. If you intend to consult a solicitor in connection with the

proceedings, you should take to him all the documents delivered
to you.

4. The form of the acknowledgement of service delivered to you

with this Notice should be completed and signed by you and
either you or your legal practitioner should immediately return it
to the Petitioner’s Legal Practitioner. A stamped and addressed
envelope is delivered to you for that purpose.

5. If you desire ……..

a.)To deny all the facts alleged in the petition;

b.)To allege any additional facts for the consideration of the
court.
c.) To submit to the Court that it should dismiss any of the
proceedings instituted by the petition or
d.)To make any other submission to the Court.
 M & P LAW GREEN CHAMBERS: Ajayi Olubukola Seun vs Adeniyi Risikat Awero: Petitioner’s Petition
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You should file an answer to the Petition.

6. If you wish to institute proceedings for dissolution of marriage,

nullity of marriage, judicial separation or restitution of conjugal
rights, you may do so in the answer to the petition filed by you. If
you institute proceedings for Dissolution of Marriage on the
ground that the Petitioner has committed adultery, you may also,
by the answer, institute proceedings for damages in respect of
adultery.

7. If you wish to institute proceedings for the purpose of seeking an

order with respect to maintenance for yourself, settlement, the
custody or guardianship of infant children of the marriage or the
maintenance, welfare, advancement or education of the children
of the marriage, you should do so by filing an answer to the
petition. If you fail to do so, you will have to obtain the leave of
the Court to institute the proceedings.

8. If you do not wish to file an answer but wish to receive a copy of

the document filed in connection with the proceedings, you
should file a notice of address for service. However, unless you
file an answer, you will not, without the leave of Court, be
entitled to furnish evidence to the court, or address the court, at
the trial of the proceeding and the court may hear and determine
the proceedings in your absence.

9. An answer or Notice of address of service filed by you must be

filed within 28 days after you received notice or within such
extended period as the petitioner or the Court allows, and service
of a copy of answer or notice must be effected in accordance
with the Matrimonial Causes Rules.

Dated this day of , 2024

____________________
REGISTRAR
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IN THE HIGH COURT OF OSUN STATE,

HOLDEN AT IKIRUN

SUIT NO: ………………

BETWEEN
AJAYI OLUBUKOLA SEUN PETITIONER

AND

ADENIYI RISIKAT AWERO RESPONDENT

VERIFYING AFFIDAVIT

I, AJAYI OLUBUKOLA SEUN, Male, Christian, Nigerian Citizen of

Murphy Street, Iwo road, Ibikunle area, Osogbo, Osun state do hereby
make oath and states as follows:
1. That I am the Petitioner in the above petition for the Dissolution
of marriage by virtue of which I am familiar with the facts of the
petition.

2. That the facts stated in the petition are matters of which I have
personal knowledge and they are true and correct.

3. That I hereby verify and affirm the facts stated in the petition.

4. That I make this oath in good faith believing same to be true and
correct in accordance with the provision of the Oath Act currently
in force.

________________
DEPONENT
Sworn to at the of High Court Registry, IKIRUN
This ___day of ________ ,2024

BEFORE ME

_____________________________
COMMISSIONER FOR OATHS
 M & P LAW GREEN CHAMBERS: Ajayi Olubukola Seun vs Adeniyi Risikat Awero: Petitioner’s Petition
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IN THE HIGH COURT OF OSUN STATE,

HOLDEN AT IKIRUN

SUIT NO: ………………

BETWEEN
AJAYI OLUBUKOLA SEUN PETITIONER

AND

ADENIYI RISIKAT AWERO RESPONDENT

CERTIFICATE RELATING TO RECONCILIATION

I, MUYIWA OKEDOYE Esq., Legal Practitioner certify that I am the

Legal Practitioner representing the Petitioner and that I have brought
to the attention of the Petitioner the provisions of the Matrimonial
Causes Rules relating to reconciliation of the parties to the marriage
and the approved marriage guidance organization reasonably
available to assist in effecting a reconciliation between the parties
being affected.

Dated this _________ day of ______________2024

--------------------------------------------
MUIWA OKEDOYE ESQ.
APPLICANT’S COUNSEL
M & P Law Green
Chambers
SOLICITORS/PROPERTY
CONSULTANTS
Suite 8, Arry Plaza, Dada
Estate, KLM.4, IWO IBADAN
Rd., Osogbo, Osun State.
: 08052723555,
08132330933
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 M & P LAW GREEN CHAMBERS: Ajayi Olubukola Seun vs Adeniyi Risikat Awero: Petitioner’s Petition
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IN THE HIGH COURT OF OSUN STATE,

HOLDEN AT IKIRUN

SUIT NO: ………………

BETWEEN
AJAYI OLUBUKOLA SEUN PETITIONER

AND

ADENIYI RISIKAT AWERO RESPONDENT

ACKNOWLEDGEMENT OF SERVICE

I, ADENIYI RISIKAT AWERO, acknowledge that on the _____ day of

______________________, 2024 at Awosuru Alekuwodo, Osogbo, Osun
State.

I received:

a.) A sealed copy of the Petition in this proceedings and;

b.) A Notice of Petition address to me

I also acknowledge that I am the person referred to in the sealed copy

of the petition as the Respondent and I am the person to whom the
Notice of Petition is addressed.

Dated this _______ day of ___________________, 2024

__________________________________________
ADENIYI RISIKAT AWERO
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IN THE HIGH COURT OF OSUN STATE,

HOLDEN AT IKIRUN

SUIT NO: ………………

BETWEEN
AJAYI OLUBUKOLA SEUN PETITIONER

AND

ADENIYI RISIKAT AWERO RESPONDENT

WRITTEN STATEMENT ON OATH OF AJAYI OLUBUKOLA SEUN

I, AJAYI OLUBUKOLA SEUN, Male, Christian, Nigerian Citizen and

Clergy Man of Murphy Street, Iwo road, Ibikunle area, Osogbo, Osun do
hereby make oath and states as follows that:

1. I am the Petitioner in the above petition for the dissolution of

marriage, and by virtue of this, I am fully conversant with the
facts of the case.

2. The Respondent is my wife, whom I married on April 9 th, 2015, in

accordance with the Marriage Act.

3. Approximately Nine years ago, I met the Respondent, then

known as ADENIYI RISIKAT AWERO, and we courted for about
six months before I decided to legally marry her.

4. We were married on April 9th, 2015, at the Ifako Ijaye Local

Government, Lagos State Marriage Registry, in accordance with
the provisions of the Marriage Act. Attached herewith and
marked Exhibit A is the Marriage Certificate issued to us at Ifako
Ijaye Local Government, Lagos State Marriage Registry.

5. After our marriage, the Respondent and I lived together as

husband and wife at at Oke Aro, Otemuyin, Ogun State later
moved to 18 Murphy Street, Iwo road, Ibikunle area, Osogbo,
Osun state before finally resides at Dagbolu area, Osogbo, Osun
State.

6. The Respondent has been cruel, prone to mood swings,

uncooperative, and unsupportive, refusing to satisfy my sexual
needs.
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7. The Respondent is also aggressive, deceitful, and obviously

disinterested in the marriage, having withdrawn and kept to
herself for at least five years.

8. Two years into the marriage, the Respondent began exhibiting

behaviors that I found intolerable and impossible to cope with.

9. The Respondent repeatedly denied me sexual pleasure, insulted

me on multiple occasions, distanced herself from me, and led a
secretive life, making it evident that she was no longer interested
in the marriage.

10. The Respondent further tarnished my image before her

Pastor, parents, and members of the church by telling them that I
am possessed and that whenever I speak, it seems as though a
demon is speaking through me.

11. The Respondent frequently used vulgar and offensive

language, which I found highly intolerable.

12. The Respondent engaged in indecipherable relationships

with several men, made secret calls, and chatted with strange
men, often deleting messages to conceal her actions.

13. I informed the Respondent that I was uncomfortable with

such relationships and requested that she terminate them.

14. The Respondent promised to change but continued these

relationships secretly, leading me to lose trust in her and develop
a nostalgic feeling that my life is in serious danger.

15. The Respondent password-protected her phone, made

strange calls at night, and denied me access to her phone.

16. The damage done by the Respondent’s behavior to my self-

esteem is such that I can no longer cohabit with her, and I find it
intolerable to continue living with her.

17. Therefore, I urge this honorable court to dissolve the

marriage celebrated between myself and the Respondent on
September 8, 2018, at the Anglican Church, Ido-Osun, Egbedore
LGA, Osun State.

18. That I make this oath in good faith believing same to be

true and correct in accordance with the provision of the Oath Act
currently in force.
________________
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DEPONENT
Sworn to at the of High Court Registry, IKIRUN
This ___day of ________, 2024

BEFORE ME

_____________________________
COMMISSIONER FOR OATHS
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IN THE HIGH COURT OF OSUN STATE,

HOLDEN AT IKIRUN

SUIT NO: ………………

BETWEEN
AJAYI OLUBUKOLA SEUN PETITIONER

AND

ADENIYI RISIKAT AWERO RESPONDENT

1. I, MUYIWA OKEDOYE Esq, the solicitor to the petitioner, certify

that this suit is ready for trial and request that this suit be set
down for trial at Ikirun Division of High Court of OSUN State.

2. At the trial of this suit, we proposed to call as witness the

petitioner and other relevant evidence requisite for the
determination of this suit.

3. No proceedings, other than proceedings comprising this suit, are

pending in this court between the petitioner and the Respondent.

4. The probable length of the trial is six months.

Dated this _________ day of ______________2024

--------------------------------------------
MUYIWA OKEDOYE ESQ.
APPLICANT’S COUNSEL
M & P Law Green
Chambers
SOLICITORS/PROPERTY
CONSULTANTS
Suite 8, Arry Plaza, Dada
Estate, KLM.4, IWO IBADAN
Rd., Osogbo, Osun State.
: 08052723555,
08132330933
 M & P LAW GREEN CHAMBERS: Ajayi Olubukola Seun vs Adeniyi Risikat Awero: Petitioner’s Petition
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 M & P LAW GREEN CHAMBERS: Ajayi Olubukola Seun vs Adeniyi Risikat Awero: Petitioner’s Petition
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FORM 33
IN THE HIGH COURT OF OSUN STATE,
HOLDEN AT IKIRUN

SUIT NO: ………………

BETWEEN
AJAYI OLUBUKOLA SEUN PETITIONER

AND

ADENIYI RISIKAT AWERO RESPONDENT

NOTICE is hereby given that this suit has been set down for trial at
High Court of Osun State, IKIRUN, Judicial Division on the day
of , 2023

Dated this _________ day of ____________________, 2024

………………….
Registrar

To.
ADENIYI RISIKAT AWERO
Awosuru Alekuwodo, Osogbo,
Osun State.
Tel:08110960270

Notes: 1. This notice does not necessarily state the actual date on
which this suit will be tried by the court. Inquiry may be made at the
office of the court as to the appropriate date on which the suit will be
tried. The date if the trial may in accordance with the usual practice of
the court, be published in certain daily newspaper.
2. If this suit proceeds to trial and a decree of dissolution of marriage
(or decree of nullity of a voidable marriage) is made, the marriage is
not dissolved (or annulled) until the decree has become absolute in
accordance with provision of section 58 of the Matrimonial Causes Act.
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IN THE HIGH COURT OF OSUN STATE,

HOLDEN AT EJIGBO

SUIT NO: ………………

BETWEEN
AJAYI OLUBUKOLA SEUN PETITIONER

AND

ADENIYI RISIKAT AWERO RESPONDENT

REGISTRAR CERTIFICATE THAT SUIT IS READY FOR TRIAL

1. I certify that this suit is ready for trial.

2. The documents filed in this suit disclose that no proceedings,
other than proceedings comprising this suit, are pending in this
court between the Petitioner and the Respondent.

3. The Petitioner complied with the provisions of Sub-rule (1) of

Rule 34 of Order XI of those rules but the Respondent failed to
attend (or take part in) a conference for the purpose of part 6 of
order XI of those rules.

4. I am satisfied that it is unnecessary for a certificate of means to

be obtained.

5. I certified that I have duly complied with the provisions of

Paragraphs (a) and (b) of sub-rule (5) of Rule 46 of Order XI of
those rules in relation to this suit.
Service of the Petition was affected on the Respondent by pasting
same at the premises of her last known address at Awosuru
Alekuwodo, Osogbo, Osun State.

Dated this ______ day of ____________, 2024

___________________
Registrar
ON NOTICE TO:
The Respondent
ADENIYI RISIKAT AWERO
Awosuru Alekuwodo, Osogbo,
Osun State.
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Tel:08110960270