Saturday, 16th December, 2017

The Officer in Charge

Nima Police Station
Off Ring Road Central
Accra

Dear Sir/Madam,

DEMAND NOTICE: BERNARD ANBATAAYELA MORNAH

We act as Solicitors for BERNARD ANBATAAYELA MORNAH, (our Client) and write
to you upon his firm instructions.

At about 9am this morning, I saw an incoming call from our Client, who is also the
National Chairman of the Peoples National Convention (PNC). I was unable to
answer his call, as I was then meeting with another client.

At 9:31am, I received a WhatsApp Messenger message from our Client as follows:

We have been picked in Rambo style and now at Nima Police Station. I abruptly
adjourned my meeting and called him back.

He informed me that he had previously written to the Ghana Police Service on behalf
of the Ghana-Togo Solidarity Movement, seeking permission to hold a rally in Ghana,
in support of persons in the Republic of Togo whose rights were being violated. The
Police requested for a meeting with the Movement to urge them not to hold the
rally, as they claimed they were short of numbers to provide the requisite
protection. The position of the Movement at the meeting was that, as a lot of
resources had already been invested by them in preparation for the rally, they would
be unable to cancel or postpone same. In the alternative, the Movement informed
the Police that they could resort to the terms of the Public Order Act to secure a
court order to postpone the rally.


This morning, as the rally was about to commence at the Kawukudi Park, a band of
police officers descended upon them, forcibly dispersed the gathering, rounded up
about twenty (20) members of the Movement and detained them at the Nima Police
Station. As of the time he was speaking to me, he and the others were being held at
the Nima Police Station. As at the time of writing this letter, the Police have still
not informed them the reason(s) for their arrest and detention and they are still
under detention.

I despatched a Staffer to the Police Station to monitor the situation, as I expected

the clear illegal arrest to abate momentarily. The last report I received from our
Staffer was to the effect that some or all of the 20 persons arrested were being
processed to be locked up in the Nima Police Station cells.

Therefore, we urgently wish to inquire from you the following:

1. Whether or not our Client, BERNARD ANBATAAYELA MORNAH, is in the
custody of the Nima Police Station, any of the affiliates of that Police Station,
or any officer or worker or affiliate or agent of that Police Station;

2. Whether or not our Client has been charged with any offence(s), and if so
what offence(s);

3. Whether or not our Client will be granted bail, and if so on what day and time;

4. Whether or not our Client will be put before a Court of law, and if so on what
day and time and at which Court.

I have copied the President of the Republic of Ghana, the Chief Justice, the
Attorney-General, and the Inspector General of Police on this letter for the following
reasons. The President is the employer of the Inspector General of Police; the Chief
Justice is the official empowered to appoint a judge to sit on any matter that may
arise regarding this case on a Saturday or Sunday; the Inspector General of Police is
the supervisor of the police officers who effected the arrest of our Client, and of
the Nima Police Station; and the Attorney-General is both the principal legal adviser
to Government and the nominal or substantive defendant in any human rights or
other action or proceedings we may decide to pursue to vindicate the rights of our
Client.

Finally, in the event that any notice is required for the institution of any legal
proceedings against you or any recipient of this letter, this letter shall constitute
such notice.
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Be accordingly advised.

Dr. Raymond Atuguba

(License No. GAR 14621/17)

CC:

1. The President of the Republic of Ghana

Office of the President
Flagstaff House
Kanda
Accra

2. The Chief Justice of the Republic of Ghana

Chief Justices Chambers
Supreme Court Building
Accra

3. The Attorney-General
Ministry of Justice and Attorney-Generals Department
Ministries
Accra

4. The Inspector General of Police

Ghana Police Service Headquarters
Cantonments
Accra

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