Ayisi Addo sues Anas, Tiger Eye, 7 others for defamation

Justice Ayisi Addo the following reliefs:

i. General damages for defamation.

ii. Aggravated damages for the malicious recordings, publication, republication and circulation of the said audio visual recordings.

iii. Exemplary damages for the reckless publication, republication and circulation of the said audio visual recordings.

iv. Compensatory damages for the damage done to the Plaintiff’s reputation.

v. A declaration that the 1st Defendant carefully and maliciously pieced together the audio visual recordings and the transcripts thereof in a manner to incriminate the Plaintiff on the allegations of bribery and corruption.

vi. A declaration that the audio visual recordings and the transcripts thereof were fraudulently and unlawfully obtained by the 1st Defendant.

vii. A declaration that the Plaintiff never demanded any money from the 1st Defendant to influence his decision in any case pending before him.

Read Below the full details of the suit:

2. The 1st Defendant is an unregistered entity which according to its website

tigereyepi.org provides its clients with accurate, efficient and cost effective private investigations in a timely manner.

3. The Plaintiff avers that the 1st Defendant is not a legally registered company per a search conducted at the Registry of the Registrar-General’s Department dated 3rd November, 2015.

4. The Plaintiff avers that the 1st Defendant is not licenced to carry out privateinvestigations under the relevant laws of Ghana.

5. The Plaintiff avers that the 2nd Defendant is the self-styled Chief Executive Officer of the 1st Defendant, the Acting Editor of the New Crusading Guide Newspaper and a lawyer.

6. The Plaintiff says that the 3rd Defendant is the publisher of the New Crusading Guide Newspaper.

7. The Plaintiff avers that the 4th Defendant is the owner and operator of Starr FM, a radio station based in Accra.

8. The 5th Defendant is an organization that purports to promote media rights and freedom of expression in West Africa.

9. The 6th Defendant is the official of the Ministry of Foreign Affairs with oversight responsibility for the Accra International Conference Centre.

10. The 7th Defendant is the day to day administrator and manager of the Accra International Conference Centre.

11. The Plaintiff says that the 8th Defendant is the owner and operator of the Global Cinemas, a cinema complex located at Old Barrier Junction, Weija.

12. The Plaintiff says that the 9th Defendant is the principal legal advisor to the government of Ghana and the person against whom all civil proceedings against the State and its organs shall be directed at.

13. The Plaintiff has been a lawyer for 19 years and has been a member of the Bench for 7 years.

14. The Plaintiff avers that he was at all material times a Justice of the High Court, Tamale.

15. The Plaintiff avers that he received a letter from the Office of the Chief Justice dated 9th September, 2015, titled “Petition in Accordance with Article 146 of the 1992 Constitution on allegation of Bribery”.

16. The Plaintiff avers that he duly perused the said letter dated 9th September, 2015, and found that an allegation of bribery was levelled against him by the 1st Defendant in respect of a case he presided over titled: Hans vs. Nuhu Abu Hassan with suit number RPC/10/14.

17. The Plaintiff avers that the Office of the Chief Justice attached a copy of the particulars of the alleged misconduct and a transcript marked A and B filed together with the petition by the 1st Defendant.

18. The Plaintiff further avers that the letter from the Office of the Chief Justice stated that His Excellency, the President had forwarded Tigereyepi’s petition to the Office of the Chief Justice for her action as required under Article 146 of the 1992 Constitution of Ghana which petition was accompanied by audio visual recordings.

19. The Plaintiff avers that the said audio visual recordings purportedly contained the evidence in support of the allegations of bribery levelled by Tigereyepi against the Plaintiff.

20. The Plaintiff avers that the Chief Justice relying on the said audio visual recordings and the transcript of the alleged misconduct requested the Plaintiff to respond to Tigereyepi’s allegations by the 14th September, 2015.

21. The Plaintiff avers that he filed his response in accordance with the Chief Justice’s directive in a letter dated 11th September, 2015.

22. The Plaintiff avers that the 1st Defendant made the following defamatory allegations against him in the said petition:

“I negotiated and paid an amount of two thousand Ghana Cedis (GH?2,000) to Justice Addo in order for him to find the defendant not liable”.

23. The Plaintiff avers further that he denied ever taking any bribe from any person in respect of a case pending before him.

24. The Plaintiff states that the Chief Executive Officer of Tigereyepi, the 2nd Defendant, caused to be published on various media platforms, the defamatory audio visual recordings the 1st Defendant had unlawfully procured in support of its bribery allegations against the Plaintiff.

25. The Plaintiff states further that the 1st, 2nd, 3rd, 4th, 5th, 6th and 7th Defendants screened the unlawfully procured defamatory audio visual recordings at the Accra International Conference Centre on the 22nd and 23rd September, 2015.

PARTICULARS OF DEFAMATION

i. That the 1st Defendant in a petition signed by the 2nd Defendant said “I negotiated and paid an amount of two thousand Ghana Cedis (GH?2,000) to Justice Addo in order for him to find the defendant not liable”.

ii. That the 1st Defendant in conjunction with the 2nd, 3rd, 4th, 5th, 6th and 7th Defendants advertised a public screening of the said audio visual recordings at the Accra International Conference Centre on the 22nd and 23rd September, 2015 at 8pm titled “Ghana In the Eyes of God: Epic of Injustice”.

iii. That the 1st, 2nd , 3rd, 4th, 5th, 6th and 7th Defendants screened the unlawfully procured defamatory audio visual recordings to the general public at the Accra International Conference Centre on the 22nd and 23rd September, 2015.

26. It is the Plaintiff’s contention that by the ordinary meaning, the said petition accompanied by the audio visual recordings was meant to portray the Plaintiff as a corrupt and criminally minded judge and public officer, and a common criminal.

27. The Plaintiff contends further that by the ordinary meaning, the said petition accompanied by the audio visual recordings was meant to portray the Plaintiff as a judge who perverts the cause of justice by demanding bribes from parties appearing before him to influence the judgments he delivers.

28. The Plaintiff avers further that the 8th Defendant republished the defamatory audio visual recordings of the Plaintiff at the Global Cinemas, a cinema complex located at Old Barrier Junction, Weija on the 24th and 25th September, 2015.

29. The Plaintiff says that the 4th Defendants republished the defamatory audio visual recordings against the Plaintiff on their website and on their YouTube Channel titled "Exclusive Video: How Judge Ayisi Addo Took Bribe" on 15th October, 2015 with the hyperlink https://www.youtube.com/watch?v=3tK1cdxq3ro.

PARTICULARS OF DEFAMATION

i. Republication of a video titled “Exclusive Video: How Judge Ayisi Addo Took Bribe” on the 4th Defendant’s website starrfmonline.com.

ii. Republication of a video titled “Exclusive Video: How Judge Ayisi Addo Took Bribe” on the 4th Defendant’s YouTube Channel on the worldwide web.

30. It is the Plaintiff’s contention that by the ordinary meaning, the said publication of the audio visual recordings at the Accra International Conference Centre was meant to portray the Plaintiff as a corrupt judge and public officer, criminally minded, and a common criminal.

31. The Plaintiff contents that by its ordinary meaning, the public screening of the 1st Defendant’s unlawfully obtained and manipulated audio visual recordings was meant to portray the Plaintiff as a judge who perverts the cause of justice by demanding bribes from persons to influence the judgments he delivers.

32. The Plaintiff says that due to the publication of the said audio visual recordings at the Accra International Conference Centre on the 22nd and 23rd September, 2015, he has suffered great distress, embarrassment and damage to his reputation as a lawyer and a Justice of the Superior Court.

33. The Plaintiff contends that the republication of the audio visual recordings by 4th Defendant titled "Exclusive Video: How Judge Ayisi Addo Took Bribe" on 15th October, 2015 generally imputes criminal conduct on the Plaintiff by the 4th Defendant.

34. The Plaintiff avers that the public screening of the said audio visual recordings was calculated to scandalize and abuse his person and also to prejudice the public against him.

35. The Plaintiff avers that the Defendants’ actions of publishing the audio visual recordings was meant to injure his reputation by exposing him to public hatred, ridicule and contempt.

36. The Plaintiff avers that the public screening was essentially set to prejudice the ongoing investigations as part of the impeachment process by portraying the Plaintiff to be guilty of the offence of bribery before the preliminary investigations are concluded.

37. The Plaintiff avers that the publication of the pictures and transcripts of the said audio visual recordings by the 1st, 2nd, 3rd and 4th Defendants was premeditated and designed to injure his reputation by exposing him to public hatred, ridicule and contempt.

38. The Plaintiff avers that the republication of the audio visual recordings by the 4th Defendant on its YouTube channel on the worldwide web, and in effect to the whole world, was calculated to disparage the Plaintiff personally and his position as a lawyer and a Justice of the Superior Court of Ghana.

39. The Plaintiff avers that the said audio visual recordings were obtained illegally and maliciously.

PARTICULARS OF MALICE

a. That the 1st Defendant fraudulently misrepresented itself as a relative of the Defendant in the case titled Hans vs. Nuhu Abu Hassan with suit number RPC/10/14 in order to unlawfully procure the audio visual recordings and its transcripts thereof of the Plaintiff.

b. That the 1st Defendant unlawfully recorded the Plaintiff and pieced together the audio visual recording in a manner to incriminate the Plaintiff.

c. That the method or procedure adopted by the 1st Defendant in procuring the audio visual recordings and its transcripts thereof of the Plaintiff was illegal and intended only to falsely demonstrate that the Plaintiff has received a sum of money to influence the Plaintiff’s conduct of the case in question.

40. The Plaintiff contends that the audio visual recordings and its transcripts thereof were procured through fraud by the 1st Defendant with the sole aim of incriminating the Plaintiff.

PARTICULARS OF FRAUD

a. The Plaintiff never demanded from the 1st Defendant or any other person any sum of money nor did he receive any sum of money to influence his conduct in the suit titled Hans vs. Nuhu Abu Hassan with suit number RPC/10/14.

b. The method or procedure adopted by the 1st Defendant in procuring the audio visual recordings and its transcripts thereof of the Plaintiff was illegal and intended only to demonstrate that the Plaintiff has received a sum of money to influence the Plaintiff’s conduct of the case in question.

c. That the Plaintiff fraudulently misrepresented itself as a relative of the Defendant in the case titled Hans vs. Nuhu Abu Hassan with suit number RPC/10/14 in order to unlawfully procure the audio visual recordings and its transcripts thereof of the Plaintiff.

41. That the said audio visual recordings and the transcripts thereof were illegally and maliciously pieced together to falsely incriminate the Plaintiff.

42. In consequence, the Plaintiff’s reputation has been seriously damaged in the eyes of well-meaning persons in the society and he has suffered distress and embarrassment. WHEREFORE the Plaintiff claims against the Defendants both jointly and severally for the following reliefs:

i. General damages for defamation.

ii. Aggravated damages for the malicious recordings, publication, republication and circulation of the said audio visual recordings.

iii. Exemplary damages for the reckless publication, republication and circulation of the said audio visual recordings.

iv. Compensatory damages for the damage done to the Plaintiff’s reputation.

v. A declaration that the 1st Defendant carefully and maliciously pieced together the audio visual recordings and the transcripts thereof in a manner to incriminate the Plaintiff on the allegations of bribery and corruption.

vi. A declaration that the audio visual recordings and the transcripts thereof were fraudulently and unlawfully obtained by the 1st Defendant.

vii. A declaration that the Plaintiff never demanded any money from the 1st Defendant to influence his decision in any case pending before him.