..Alleges forgery and fake law certificate
The dispute surrounding the ownership of the 65-year-old law firm of Gaisie Zwennes Hughes & Co. has escalated, taking an intriguing turn as Charles Zwennes, rubbished an application filed by ex-Speaker of Parliament, Ebenezer Begyina Sekyi Hughes.
The application, seeking to strike out certain pleadings in a lawsuit against Mr Hughes, is labeled an abuse of process by Zwennes, who claims it lacks merit.
Charles Zwennes, one of the plaintiffs, countered the application in an affidavit, asserting that the ex-Speaker’s motion, fails to demonstrate any deficiency in the writ of summons or establish that the pleadings are scandalous, frivolous, vexatious, or constitute an abuse of process.
He stated only the ex-Speaker and his daughters, Antoinette and Josephine alias “Josey Hughes” could be said to have hoped to benefit and to have hoped to gain from these perpetrated acts of forgery and fraud, including a false claim by one of them of being a lawyer trained both in the UK and Ghana School of Law, which merit trial and investigation by the Court.
The legal battle stems from Mr Hughes, ejecting Charles and Peter Raymond Zwennes, along with Jacqueline Lucille Zwennes, the late widow of CBK Zwennes, asserting they were never made partners in the law firm.
Mr Hughes argues that the Annual Renewal for Incorporated Private Partnerships filed annually with the Registrar General’s Department, never listed the respondents as partners, even after the death of CBK Zwennes.
He contends they lack the standing to mount this legal action in the name of Gaisie Zwennes Hughes & Co with branches in Accra and Takoradi.
Charles Zwennes rebuts these claims, asserting that the respondents were appointed as partners in 2002 and were treated as such by the existing partners.
He presents evidence, including draft Deeds of Partnership and correspondence from CBK Zwennes, demonstrating their inclusion in the firm.
The legal battle involves allegations of forgery and fraudulent misrepresentation against Mr Sekyi Hughes.
As the lawsuit unfolds, both parties are set to present their evidence in court, with Charles Zwennes, insisting that their legal action is grounded in the tort of misrepresentation.
The case raises serious matters of fraud and collusion, which, according to Zwennes, will be demonstrable through evidence of document suppression and falsification of public records.
Charles Zwennes contends that the application, seeking the striking out and dismissal of certain pleadings in the lawsuit against him, is misconceived and lacks merit.
The ex-Speaker of Parliament, filed the application through Theophilus Masoperh, the Managing Clerk of the Takoradi branch of the law firm, aiming to remove specific portions of the lawsuit against Hughes and have the case dismissed.
The legal dispute originated from Charles and Peter Raymond Zwennes being ousted from the law firm, with the ex-Speaker, claiming they were never made partners, as per the last will of CBK Zwennes. Sekyi Hughes’ motion argues that the annual renewal filings with the Registrar General’s Department never listed the Zwennes cousins and Jacqueline Lucille Zwennes as partners.
In response, Charles Zwennes insisted that there is substantial evidence, including correspondence, draft partnership deeds, and registration forms, proving their appointment as partners from 2002 until CBK Zwennes’s death.
The affidavit highlights handwritten drafts and notes from CBK Zwennes outlining the appointment of new partners and the restructuring of the firm.
Charles Zwennes, claims these documents clearly indicate that the Zwennes cousins and Jacqueline Lucille Zwennes were recognized as partners.
Furthermore, Charles Zwennes alleges forgery and fraudulent misrepresentation against Sekyi Hughes, asserting that the ex-speaker, along with his daughters, hoped to benefit from acts of forgery and fraud.
He argues that the current legal action against Sekyi Hughes exposes conduct offensive to the law and calls the application to have the matter struck out as an abuse of process.
The legal battle is set to continue as the court is expected to determine the validity of the pleadings and the allegations of forgery and fraud in the upcoming trial hearings.
Sekyi Hughes’ application which was deposed to by one Theophilus Masoperh, the Managing Clerk of the Takoradi branch of the law firm, wants some of the pleadings in the lawsuit filed against him struck out, and also dismissed.
Mr Sekyi Hughes, has been dragged to court for kicking out Charles and Peter Raymond Zwennes, saying they, together with Jacqueline Lucille Zwennes, the late widow of CBK Zwennes, were never made partners of the law firm of Gaisie Zwennes Hughes & Co as evidenced in his last will.
Charles and Peter had insisted that since 2002, they had been partners in the law firm and practised as such. Thus found it strange that the ex-speaker, a contemporary of the father and uncle, respectively, will kick them out of the prominent law firm shortly after his death.
According to Sekyi Hughes’ motion, “the Annual Renewal for Incorporated Private Partnerships which is filed annually by Partner of the firm to the Registrar Generals Department’s as required by law has never had Respondents and Jacqueline Lucille Zwennes as partners at all times even at the time of the death of CBK Zwennes”.
The ex-Speaker promised to demonstrate Charles and Peter respectively knew their status hence never complained or protested in any shape or form about their non-inclusion as partners. They therefore lack the locus standi/capacity to mount this action in the name of Gaisie Zwennes Hughes & Co.
But Charles in his reply noted that the ex-Speaker “intentionally avoids deposing to the litany of palpable falsehoods himself in the affidavit in support, and unkindly shields behind Theophilus Masoperh who is a clerk with no real or true knowledge of the facts, and knoweth not the false oath he giveth”.
Mr Zwennes insists that “their legal suit brought against the Defendant/Applicant as an individual is one grounded in the tort of misrepresentation, and raises very serious matters against him of fraud and collusion which are demonstrable by the evidence available to them of his suppression of documents and his falsification of a public record amongst other things”.
According to him the “Statement of Defence, issues arising out of the pleadings are properly joined and more than well-deserving of being set down for final determination through the due process of a trial hearing”.
He stated Theophilus Masoperh did not offer any evidence to support his bare allegation that E.B. Gaisie objected to their appointment as partners, the said E.B. Gaisie never signed or filed any documents concerning the partnership at the Registrar General’s Department or elsewhere to suggest that he did not hold, consider and treat the Plaintiff/Respondents indeed to be partners of the firm.
Charles stated that “it is baldly false for the said Theophilus Masoperh to say further in support of his bare allegation that the process of their appointment ended and can be established by C.B.K. Zwennes re-registering the firm in 2016 only with the Defendant/Applicant when there is clear evidence to show the contrary is actually the case”.
He insisted that “throughout the years from their appointment in August 2002 until his untimely death, C.B.K. Zwennes engaged in numerous correspondence with the Defendant/Applicant regarding the facts of: (i) The appointment of the new Partners, (ii) The re-drafting of a new Deed, and (iii) The registration of the new composition of the partnership which included the Plaintiffs/Respondents”.
“That regarding the fact of the appointment of the Plaintiff/Respondents the Partnership File of CBK Zwennes in which he kept his correspondence with Defendant/Applicant and documents about the firm contains the following:
The handwritten draft copy of a written by CBK Zwennes to the Defendant/Applicant stating as follows: “Dear Sekyi, RE: GZH FORM B, I am sending the required Notice of Appointment of new Partners (since 2003) for your signature and return for filing. We tried to complete the Form and file this in 2002 after the new Partners had been approved by you & Eddie (of blessed memory), but the Companies Registry could not trace our partnership file. Do you have a copy of the Partnership Deed in Sekondi? Please sign your portion of the Form B and return to me for filing. PS: I have made the date of appointment December 2010 instead of 2002 because of the statutory penalties for a late filing! CBK.” (I attach a copy of the original hand-written draft letter hereto and mark same as “EXH1”).
“The hand-written working notes of CBK Zwennes dated 12/04/2013 and outlining a 5-stage roadmap for restructuring the firm stating as follows: “Check 09/04/2013. New Partnership Deed. (1) Draft – pursuant to death earlier of Ed.B.G. and Saki S., leaving EBSHghs & CBKZ as old partners. (2) The ff were on …..agreed appointed to be partners by Ed.B.G., CBK & EBSH before the death and have carried on in said partnership to date. (3) Agreed now between the existing partners to reconstitute the partnership by approving additional terms of a new amended substituted Partnership Deed in the Schedule hereto signed by all the partners and agreed to be substituted for the existing old P Deed. (4)Now Therefore upon the signatures executed hereunto and to the Scheduled Deed attached the existing partners & new partners (parties) shall be and carry on the business of legal practitioners as previously carried out under the name and style of GZH&CO, etc. (5) The said Partnership Deed & the firm name shall be registered under the Registration of Business Names Act etc/or the I.P.P. Act (1962) (Act 152).” (I attach a copy of the handwritten roadmap for restructuring the firm hereto and mark same as “EXH2”).
The above show, he says shows that he and peter had been appointed as partners and were treated as such by all the earlier Partners immediately upon their appointment in 2002 and that a new partnership deed was in the making, hence one not having as yet been signed by the Plaintiff/Respondents.
Regarding the fact of the re-drafting of the new Deed of Partnership for the Firm the Partnership File of CBK Zwennes on which he kept all his correspondence with Defendant/Applicant and documents about the firm contains the following:
The handwritten draft copy of a letter written by CBK Zwennes to the Defendant/Applicant stating as follows: “E.B. Sakyi-Hughes, G.Z.H., Takoradi. Dear Sekyi, You may have heard that I have achieved the venerable status of an octogenarian by the grace and mercy of God. I did not get a card from you! How come? Anyway, I think the matter of the Partnership practice (GZH) in which you and I are the “oldest” subsisting partners should now be properly addressed. The 1963 Agreement needs to be reformed so that the practice can look confidently into the future as our legacy to legal practice in Ghana, by us as “founding fathers”. I have not been able to get a copy of the original Partnership Agreement either from my office in Accra, or from Takoradi after much search. Its terms of course need to be revised and amended and brought up to date to reflect the actual practice relationship adopted by the partners over the years, reflecting especially the near independence of each branch office. I will have to re-write a new partnership deed with your consent which I am now working on. Can you fax me your copy of the old Agreement if you can find it. Thanks. I am also forwarding to you belatedly the completed Statement of Change under S.7 (particulars of change) for your signature which I should have completed and filed in 2002 to reflect the new partners when appointed. Please expedite and thanks, it would be a special pleasure to see you in Accra. Regards to Betty. Kwesi Z.” (I attach a copy of the original hand-written draft letter hereto and mark same as “EXH3”).
A Note entered in his own handwriting on the inside jacket of the Partnership File of C.B.K. Zwennes dated 2011, in which he stated as follows: “Restructure of the Firm. NB. To propose to re-write a new P. Agreement and terms by consent of existing partners and substitute same for original Partnership Deed of 1963 which cannot be traced at the Registry. (sgd.) CBKZ, 2011.
Sekondi Office. Clerk – Mr Masoperh.” This would be a reference to the said same Masoperh, who at least was also aware that the original Partnership Deed could not be traced at the Registry. (I attach a copy of the original hand-written Note hereto and mark same as “EXH4”).
Also with respect to the Certificate of Incorporation of the firm Gaisie Zwennes Hughes & Co., another daughter of the Defendant/Applicant, who – (in her case) at least does not falsely hold herself out to the general public as a lawyer fit to practice – appears on the face of a Certificate of Incorporation dated 12th October 2016 as a partner of our firm.
The false certificate states: “Names of Partners: Antoinette Hughes, Charles Bartels Kwesi Zwennes, Ebenezer Begyina Sekyi Hughes”. That a Search at the Registrar General’s Department shows that the said Antoinette Hughes had once upon a time been presented for registration as a partner of the firm and has since been deleted as such. (I attach a copy of the said fraudulent Certificate of Incorporation hereto and mark same as “EXH7”).
To him, only the ex-Speaker and his daughters, Antoinette and Josey Hughes could be said to have hoped to benefit and to have hoped to gain from these perpetrated acts of forgery and fraud, which merit trial and investigation by this Honourable Court.
According to him, the instant suit brought by him and his cousin raises very serious allegations of forgery, and fraudulent misrepresentation against Mr Sekyi Hughes, which do not breach Order 11 Rule 18 of C.I. 47, but rather expose conduct deeply offensive to law, and which, they will easily establish well above and beyond the standard of proof required at the eventual trial and hearing of this lawsuit.
In this regard, the instant application is rather an abuse of process intended by the Mr Sekyi Hughes to serve the collateral purpose of shielding him from answering for his wrongful acts and preventing him from facing public opprobrium which will be his only inheritance as the outcome of the course of justice.
“..Ironically and laughably, the false allegations of dishonesty being levelled against me in paragraphs 14 and 15 by Theophilus Masorpeh relate to my written requests to the Registrar General’s Department to correct the false entries on her Register. My written requests to show also JL Zwennes as a partner up until her death in October 2020 and to show her as no longer being so thereafter upon advent of her death was purely motivated by my honesty and my genuine desire to have the public record corrected of its mistakes in order for it to accurately reflect the true state of affairs as regards ownership of the law firm to which I belong and co-own. My applications to the Office of the Registrar and the Head of Legal Department were made to the appropriate officers and officials in writing and only after it became clear to me that the Defendant/Applicant was playing a game of hide-and-seek to avoid facing 2nd Plaintiff and I to answer for his wrongful deeds”.
“…my letter which Defendant/Applicant has attached to his affidavit as “Exhibit 8.1” rather goes to show by a reference to its second paragraph that my application for correcting the record was following a process as guided by the Office of the Registrar, but who finally advised us to sue the Defendant instead, given his reprehensible, unenviable conduct”.
The dispute surrounding the ownership of the 65-year-old law firm of Gaisie Zwennes Hughes & Co. has escalated, taking an intriguing turn as Charles Zwennes, rubbished an application filed by ex-Speaker of Parliament, Ebenezer Begyina Sekyi Hughes.
The application, seeking to strike out certain pleadings in a lawsuit against Mr Hughes, is labeled an abuse of process by Zwennes, who claims it lacks merit.
Charles Zwennes, one of the plaintiffs, countered the application in an affidavit, asserting that the ex-Speaker’s motion, fails to demonstrate any deficiency in the writ of summons or establish that the pleadings are scandalous, frivolous, vexatious, or constitute an abuse of process.
He stated only the ex-Speaker and his daughters, Antoinette and Josephine alias “Josey Hughes” could be said to have hoped to benefit and to have hoped to gain from these perpetrated acts of forgery and fraud, including a false claim by one of them of being a lawyer trained both in the UK and Ghana School of Law, which merit trial and investigation by the Court.
The legal battle stems from Mr Hughes, ejecting Charles and Peter Raymond Zwennes, along with Jacqueline Lucille Zwennes, the late widow of CBK Zwennes, asserting they were never made partners in the law firm.
Mr Hughes argues that the Annual Renewal for Incorporated Private Partnerships filed annually with the Registrar General’s Department, never listed the respondents as partners, even after the death of CBK Zwennes.
He contends they lack the standing to mount this legal action in the name of Gaisie Zwennes Hughes & Co with branches in Accra and Takoradi.
Charles Zwennes rebuts these claims, asserting that the respondents were appointed as partners in 2002 and were treated as such by the existing partners.
He presents evidence, including draft Deeds of Partnership and correspondence from CBK Zwennes, demonstrating their inclusion in the firm.
The legal battle involves allegations of forgery and fraudulent misrepresentation against Mr Sekyi Hughes.
As the lawsuit unfolds, both parties are set to present their evidence in court, with Charles Zwennes, insisting that their legal action is grounded in the tort of misrepresentation.
The case raises serious matters of fraud and collusion, which, according to Zwennes, will be demonstrable through evidence of document suppression and falsification of public records.
Charles Zwennes contends that the application, seeking the striking out and dismissal of certain pleadings in the lawsuit against him, is misconceived and lacks merit.
The ex-Speaker of Parliament, filed the application through Theophilus Masoperh, the Managing Clerk of the Takoradi branch of the law firm, aiming to remove specific portions of the lawsuit against Hughes and have the case dismissed.
The legal dispute originated from Charles and Peter Raymond Zwennes being ousted from the law firm, with the ex-Speaker, claiming they were never made partners, as per the last will of CBK Zwennes. Sekyi Hughes’ motion argues that the annual renewal filings with the Registrar General’s Department never listed the Zwennes cousins and Jacqueline Lucille Zwennes as partners.
In response, Charles Zwennes insisted that there is substantial evidence, including correspondence, draft partnership deeds, and registration forms, proving their appointment as partners from 2002 until CBK Zwennes’s death.
The affidavit highlights handwritten drafts and notes from CBK Zwennes outlining the appointment of new partners and the restructuring of the firm.
Charles Zwennes, claims these documents clearly indicate that the Zwennes cousins and Jacqueline Lucille Zwennes were recognized as partners.
Furthermore, Charles Zwennes alleges forgery and fraudulent misrepresentation against Sekyi Hughes, asserting that the ex-speaker, along with his daughters, hoped to benefit from acts of forgery and fraud.
He argues that the current legal action against Sekyi Hughes exposes conduct offensive to the law and calls the application to have the matter struck out as an abuse of process.
The legal battle is set to continue as the court is expected to determine the validity of the pleadings and the allegations of forgery and fraud in the upcoming trial hearings.
Sekyi Hughes’ application which was deposed to by one Theophilus Masoperh, the Managing Clerk of the Takoradi branch of the law firm, wants some of the pleadings in the lawsuit filed against him struck out, and also dismissed.
Mr Sekyi Hughes, has been dragged to court for kicking out Charles and Peter Raymond Zwennes, saying they, together with Jacqueline Lucille Zwennes, the late widow of CBK Zwennes, were never made partners of the law firm of Gaisie Zwennes Hughes & Co as evidenced in his last will.
Charles and Peter had insisted that since 2002, they had been partners in the law firm and practised as such. Thus found it strange that the ex-speaker, a contemporary of the father and uncle, respectively, will kick them out of the prominent law firm shortly after his death.
According to Sekyi Hughes’ motion, “the Annual Renewal for Incorporated Private Partnerships which is filed annually by Partner of the firm to the Registrar Generals Department’s as required by law has never had Respondents and Jacqueline Lucille Zwennes as partners at all times even at the time of the death of CBK Zwennes”.
The ex-Speaker promised to demonstrate Charles and Peter respectively knew their status hence never complained or protested in any shape or form about their non-inclusion as partners. They therefore lack the locus standi/capacity to mount this action in the name of Gaisie Zwennes Hughes & Co.
But Charles in his reply noted that the ex-Speaker “intentionally avoids deposing to the litany of palpable falsehoods himself in the affidavit in support, and unkindly shields behind Theophilus Masoperh who is a clerk with no real or true knowledge of the facts, and knoweth not the false oath he giveth”.
Mr Zwennes insists that “their legal suit brought against the Defendant/Applicant as an individual is one grounded in the tort of misrepresentation, and raises very serious matters against him of fraud and collusion which are demonstrable by the evidence available to them of his suppression of documents and his falsification of a public record amongst other things”.
According to him the “Statement of Defence, issues arising out of the pleadings are properly joined and more than well-deserving of being set down for final determination through the due process of a trial hearing”.
He stated Theophilus Masoperh did not offer any evidence to support his bare allegation that E.B. Gaisie objected to their appointment as partners, the said E.B. Gaisie never signed or filed any documents concerning the partnership at the Registrar General’s Department or elsewhere to suggest that he did not hold, consider and treat the Plaintiff/Respondents indeed to be partners of the firm.
Charles stated that “it is baldly false for the said Theophilus Masoperh to say further in support of his bare allegation that the process of their appointment ended and can be established by C.B.K. Zwennes re-registering the firm in 2016 only with the Defendant/Applicant when there is clear evidence to show the contrary is actually the case”.
He insisted that “throughout the years from their appointment in August 2002 until his untimely death, C.B.K. Zwennes engaged in numerous correspondence with the Defendant/Applicant regarding the facts of: (i) The appointment of the new Partners, (ii) The re-drafting of a new Deed, and (iii) The registration of the new composition of the partnership which included the Plaintiffs/Respondents”.
“That regarding the fact of the appointment of the Plaintiff/Respondents the Partnership File of CBK Zwennes in which he kept his correspondence with Defendant/Applicant and documents about the firm contains the following:
The handwritten draft copy of a written by CBK Zwennes to the Defendant/Applicant stating as follows: “Dear Sekyi, RE: GZH FORM B, I am sending the required Notice of Appointment of new Partners (since 2003) for your signature and return for filing. We tried to complete the Form and file this in 2002 after the new Partners had been approved by you & Eddie (of blessed memory), but the Companies Registry could not trace our partnership file. Do you have a copy of the Partnership Deed in Sekondi? Please sign your portion of the Form B and return to me for filing. PS: I have made the date of appointment December 2010 instead of 2002 because of the statutory penalties for a late filing! CBK.” (I attach a copy of the original hand-written draft letter hereto and mark same as “EXH1”).
“The hand-written working notes of CBK Zwennes dated 12/04/2013 and outlining a 5-stage roadmap for restructuring the firm stating as follows: “Check 09/04/2013. New Partnership Deed. (1) Draft – pursuant to death earlier of Ed.B.G. and Saki S., leaving EBSHghs & CBKZ as old partners. (2) The ff were on …..agreed appointed to be partners by Ed.B.G., CBK & EBSH before the death and have carried on in said partnership to date. (3) Agreed now between the existing partners to reconstitute the partnership by approving additional terms of a new amended substituted Partnership Deed in the Schedule hereto signed by all the partners and agreed to be substituted for the existing old P Deed. (4)Now Therefore upon the signatures executed hereunto and to the Scheduled Deed attached the existing partners & new partners (parties) shall be and carry on the business of legal practitioners as previously carried out under the name and style of GZH&CO, etc. (5) The said Partnership Deed & the firm name shall be registered under the Registration of Business Names Act etc/or the I.P.P. Act (1962) (Act 152).” (I attach a copy of the handwritten roadmap for restructuring the firm hereto and mark same as “EXH2”).
The above show, he says shows that he and peter had been appointed as partners and were treated as such by all the earlier Partners immediately upon their appointment in 2002 and that a new partnership deed was in the making, hence one not having as yet been signed by the Plaintiff/Respondents.
Regarding the fact of the re-drafting of the new Deed of Partnership for the Firm the Partnership File of CBK Zwennes on which he kept all his correspondence with Defendant/Applicant and documents about the firm contains the following:
The handwritten draft copy of a letter written by CBK Zwennes to the Defendant/Applicant stating as follows: “E.B. Sakyi-Hughes, G.Z.H., Takoradi. Dear Sekyi, You may have heard that I have achieved the venerable status of an octogenarian by the grace and mercy of God. I did not get a card from you! How come? Anyway, I think the matter of the Partnership practice (GZH) in which you and I are the “oldest” subsisting partners should now be properly addressed. The 1963 Agreement needs to be reformed so that the practice can look confidently into the future as our legacy to legal practice in Ghana, by us as “founding fathers”. I have not been able to get a copy of the original Partnership Agreement either from my office in Accra, or from Takoradi after much search. Its terms of course need to be revised and amended and brought up to date to reflect the actual practice relationship adopted by the partners over the years, reflecting especially the near independence of each branch office. I will have to re-write a new partnership deed with your consent which I am now working on. Can you fax me your copy of the old Agreement if you can find it. Thanks. I am also forwarding to you belatedly the completed Statement of Change under S.7 (particulars of change) for your signature which I should have completed and filed in 2002 to reflect the new partners when appointed. Please expedite and thanks, it would be a special pleasure to see you in Accra. Regards to Betty. Kwesi Z.” (I attach a copy of the original hand-written draft letter hereto and mark same as “EXH3”).
A Note entered in his own handwriting on the inside jacket of the Partnership File of C.B.K. Zwennes dated 2011, in which he stated as follows: “Restructure of the Firm. NB. To propose to re-write a new P. Agreement and terms by consent of existing partners and substitute same for original Partnership Deed of 1963 which cannot be traced at the Registry. (sgd.) CBKZ, 2011.
Sekondi Office. Clerk – Mr Masoperh.” This would be a reference to the said same Masoperh, who at least was also aware that the original Partnership Deed could not be traced at the Registry. (I attach a copy of the original hand-written Note hereto and mark same as “EXH4”).
Also with respect to the Certificate of Incorporation of the firm Gaisie Zwennes Hughes & Co., another daughter of the Defendant/Applicant, who – (in her case) at least does not falsely hold herself out to the general public as a lawyer fit to practice – appears on the face of a Certificate of Incorporation dated 12th October 2016 as a partner of our firm.
The false certificate states: “Names of Partners: Antoinette Hughes, Charles Bartels Kwesi Zwennes, Ebenezer Begyina Sekyi Hughes”. That a Search at the Registrar General’s Department shows that the said Antoinette Hughes had once upon a time been presented for registration as a partner of the firm and has since been deleted as such. (I attach a copy of the said fraudulent Certificate of Incorporation hereto and mark same as “EXH7”).
To him, only the ex-Speaker and his daughters, Antoinette and Josey Hughes could be said to have hoped to benefit and to have hoped to gain from these perpetrated acts of forgery and fraud, which merit trial and investigation by this Honourable Court.
According to him, the instant suit brought by him and his cousin raises very serious allegations of forgery, and fraudulent misrepresentation against Mr Sekyi Hughes, which do not breach Order 11 Rule 18 of C.I. 47, but rather expose conduct deeply offensive to law, and which, they will easily establish well above and beyond the standard of proof required at the eventual trial and hearing of this lawsuit.
In this regard, the instant application is rather an abuse of process intended by the Mr Sekyi Hughes to serve the collateral purpose of shielding him from answering for his wrongful acts and preventing him from facing public opprobrium which will be his only inheritance as the outcome of the course of justice.
“..Ironically and laughably, the false allegations of dishonesty being levelled against me in paragraphs 14 and 15 by Theophilus Masorpeh relate to my written requests to the Registrar General’s Department to correct the false entries on her Register. My written requests to show also JL Zwennes as a partner up until her death in October 2020 and to show her as no longer being so thereafter upon advent of her death was purely motivated by my honesty and my genuine desire to have the public record corrected of its mistakes in order for it to accurately reflect the true state of affairs as regards ownership of the law firm to which I belong and co-own. My applications to the Office of the Registrar and the Head of Legal Department were made to the appropriate officers and officials in writing and only after it became clear to me that the Defendant/Applicant was playing a game of hide-and-seek to avoid facing 2nd Plaintiff and I to answer for his wrongful deeds”.
“…my letter which Defendant/Applicant has attached to his affidavit as “Exhibit 8.1” rather goes to show by a reference to its second paragraph that my application for correcting the record was following a process as guided by the Office of the Registrar, but who finally advised us to sue the Defendant instead, given his reprehensible, unenviable conduct”.
