THERESA AKOROBO KOFI VS CHARLES ADAMS OHEMENG

Introduction

Counsel for and on behalf of the Plaintiff took out the instant writ of summons on 19th July, 2017 against the Defendant.

However, proceedings in this matter went cold until the plaintiff on 22nd May, 2020 filed a notice of intention to proceed for the continuation of this matter.

Following the resurrection of the matter, Plaintiff amended his Writ of Summons and Statement of Claim.

Thus per an Amended statement of claim filed on 9th November, 2020 the plaintiff seeks the following reliefs against the Defendant: 1. Declaration of Title and Recovery of possession to ALL THAT PARCEL OF LAND situate lying and being at NYANYANO in the Central Region of the Republic of Ghana and bounded on the North by Lessor's Land measuring 2, 000 feet more or less on the East by Lessor's Land measuring 3, 090 feet more or less on the South by Lessor's Land measuring 2, 000 feet more or less on the West by Lessor's Land measuring 2, 810 feet more or less and containing an approximate area of 135. 45 Acres more or less as the same time is more particularly delineated on the Plan attached hereto and thereon shown edged Pink.

2. Perpetual injunction restraining the Defendant, his agents, assigns, representatives, workmen, heirs, successors, or any other persons claiming right or title through him howsoever described from entering upon or dealing in any manner with the said land.

3. Damages for Trespass.

4. General Damages 5. Cost Counter-Claim The Defendant on his part filed a Statement of Defence on 19th October, 2018, subsequently amended it and then filed a new defence on 20th January, 2021. This amended statement of defence did not however survive the tenure of this case and was finally amended on 18th November, 2022. Thus, per the Amended Statement of Defence filed on 18th November, 2022 the Defendant counter-claimed against the plaintiff as follows: 1. A declaration of title to the parcel of land described in paragraph 10 of the Statement of Defence.

2. Recovery of possession 3. Damages for trespass 4. Perpetual injunction restraining the Plaintiff, by herself, agents, servants, personal representatives, assigns, workmen, administrators, privies or however from dealing with or having anything to do with the Defendant’s land in dispute.

5. Cost, including solicitor’s legal fees.

Brief Case of the Plaintiff The case of the Plaintiff is expressed in a 10 paragraphed Amended Statement of Claim filed on 9th November, 2020. According to the Plaintiff