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Here is Toke Makinwa’s complete divorce petition

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The divorce petition of Toke Makinwa, adored on air personality, socialite and fashionista against her husband of a few months ( Maje Ayida) is now in public domain.

But here is the complete petition…

In the High Court of Lagos State in the Judicial Division Holden at Lagos.




OMOTOKE MAKINWA                           Petitioner




  2. MISS ANITA SOLOMON        Respondents






1TAKE NOTICE that a petition has been presented in the above named Court by OMOTOKE MAKINWA c/o.  her Solicitors, Messrs, Adepetun, Caxton-Martins, Agbor & Segun of St. Nicholas Building (9th Floor), Catholic Mission Street, Lagos Island, Lagos instituting proceedings for a decree of dissolution of marriage on the facts specified in paragraph 1 of the said petition.


  1. A sealed copy of the said petition is delivered to you with this notice.


  1. If you intend to consult a Solicitor in connection with the proceedings, you should take to him all the documents delivered to you.


  1. The form of acknowledgment of service to you with this notice should be completed and signed by you and either you or your solicitor should immediately return it to the Petitioner’s solicitor. A stamped and addressed envelope is delivered to you for that purpose.


  1. If you desire:


  1. To deny any facts alleged in the Petition
  2. To allege any additional facts for the consideration of the Court
  3. To submit to the court that it should dismiss any of the proceedings instituted by the Petitioner, or
  4. To make any other submission to the Court, you should file an answer to the petition


  1. If you wish to institute proceedings for the dissolution of the marriage, judicial separation or restitution of conjgual rights, you may do so in an answer to the petition filed by you. If you committed adultery, you may also, by the answer institute proceedings for damagess in respect of adultery.


  1. If you wish to institute proceedings for the purpose of seeking an order with respect of maintenance of yourself, a settlement, the custody or guardianship of the children of the marriage or maintenance, welfare, advancement of 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 Court to institute the proceedings.


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


  1. Any answer or notice of address for the service filed by you must be filed within 28 (twenty eight) days after you receive the notice or within such extended periods as the Petitioner or the Court allows and service of a copy of the answer or notice must be affected in according with the Matrimonial Causes Rules.


Dated this 9th day of March 2016.




In the High Court of Lagos State in the Judicial Division Holden at Lagos.



OMOTOKE MAKINWA                           Petitioner




  2. MISS ANITA SOLOMON        Respondents




To the above named High Court


THE PETITIONER whose address is:


1, Lagos Nigerian Citizen, and whose occupation is a radio presenter and On Air Personality humbly petitions this Honourable Court for a decree of dissolution of marriage against the 1st Respondent, whose address is


Lagos, Lagos State, and who is a Nigerian Citizen, Chief Executive Officer, on te ground that the marriage has broken down irretrievably based on the following facts supporting the ground.


  1. Adultery by the 1st Respondent which the Petition finds intolerable
  2. Cruelty
  3. Irreconcilable differences




  1. The Petitioner is within the meaning of the Matrimonial Causes Act domiciled in Nigeria.


The facts upon which the Court will be asked to find that the Petitioner is so domiciled are as follows:


That the Petitioner is a Nigerian, of Nigerian parentage and married to a Nigerian. The Petitioner has remained resident in Nigeria since her birth.




  1. The Petitioner and the 1st Respondent lived together from 15th January 2014 to 8th November 2015 at


1, Lagos, Lagos State.


  1. That cohabitation between the Petitioner and the Respondent ceased on Sunday, 8th November 2015 when the Petitioner left their matrimonial home at 18 …………………………

Lagos, Lagos state as she could no longer tolerate the continuous adulterous acts of the 1st Respondent with the 2nd Respondent despite repeated promises by the 1st Respondent to changeover a new leaf.




  1. The Petitioner and the 1st Respondent do not have any children together.




Since the Marriage, there has been no previous proceedings in Court between the Petitioner and the 1st Respondent


The petition of on air personality and socialite Toke Makinwa seeking the dissolution of her marriage from Maje Ayida is predicated on 11 reasons.

Here are the reasons cited :

The facts relied on by the Petitioner are constituting on the grounds specified above are as follows:

i. Since the celebration of the marriage on 19th January 2014, the 1st Respondent has consistently and continually indulged in sexual and adulterous relationship with the 2nd Respondent in their matrimonial home when the Petitioner is away at work and outside the matrimonial home when the Petitioner is around.

ii. Further to (i) above, the 2nd Respondent delivered a baby boy to the 1st Respondent sometime in July 2015. The child was born in the United Kingdom amidst spurious claims by the 1st Respondent that he does not have money to pay the bills in the house and/or take care of the Petitioner. The 1st Respondent claimed to have invested into building a business and given this assurances, the Petitioner didn’t ask him for upkeep under that notion. Unbeknownst to the Petitioner, the 1st Respondent was diverting funds to the 2nd Respondent for her upkeep and for her travel expenses to the UK to have the 1st Respondent’s baby. The Petitioner saw several text messages and Bank alerts to this effect. The 1st Respondent didn’t pay the rent on account of lack of funds and by reason of this, the landlord came on two occasions to embarrass the Petitioner.

iii. Following the birth of the child, the 1st Respondent became physically and emotionally tied with the 2nd Respondent to the annoyance and frustration of the Petition.

iv. Prior to the scandal which is now public knowledge, the Petition was meant to sign an endorsement deal with ……………Limited (one of the telecommunication giant in Nigeria) worth N20,000,000.00 (Twenty Million Naira). However, following the widespread negative media publicity of the Petitioner’s marriage predicated on the 1stRespondent’s adultery with the 2ndRespondent and the birth of a child, ……withdrew from the endorsement deal which withdrawal negatively impacted on the Petitioner as she has expended a lot of time and finances leading to the failed deal.

v. That in spite of the above, the Petitioner preserved in the marriage with the 1stRespondent sincerely believing that things will get better. However, the situation got worse as the 1stRespondent continued his adulterous acts and boasted on several occasions that he wished to have been married to someone else. The 1st Respondent continued to call and text the 2nd Respondent at questionable times of the night to spite the Petitioner.

vi. That due to the 1stRespondent’s apparent lack of love and affection to the Petitioner, it has never been a concern to the 1stRespondent if the Petition is in a good state of health. Living with the 1stRespondent became disconsolate and terrifying making the home most uncomfortable and unconducive.

vii. The 1st Respondent took pride in doing whatever he desires and when he desires it with no consultation with or regards to the Petitioner’s feelings. On countless occasion, the 1st Respondent discussed his business dealings and takes advises from the 2ndRespondent. The Petitioner was never consulted and was continually treated with disdain. The Petitioner continued to forebear.

viii. The above notwithstanding, the slightest complaint by the Petitioner of some of the attitude of the 1st Respondent would generate serious verbal nagging, the use of vulgar abuses by the 1st Respondent in the clear view of the domestic staff, church members and neighbours and menacing the estimation of the petitioner in the minds of family, friends and members of the public given the peculiar nature of the Petitioner’s job and has thus created an unpleasant environment for the Petitioner. The 1st Respondent has repeatedly sent text messages and phones calls to the 2nd Respondent inviting her to live with him.

ix. Sometime in December 2014 and when several entreaties from the  Petitioner had failed, in order to exploit other means of saving her marriage the Petitioner invited some of her family members and in-laws in order to seek a resolution of the matter. Rather, than yield  to the Petitioner’s plight, the 1stRespondent continued his adulterous relationship with 2ndRespondent, became more resolute in embarrassing and disrespecting, the Petitioner such that verbal abuse/nagging to the knowledge of all the people living in the neighborhood from the 1st Respondent became a routine affair. The Petitioner further tried to persevere and bore all the insults, emotional and psychological abuse of the 1st Respondent from December 2014 to 8th November 2015 when she could no longer tolerate same and was thus forced to leave her matrimonial home. The 2nd Respondent  presently lives with the 1st Respondent in their matrimonial home.

x. The adultery and irreconcilable differences have caused the irretrievable breakdown of the marriage between the Petitioner and the 1stRespondent, efforts at further reconciliation have failed and future attempts at reconciliation would be impracticable and not in the best interests of the Petitioner.

xi. That from the foregoing, the 1stRespondent has behaved in such a way that the Petitioner cannot reasonably be expected to live together with him.



The Petitioner has not condoned or connived with the 1st Respondent in any of the grounds specified above and is not guilty of collusion in presenting this petition.



  1. The Petitioner seeks the following reliefs.


  1. A decree of dissolution of marriage between the Petitioner and the 1st Respondent on the grounds

a. That the marriage has broken down irretrievably.

b. The 1st Respondent has committed adultery with the 2nd Respondent and the Petitioner can no longer tolerate the 1st Respondent’s adultery.

c. That since the marriage,, the 1st Respondent has behaved in such a way that the Petitioner cannot reasonably be expected to continue to live with the 1st Respondent

d. Such further or other reliefs that this Honourable Court may deem fit to make in the circumstance.


THIS PETITION was settled by Olushola Abioloye, FCIArb, Legal Practitioner to the Petitioner

FILED on the 9th day of March 2016.


By Olusola Abiloye, Legal Practitioner, on behalf of the Petitioner whose address for service is Adepetun, Caxton-Martins, Agbor & Segun, St. Nicholas House (9th Floor), Catholic Mission Street, Lagos Island, Lagos.


Olusola Abiloye, FCIArb,

Petitioner’s Counsel


For Service on the:

  1. 1st Respondent

Mr. Maje Amaju Ayida


  1. 2nd Respondent

Miss Anita Solomon


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  • Peterson Ade

    na so