BETWEEN: EBRIMA SOLO SANDENG AND INSPECTOR GENERAL OF
POLICE NATIONAL INTELLIGENCE AGENCY (N.l.A) COMMISSIONER OF PRISONS THE
ATTORNEY GENERAL IN THE MATTER OF EBRIMA SOLO SANDENG AND IN THE MATTER OF AN
APPLICATION FOR A WRIT OF...
- I am the
deponent herein and I swear to this affidavit in support of the summons
for the issue of a writ of Habeas corpus ad subjiciendum in respect of
Ebrima Solo Sandeng’
- The facts
deposed in this affidavit are matters within my own knowledge
- On the
14th day of April, 2016,”l decided to travel to Banjul to get some
medication for my mother who suffers from diabetes and hypertension’
- I took a
taxi and got down at Westfield junction to get another taxi van to Banjul
when I saw a group of people by the said junction one of whom I recognized
as Ebrima Solo Sandeng. I asked him what was happening and he told me that
they were requesting for certain changes to be done and I further asked
whether they were doing so in the street and he answered, yes, I then
bought a bottle of water nearby and asked a young boy to get me a seat in
one of the taxi’s to Banjul’
- As waited,
some Police lntervention Unit (PlU) officers came and hit me on my back
saying to me that I was running away. When I was about to explain to them
why I was there, one of the PIU officers whom I can identify facially
started beating me. He then asked me to climb into a truck that was
nearby. I asked him “what have I done to climb onto the truck’ I cannot
climb.” I was then carried into the truck by some PIU officers and taken
amongst others to the PIU Headquarters in Kanifing.
- I, amongst
others were brought down from the truck and taken into a room. I was the
first to be called out of the room and put in handcuffs. I was then taken
directly to the National Intelligence Agency (NIA) Headquarters. I was
taken to the NIA Headquarters in a double cabin pick up together with one
Modou Ngum in the company of two PIU officers’ Upon arrival at the NlA, 2
other pickups followed. One of the pick-up vehicles had Ebrima Solo
Sandeng alone. The third pick up transported Ebrima Jabang and Kafu Bayo.
- We were
all in Handcuffs. Photographs were then taken of us at the said headquarters.
Thereafter I was asked in the wollof language by a man unknown to me but
who was being called by the name James at the NIA Headquarters; “What
Political Party do you support?” I then answered “That is not what I am
here for. You should be asking me my name, where I am from and what has
brought me here.” The said man then asked me “What brought you here” and I
said to him “l do not know”‘ He then said to me “You do not know it now
but by the time we are ready with you, you will know.”
- He then
took me into a room and a lady was called in and I was asked to remove my
clothes for her to examine me. I then asked what they are looking for by
which time some other NIA officers including James were also in the said
room. One of them then said that they were looking for the things I was
carrying at the Westfield junction and I said to them I was 6. carrying
nothing except my money which dropped when I was being put into the truck.
- I lifted
up my top clothing except my wrapper and a body search was carried out on
me by the said lady who was earlier called. I was then asked whether I had
any charms on me. I answered in the affirmative. I started to remove them
when James asked the lady to use a knife to cut them off me’ When the lady
cut the charms, I was asked to remove my earrings and taken into another
room and then another. ln the 3to room I was taken to, I found two men and
a woman there. They asked me my name and where I was from. I was then
asked whether I was a supporter of the APRC or the UDP. I told them that I
was not there for that. A well-built fair coloured man came into the room
and said to me “Here, you either say something clear or we will show you
that we have drunk more pepper than you'” While he said this he placed his
finger on the top side of his head as a gesture.
- 1 was then
asked what I know about the issue at hand and I said “l know nothing about
it.” The fair coloured man came back into the room and again repeated his
earlier statement. He left and then returned with the said James and James
asked me to follow him which I did and on the way we met a young man who
was asked to take me with him.
11.1 followed the young man and we got to a white
storey building and there I saw some people in a room downstairs. The young man
then said to them, she is here”. When I looked at them they were fully clothed
in black wearing black hoods and gloves. All I could see were their eyes. I
became very much afraid and as soon as I shouted they surrounded me and grabbed
me, put a rope around one of my legs and pulled the same tight as a result of
which I fell down. I resisted and struggled with them to avoid my other foot
being tied and that was when the mask on one of the men came off.
- 1 held
onto a NIA officer named Sheikh Omar Jeng alias sir Jeng who was present
and asked him to help me so that I won’t get killed and he said to them
“leave her alone, I will bring her, you go.” They then left me and waited
aside while I sat down at the bottom of the stairs of the said storey
building holding onto Sheikh Omar Jeng asking him to help me so that they
won’t kill me. He then pulled me up and walked away with me when the said
men in mask started shouting out that they will not take this nonsense
from Sheikh Omar Jeng and that he should allow them to take me’ One of
them then took hold of my middle left finger and bent it until it broke’
My finger is still swollen and I have not been given any medical treatment
for it’ one of them then said to me “will you go or not” and I said “Yes
but I am afraid of you”. Another one said “Don’t waste time because a lot
more are coming,,.That was when they jumped on top of me and tried to
remove my clothes and when I resisted they pulled my clothing and tore it
removing same from my body. I was left naked except for a short wrapper I
wore underneath my clothing’
- They then
took me to a building containing rooms and l sat on the ground by the said
building. I was asked to enter into one of the rooms and then one of them
said to me “Here you will cry until your mouth tears up and no one will
hear you”.
14.1 got into the room and found three men inside
again fully clothed in black with black hoods and gloves. They asked me to lie
down on a table and when I did they started beating me continuously like an
animal for long time. Probably for about an hour, however l can’t tell what
time it was’ My whole body was damaged and bleeding. Suddenly I heard some
people in the next room shouting the word “Excuse”. An adjoining door was then
opened and l was pushed into the next room. ln there I saw more than 10 men in
plain clothes including James and from there I was moved to the next room again
through an adjoining door’
- In that
room, I found some elderly men sitting around on benches. They asked me
what my name was and where I was from and I told them’ They then asked me
what political party I support and I replied again that I wasn’t brought
here for that. They then said that they need to know and that was when I
told them that I am an opposition supporter. They asked me which of the
political parties and I said “UDP”‘ The old men then said that they want
me to come over to their own party and l asked them which party. They then
said “Yaya Jammeh’s party.” I then said to them “so you are members of
Yaya Jammeh’s party” and they answered “yes”‘ I then said to them “you
beat me mercilessly and now you want me to join your party”. One of them
who was black in colour then said to me “Do you see us with whips, we did
not beat you”. I then said to them; “You know who beat me and where the
beating came from. You gave the orders for me to be beaten”. .
- The old
man then asked me to follow James out of the room and while leaving the
room the old men who sat on the benches began hitting my back side asking
me whether I had beads around my waist and I told them to ask their wives.
James and the old man took me to a small cell which had been urinated in
as I could smell the stench coming from the cell’ They called a young man
short in height and asked him to open the cell which was locked with a
key. The cell opened and I was pushed in and asked to sit by the men
inside. There I found Modou Ngum, Kafu Bayo and Ebrima Jabang. I was the
first person who was beaten’
- We sat
there for about 5 minutes and then they brought in Ebrima solo sandeng.
They had already beaten him. His body was all swollen and he was in severe
pain. I then asked him to come closer to me away from the urinated area
and as he laid flat on the ground I bent down and started to massage his
head and body. His body was bleeding all over’ He then started to sleep
and I sat up’
- A few
minutes later, barely five minutes, the cell was opened and someone called
out at Solo. He woke up and answered’ He was then asked to come out of the
cell which he did and was taken away and a few moments later I heard and recognized
the voice of Solo screaming
- Three men
including James came back to the cell and called me out and asked me to
come out which I did. A fourth man, very tough and tall who had a scarf
tied around his head then asked to take me away’ In fact he was the one
who collected Solo from the cell. He attempted to tie my eyes and I
resisted telling him that it was night time and so he should not tie my
eyes. He then said to me that he did not want me to know where they were
taking me to and I said to him there is no need to tie my eyes because
those he is taking me to I can see them standing over there
- As we
walked away from the cell I saw a table in an open area surrounded by
seven men three of whom were fully clothed in black wearing hoods and
gloves. The said tough guy who was taking me then stopped and said to them
in Mandinka that he had brought them an onion and they responded that he
should put me on the table so that they can break the onion in two’ I then
said to them that I was not an onion but a human being like them and an
age mate of their mothers. They ask me to lie down on the table but I
refused.
- I then saw
Solo lying on the Bahama grass next to the table flat on the ground badly
beaten and bleeding profusely. I then shouted the name of God and called
out to Solo. In fact at that moment I thought he was dead’ He did not
respond to my call. I then saw his head moving from one side to the other.
22. They then started beating me with hose pipes and
batons while pouring water over me. I was still wearing my short wrapper then
and even when I fell they continued beating me and ask why I was mentioning God
there’ I again called out to solo but he did not respond. He was completely
naked just the way his mother gave birth to him. They continued beating me and
when the water got finished they brought some more. The beating continued until
early hours of the morning of 15th April, 2016. During intervals of beatings
they would ask me why am I supporting the opposition and when I answer they
would use both their hands to slap me on both my ears simultaneously.
- After the
beating I could not get myself off the ground’ The people who beat me were
fully clothed in black and were behaving and jumping around like monkeys
and from the stench coming from them I believe they were highly drugged.
Two men on either side of me carried me and then one of those in full
black clothing with a hood on and gloves asked them to leave me and as
they did I fell down to the ground. During this time they had picked solo
up and carried him behind the building and l could hear him moaning while
they resumed beating him. I tried to get up when the said guy in the hood
slapped me again simultaneously on both my ears’ Then the old man who had
accompanied James to get me from the cell said to the guy in the hood
“Leave her alone, don’t kill her” and he shouted back “leave me, this is
my job”. A dispute then arose between them and the others began to
mediate. The same men who earlier helped me again helped me up and carried
me. They took me to an open room like a parlour where I found Fatoumata
Jawara and Fatou Camara. I then asked them whether they were also brought
to the said parlour and they said yes after they had been beaten. This
happened on Friday the 15th day of April, 2016. Later that day three sheep
were brought into the said headquarters and given to these men. They
slaughtered the sheep and had a barbecue rejoicing in celebration I
believe of what they had done to us’
- The
following day they brought us sponge mattresses to lie on. A while later
Fatoumata Jawara fainted and Fatou Camara was having problems breathing. I
then pulled them towards me and started crying and asked them to be brave.
There was a young man at the gate close to where we were.
- The young
man then called Sir Jeng to tell him that we were not feeling well and sir
Jeng in turn called one Dr. Sanyang who came to check us after which he
told sir Jeng in our presence that I had High Blood Pressure and Diabetes
while Fatou Camara had breathing problems and Fatoumatta Jawara also had a
medical problem. The said Doctor went on to tell sir Jeng that if we are
touched again and anything happens to us they will be responsible. At the
time all the three of us could not even walk.
- Sheikh
Omar Jeng (Sir Jeng) with the help of others then took us to the NIA
clinic within the headquarters and locked us up in there’ The doctor
prescribed some medication for us and cream to heal our wounds’ They
started giving us medication as well as massaging us with hot water with
the help of four women who in two’s took it in turns morning and evening
to guard us in the said hospital. On this day the NIA officers were given
a cow to cook and enjoy themselves. Benachin was cooked and a bowl was
sent to us but we refused to eat the food.
27. After a week we were given clothing by sir Jeng to
wear which are now wearing because they had torn all our clothing’ He said to
us that he has a lot of sympathy for all of us. He further stated that he was
in charge of the NIA but the instructions to torture us came from above and as
such he could not do anything about it. I then said to him “You are the boss
here and people were brought into your house to torture us, yet you say you are
the boss. What you are saying is very interesting’ lf this is so then you are
useless here.”
28.Thereafter we were being taken care of and they
started treating us nicely like a child you beat and then give him or her
sweets or biscuits to coax to a point that I told sir Jeng that all these nice
things he was doing with the aim of pleasing us was immaterial’
- After
remaining in the clinic for more than a week we were moved to a cell at
NIA and thereafter taken to Mile 2 central prisons and brought to court on
the 4th day
of May, 2o16. Ebrima Solo Sandeng was however not brought to court.
30.1 make the above statement to the best of my
knowledge information and belief.
SWORN BY THE SAID NOGOI NJIE
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