To Set aside the Primaries conducted by the Peoples Democratic Party in Anambra State preparatory to the 2011 Elections in the State

1. The Primaries held by the Peoples Democratic Party in Anambra State preparatory to the 2011 Elections are incurable bad and cannot stand.

2. First there were two sets of Congresses and primaries conducted by two separate factions of the Party in different locations on the same dates.

3. For purposes of clarity the two factions will be referred to as the Senatorr Waku faction and the Benji Udeozor Faction.

4. The Senator Waku faction held its Congress conducted by a Committee appointed by the national Working Committee of the Party on ...............

5. Contrary to the provisions of Section 87.7 of the Electoral Act, requiring the Party to select three man delegates who will in combination with the existing Ward Executives comprise the body of 20 delegates to conduct the Primaries, this faction of the Party selected only three delegates from every ward to constitute the delegates to conduct the Primaries.

6. The Waku faction conducted its Primaries under the supervision of Senator Waku on .........2011 only the three - man delegates selected candidates for the elections;

7. the Benji Udeozor faction on the other hand conducted its Congress on...... without the benefit of supervision by a Congress Committee appointed by the National Working Committee of the Party.

8. The Benji Udeozor faction selected the three -man delegates to work with the existing 17-man ward executives to conduct the Primaries as required by the Electoral Act.

9. The Benji Udeozor faction held its Primaries on............ at Awkuzu, a venue which is not the Senatorial district headquarters and without benefit of supervision by a Primaries Committee deputed by the national Working Committee of the Party.