*Our Ref: BE/SC/LA/MTN/01/2026
20th OCTOBER, 2026
The Managing Director,
MTN Nigeria Communications PLC. MTN Plaza,
No.1 Awolowo Road, Falomo Roundabout,
Ikoyi,
Lagos State.
Dear Sir,
DEMAND FOR REPAIRS OF DAMAGED ROOFS, STOPPAGE OF HARD SUBSTANCES FALLING ON ROOFS AND COMPENSATION.
We act as solicitors to Pastor Sunday Enikuomehin (hereinafter referred to as “our client”) on whose instruction we address this letter to your office as a matter of urgent concern.
Our client is the owner and occupier of the property located at No.1 & 3, Maja Street, Eyita, Ikorodu, Lagos State. The property of our client has been in existence for more than 12 years before your company erected its mast sometime in 2010.
The telecommunication mast belonging to, operated and maintained by your company “MTN Nigeria Communication PLC.” has been causing structural damage to our client’s property.
The collapse/spilled debris of the equipment used in building the MTN mast on the roof of our client’s property has resulted in extensive and severe damages to our client’s property thereby leaving leakages on the roof whenever it rains.
This has been reported severally to your security agent who reliably informed our client that reports made to the appropriate authority of your company were ignored.
The negligence of your company in placing this hazardous mast very close to our client’s property has resulted in the monumental damages caused to our client’s property and the apprehension suffered on a daily basis from harms emanating from the debris of your mast. Your company has a duty of care to ensure that its mast structures are safely engineered, regularly inspected and properly maintained so as not to pose dangers to surrounding lives and properties. Your failure to prevent this destruction constitutes gross negligence and breach of duty.
The continuous droppings of the hard substances from your mast have portend dangers both to our client’s property and the inhabitant living therein. Your company has used her business interest to deprive and deny the owner of adjoining property the benefit and peace of mind needed in his land.
The activities of your company portend great danger to the safety of our client and his property. You are hereby requested to mitigate forthwith these horrendous dangers threatening the safety and peace of mind of our client.
TAKE NOTICE that the calamities emanating from this mast has indeed put our client and other inhabitants living in the property under great apprehension.
It is our demand that your company should with immediate effect put a stop to these dangers posed by your mast.
Our client has requested a token of ₦25,000,000 (Twenty-Five Million Naira) for the pain, anguish, apprehension, danger he has been subjected to over the years from the threat posed by the hazard of hard substances on his roof, the apprehension he suffers and the repairs needed for his property.
Further take notice that upon the failure, refusal, and neglect of your company to do the needful within the time limit of 14 (FOURTEEN DAYS) of the receipt of this letter, we shall, without any further correspondence to you, proceed to the law court to seek redress against your company and the consequences of this will be that our client will escalate this matter to appropriate regulatory agency that supervises your organisation,
The choice is yours to treat this letter with a hand of levity at your company’s peril.
Yours faithfully,
For: Benson Enikuomehin & Co.
Amenawon Addo Esq.
Head of Chambers (Admin.)
