We have been consulted and our services retained by SYSTEMS IMPROVEMENT LIMITED, a health improvement and patients’ safety advocacy company duly incorporated in Nigeria with RC 1639943.

The company is at the forefront of protecting the interest and welfare of patients in Nigeria and acts in a representative capacity on behalf of other victims of the Covid-19 pandemic in Nigeria.

It is our instruction to jointly and severally demand the sum of $2 Trillion US dollars only, being compensation for damages suffered by Nigerian victims of the Covid-19 pandemic caused by the officials, representatives and agents of the Chinese Government. Those entities include the Chinese Communist Party, Wuhan Municipality Authority, The Wuhan Municipal Health Commission, Wuhan Public Security Bureau, The Wuhan Institute of Virology and Dr Yanyi Wang.

You may recall that on December 1,2019, the first known patient was identified with symptoms of ”pneumonia like illness” in Wuhan China. He was allegedly exposed to the virus at Wuhan Seafood Market. Five days after, his 53- year-old wife who had no exposure to the market was also hospitalised with the same symptoms.

This was followed by an influx of patients showing up in hospitals in Wuhan presenting the same ”pneumonia like symptoms”.
On December 25, 2019, Chinese medical staff in two hospitals in Wuhan, presented similar symptoms and were quarantined. At this time, the authorities knew or ought to have known that not only was there a viral outbreak but that there was human-to-human transmission.
Dr Li Wenliang who worked at a hospital in Wuhan was alarmed by the development and dutifully tried to warn other doctors about the outbreak of an illness similar to ”Severe Acute Respiratory Syndrome”,( SARS). He was convinced that there was human-to-human transmission. He therefore urged his colleagues to take protective measures against the infection.

However, disregarding the glaring evidence, on December 31,2019, the Wuhan Municipal Health Commission falsely declared that their investigation has not found any evidence of human-to-human transmission.

Consequent upon this false declaration, Doctor Li Wenliang was summoned by the Wuhan Public Security Bureau and accused of ”spreading rumours about a deadly virus”, and on January 3, 2020, Dr Li Wengliang was compelled (at the pains of severe sanctions) to sign a statement at a police station acknowledging his ”mistake”/ ”misdemeanour” and promising not to commit further unlawful acts meaning that he would no longer issue the life-saving warning to his colleagues or use Personal Protective Equipment, (PPE) while treating infected patients. The Chinese authorities in their desperation to deceive the world, forced the doctor to more or less commit suicide.

Predictably, Dr Wenliang contracted the disease from a patient and died from the complications. In the face of the volatile outrage that greeted his death from both International and domestic entities, the Chinese government reluctantly acknowledged their culpability in his death and apologised to his family.

However, in defiance of International Health Protocols, Wuhan Municipal Health Commission released another misleading statement denying the outbreak.

It was not until January 7, 2020 that they finally acknowledged the existence of a viral infection christened Covid-19, to the World Health Organization.

By this time, a good 36 days had passed and 59 people had been infected.
Even at this critical point, the Chinese medical authorities were not done with their deceit.

They continued to misinform the public and the international community, claiming that there was no evidence of human-to-human transmission meaning that people had no need to take precautions from making physical contact with infected patients. To perpetuate this deception, on January 8,2020, they issued a statement insisting that there was no clear evidence of human-to-human transmission.

Again, on January 11,2020, the Wuhan Municipal Health Commission issued a statement claiming that most of the victims had direct contact with animals at the Wuhan seafood market and their infection was not as a result of human-to-human transmission.

By this time, the virus had spread so widely that on January 13,2020 the first case was reported outside China. A 61 year-old woman had contacted the virus in Wuhan, China and carried it to Thailand. The Thailand Health Ministry confirmed that the woman had not visited the Wuhan Sea Market and came down with fever as early as January 5, 2020. This was a clear evidence that the virus was being transmitted from human to human.

In spite of this and inexplicably, on January 14, 2020, the World Health Organization in its report stated; ”Preliminary investigations conducted by the Chinese authorities have found no clear evidence of human to human transmission of the Novel Corona virus”.

The Wuhan Municipal Health Commission would later admit the possibility of a ”limited human-to human transmission”. However this did not stop them from allowing 50,000 families to gather in Wuhan to share home-cooked food in a Lunar New Year banquet. This wilful and wicked disregard for the safety and welfare of human life, finally buried any possibility of containment.

In January22, 2020, the World Health Organization on a field visit to Wuhan, concluded that there was human-to- human transmission. WHO however, heavily relying on information presented to it by the Chinese authorities, stated that it did not constitute a public emergency of International concern.

It was only on January 23, 2020,a good 2 months after the first case was reported and after weeks of suppressing the true nature of the virus, that the Chinese government finally announced a quarantine for Wuhan. By that time comprehensive contact tracing and containment was impossible as tens of thousands of asymptomatic patients must have spread the virus extensively across the globe including to Italy through Italians that visited Wuhan, from where eventually it got to Nigeria through an Italian who arrived on February 25, 2020, fell ill on February 26, 2020 and was confirmed with the virus on February 27, 2020.

As of April 5, 2020, there are 232 confirmed cases in Nigeria with 5 deaths. The country is on a total lockdown and the economy is haemorrhaging. Companies are losing billions of dollars on a daily basis. The price of Crude Oil has collapsed and Nigeria as a major oil producer is losing millions of dollars daily. Tens of millions of Nigerian citizens have lost their source of livelihood and families are starving. Nigerians are also experiencing immense psychological trauma due to the fear of contracting the virus or losing their loved ones to the deadly disease.

All that pain, suffering, loss and deaths have been caused by the direct, wilful and wanton act of the Chinese authorities and her proxies.

The Chinese government breached their duty of care to the world and to Nigeria in particular by;

(a) Suppressing the information that there was a dangerous viral outbreak in Wuhan, China that posed a present an imminent danger to the world at large and to Nigeria in particular.

(b) Preventing by intimidation, threats and cohesion, professionals including doctors, lawyers and journalists that wanted to issue an early and timely warning to the world.

(c) Misinforming the world of the true nature of the virus, to wit; that it could be transmitted from human to human even after they knew or ought to know of this development.

(d) Deceived the world in general and Nigeria in particular through their representation, which representation Nigeria relied on to conclude that Covid -19 did not pose any danger to Nigeria and Nigerians.

The wilful acts of the Chinese government caused extensive injury, death, pain and loss to Nigerian victims, hence this demand.

The said Nigerian victims, legally entitled to be compensated by the Chinese authorities, include but are not limited to;

  • The families and estate of all the dead victims of Covid-19.
  • All infected victims of Covid-19 including members of the Federal cabinet, Governors, Captains of Industries and distinguished citizens for the excruciating pain, suffering and loss inflicted on them by the sickness.

*The Federal Government and her Agencies including the Nigerian National Petroleum Corporation (NNPC ) for loss of revenue from the drop in the price of Crude Oil amounting to hundreds of millions of US dollars.

  • State and local governments for loss from extra budgetary expenditure and palliative interventions specifically in Lagos State, Oyo state, Rivers state, Kaduna state, Delta state, Borno state, Abia state, Akwa Ibom state, etc.
  • Nigerian citizens for loss of revenue including;
    -Traders, Artisans, Daily-pay workers, Market women, Tailors, Farmers, etc.

-Self employed Professionals like Lawyers, Engineers, Accountants, Architects, etc.

-Health care professionals like Doctors, Nurses, Medical laboratory scientists, etc.

-Self employed entrepreneurs running small scale businesses that have been forced to close shop and whose businesses may never recover from the recession induced by the shutdown.

-Professionals whose companies have been negatively impacted and may be laid-off including Journalists, bankers, Airline workers, etc.

-Hospitals, Clinics and other medical facilities for the loss incurred from extra expenditure in precautionary and preventative measures as well as loss of patients discouraged by the pandemic.

Nursery schools, Primary schools, Secondary schools and Tertiary Institutions and their students forced to lose valuable study time.

  • Companies and Corporations:

-Airline operators including; Air Peace, Aero Contractors, Azman Air, Allied Air, Med-view Airline, Overland Airways, etc, for loss of revenue from cancelled flights.

-Banks and other financial institutions including, UBA, First bank, Zenith Bank, GTB, Mortgage banks, Community banks, etc, for loss of revenue from massive withdrawals of funds, lost interests in investments and lost transactional charges.

-Land transport operators for loss of revenue from passengers including; ABC Transport, The Young Shall Grow Transport, Peace Mass Transport, God is Good Transport, etc.

-Manufactures that have shut down their factories.

-Nigerian citizens that suffered psychological trauma due to the heightened expectation of death.

Please, take notice that if within 14 days of the receipt of this letter, the sum of $2 Trillion US dollars, is not paid to victims of Covid-19 in Nigeria, we shall resort to the outstanding instructions of our Clients, to wit;

  1. Launch a mass campaign for the boycott of Chinese goods and services in Nigeria including filing a petition with the Nigerian Communications Commission, NCC, demanding that the process of licensing Hauwei Technologies Co., Ltd (a Chinese owned company) to roll out the 5G technology, be discontinued in Nigeria, until our demands are meet.
  2. File a complaint against the Chinese authorities and her proxies at the United Nations Human Rights Council, Geneva, Switzerland or any other court of competent jurisdiction.

Thank you for your anticipated cooperation.
Best regards,

Agu Obasi Esq
Director, International Medical Law Centre,
Solicitor and Advocate, Supreme Court of Nigeria.
For and on behalf of Covid-19 Victims in Nigeria.

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