C027/001/18 TBA 2/5/2018


The Director of Criminal Investigations,

Mazingira Hse, Kiambu Road,

Opp. Forestry Department Headquarters, Karura,

P.O Box 30036-00100



Dear Sir/Madam,




The hereinabove subject matter refers.

We wish to unequivocally and with a lot of apprehension lodge a formal complaint on behalf of our client Mr. Cyprian Nyakundi regarding the unconstitutional, illegal and discriminatory processes disguised as procedures that he has always been overly subjected to with impunity.

It is with profound respect to both the Constitutional and institutional offices as a law-abiding Kenyan citizen that our client hereby presents this complaint. He has received very unfortunate threats, both intended and actualized in various aspects including but not limited to denial of personal liberty, dehumanization, damage to property and harassment and intimidation both to his family and himself.

Our Client has been treated with contempt and as a third rate citizen with total disregard to constitutional provisions including but not limited to violations of Articles 19, 20, 21, 22, 25, 27, 28, 29, 33, 34, 35, 36, 39, 40, 47, 48, 49, 50, 51 and 238.

Our client is deeply perturbed by the actions of your officers who are accustomed to harassing, detaining and intimidating our client. That these unconstitutional means incessantly used by your officers with great abandon had to make our client fear for his precious life from the individuals who should be taking care of security.

In my legal capacity as the Complainant’s legal counsel, such untoward actions complained of are retrogressive, driven by malicious intents and should be shunned forthwith in line with and in respect of a proper constitutional order besides a functioning judicial system. My client has faced a barrage of criminal charges which are in real sense disguised as such but out rightly further all discernible aspects of public ridicule, mental anguish and torture.

In particularity and with a much precision, the complaint and on my account as his legal counsel having analyzed the actions meted out on him, we wish to bring the following to your attention:-

  1. That Mr. Nyalundi did honour summons to appear at your offices on Kiambu Road on the 25th April 2018 only to face a host of charges. Besides, he was then detained until the following day for a court appearance.


  1. We take great exception to the occurrences of the said 25th of April 2018. Our client was summoned to appear at 0900hrs to which he was at the said offices by 0830hrs only to be informed that the summoning officer was in Court and that he should wait for him.


  1. The summoning officer arrived a few minutes past midday but rather than being taken through the purposes of the summons, the officers held several short-stint meetings which appeared to be delaying tactics and intimidation tactics to wit.


  1. Our client was finally taken through the normal procedures that mimicked a plea taking process in a judicial court at around 1530hrs or thereabouts. This was then followed by another meeting by the officers as our client remained isolated and holed up in a different room while an officer kept watch.


  1. The officers then informed our client that he could not therefore be taken court for plea taking at around 1645hrs as it was late in total disregard to the fact that our client honoured summons out of his own volition and conscience and appeared at your offices as early as 0830hrs.


That in view of the forgoing, it is our client’s position that:-


  1. Your office has taken a witch hunt route against him and that he now feels targeted as your officers’ actions in all intents and purposes point to the actualization of a well-choreographed strategy.

  1. That your office and other security organs have always shown a condescending attitude towards our client and with unmatched superciliousness, they often charge him with cases that are civil in nature but disguised as criminal charges.


  1. That our client now feels unsafe and therefore informs your high esteemed office that should something happen to him, you should be the first individuals to be held accountable.


  1. That your office is now the face of impunity and that you are being misused to settle personal scores as you have always arrested him since the year 2015 whereas no single case has ever been finalized.


  1. That the department of Cyber Crime under your auspices is ostensibly being used to bully our client and to unconstitutionally ostracize, incarcerate, detain, harass and intimidate him.


  1. That our client’s rights have been constantly violated and in a calculated move to subject him to public odium in furtherance of settling personal scores after receipt of bribes by the Cyber Crime department officers from the alleged complainants.


  1. That our client lost his phones in the hands of your officers and despite numerous attempts recover the same, his attempts have been futile and majorly frustrated by the same persons in total disregard to his constitutional rights.


  1. That our client’s relatives have not been spared either as your officers have habitually harassed, assaulted and subjected them to inhuman treatment and torture without a legal justification.


In furtherance to the hereinabove unconstitutional and illegal acts carried out by your officers covertly and overtly, our client prays for the following from your esteemed constitutional office as per the Principles of National Security outlined under Articles 238 and 239 of the Kenyan Constitution:-

  1. That he be provided with security as he is a target of the state.
  2. That only his Legal Counsel should attend to the summons issued since all past experiences have been driven by ill will and dehumanizing intentions.
  3. That the officers who have handled his cases since the year 2015 should be investigated and subjected to disciplinary actions since they have acted unprofessionally.
  4. That an audit be carried out on all his illegal arrests, illegal detentions, and charges to wit as they further individual interests for extortion purposes from the alleged complainants.
  5. That the office of the Director of Public Prosecution to have an indepth scrutiny on the pending charges and his legal counsel to witness the veracity and merit of the same.

Yours faithfully,






CC.  Client

Director of Public Prosecutions,

Inspector General of Police,

Kenya Human Rights Commission,

Law Society of Kenya

H.E. President Uhuru Kenya

State House of Kenya

Ethics and Anti-Corruption Commission

Independent Police Oversight Authority,

The Chief Justice of Kenya, Hon. Justice David K. Maraga,

The Rt. Hon. Raila Amolo Odinga

The Ministry of Interior and Coordination of National Government

United States of America Ambassador to Kenya,

United Kingdom Ambassador to Kenya.

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