Karen Baaba Sam, a young single mother at the heart of a child custody battle with the father of her six-year-old daughter, has filed a motion at the General Jurisdiction High Court seeking an order to set aside what she says is an illegally obtained High Court order which permitted Nana Kwadwo Adjei to serve her his contempt application by substituted service.
The motion was filed on Wednesday, 9 July 2024, and it is expected to be moved by lawyers for Ms Baaba Sam on Thursday, 24 July 2025. Ms Baaba Sam essentially argues in her affidavit in support of the motion that the High Court, which permitted Nana Adjei to serve her committal for contempt of court processes, demonstrated its prejudice against her and also violated her constitutionally guaranteed right to due process.
Justification for the application
Ms Baaba Sam deposed in her affidavit that on 27 June 2025, an order for substituted service of the said contempt application was posted on the walls of her lawyers’ offices, purporting to serve her through her lawyers with Nana Adjei’s contempt application filed on 23 June 2025.
After this, Ms Baaba Sam indicates that she caused her lawyers to obtain copies of the application for substituted service and the proceedings of 25 June 2025, the day the Court made the order for substituted service.
Upon review of the application for substituted service, Ms Karen notes that aside from Nana Adjei’s mere allegations (which are false in any case and denied), Nana Adjei did not show in his application that the mandatory attempts to serve her (Karen) have been made and failed.
She further argued that Nana Adjei did not provide any such proof of failed service before applying for and being granted the order for service by substitution.
“There was also no evidence whatsoever furnished that any prior attempt had also been duly authorized and made to serve the contempt application on my lawyers to warrant the order of the Court authorizing processes to be posted on my lawyers’ office premises in purported service of the contempt application.
“What is even more egregious is that the record shows that on 23 June 2025 at 11:02 am, barely 8 minutes from the filing of the contempt application, the Applicant (Nana Adjei) filed an ex parte application to serve me (Karen Baaba Sam) with the contempt application through substituted service,” Ms Baaba Sam stated in her affidavit.
“By Nana Adjei’s showing in his motion for substituted service, not even a single attempt was made within the 8 minutes interval to serve me (Karen Baaba Sam) with the contempt application and yet he applied, ex parte, for orders to serve me by substituted service, which application the Court also presided over and granted.
“The ex-parte application for substituted service and the 25 June 2025 order of the Court offends the mandatory rules and the well-laid-out procedure for applying for and obtaining an order for substituted service of processes,” the affidavit deposed to by Karen Baaba Sam read.
Ms Sam posited that by the action of Nana Adjei and the Court, her right to due process has been violated. She argued that the 25 June 2025 order was obtained unlawfully and illegally, and the court wrongfully and illegally issued the same. It is on these grounds that she prays the court to set aside the order.
Petition to acting CJ
Ms Baaba Sam, in a related development, has petitioned the acting Chief Justice, Justice Paul Baffoe-Bonnie, to stop the latest attempt by Mr Kwadwo Adjei to abuse her and her six-year-old daughter through the use of the court system, aided by specific magistrates and justices of the superior courts.
The four-page petition dated Tuesday, 1 July 2025, and addressed to the acting Chief Justice of the Republic, is entitled, “Reminder on previous petitions and further petition against continued abuse by Mr Kwadwo Adjei and some judges.”
The petitioner copied her petition to the President of the Republic of Ghana, John Dramani Mahama, the Judicial Council of Ghana, the Attorney-General and Minister of Justice, Dr Dominic Ayine, the Registrar, High Court, General Jurisdiction 5, Accra, the Registrar, High Court, General Jurisdiction 1, Accra, Kwadwo Adjei, East Legon and to BLG Practice, Airport Residential Area, Accra.
Continuous abuse
Ms Karen Baaba Sam, states in her petition that despite assurance she was given of a swift response, an earlier petition she submitted to the acting Chief Just is yet to be responded to and to that end, she has been forced to send a reminder to the acting Chief Justice since her ex-partner has not stopped his abuses.
Ms Baaba Sam points out in her petition that “shockingly, Mr Kwadwo Adjei continues to be aided by certain judges by way of rulings that leave her with no choice than to challenge them, at appropriate courts, which has prolonged the ongoing litigations in what she says are undisputed grave domestic abuses perpetrated against her and my daughter by Nana Kwadwo Adjei.
Background
Karen Baaba Sam broke her silence on the years of physical, verbal, and emotional abuse she endured at the hands of her ex-partner, Nana Adjei, on 20 January 2025.
In a chilling account, Karen details the harrowing experiences that began in 2016 and culminated in a bitter custody battle over their daughter. Karen met Nana Adjei in 2016. What initially seemed like a loving and protective relationship soon took a dark turn.
By 2018, when she became pregnant with their daughter, Nana Adjei appeared excited, mainly since most of his children from previous relationships lived abroad with their mothers. However, cracks began to show when his second son, who had moved in with them, left after suffering physical abuse from his father.
Over the years, Karen says she suffered repeated physical assaults, often resulting in black eyes and a swollen face. Despite her brother filing a report at the East Legon Police Station, no action was taken.