Allegation of violation of Freedom of movement 128. The Applicants contend that the Ministerial Order, by preventing any demonstration in the area located between avenue El Hadji Malik Sy and Cap Manuel as well as in the immediate vicinity of the Renaissance Monument and in front of hospitals, restricts the freedom of movement of Senegalese citizens. 129. They assert that demonstrations can sometimes be likened to parades and marches on the public highway. That thus, the Ministerial Order violates the freedom of movement of the citizens since they no longer have the possibility of moving freely during demonstrations. 130. They argue that although the Respondent may restrict the freedom of movement of its citizens, this restriction must be sufficiently justified. That "reasons of security" are insufficient and remain insufficient as regards the restriction on the freedom of movement. 131. In conclusion, they submit that the Republic of Senegal, through this order of 20 July 2011, violated the human rights and fundamental freedoms of Senegalese. 132. In their response, the Respondent argue that the Applicants’ make speculations by their statement that "the Ministerial Order violates freedom of movement of its citizens since they are no longer able to move freely during demonstrations". 133. That this is a deliberate distortion of the Order which only prohibits political demonstrations but does not prevent cultural and religious events or the movement of citizens within the protected area. Again, no evidence of any violation was reported by the Applicants. 40

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