restricting access of all others. The Applicants further aver that knowledge of the shutdown and/or the inaccessibility of the internet by the abovementioned operators was attested to by three officials in government who referred variously but more particularly as a temporary restrictive measure to reduce the flow of communication. 9. The Applicants assert that as a result of the internet shutdown and/or restrictions they were prevented from carrying out their daily work which impacted their reputation and financial circumstances. The Applicants submit that the shutdown also cost the economy of Togo up to One Million Eight Hundred Thousand Dollars ($1,800,000) with empirical evidence from the United Nations Special Rapporteur on the Promotion and Protection of the Right to Freedom of Opinion and Expression estimating the shutdown between One Million Seven Hundred Dollars ($1,700,000) and Two Million Seven Hundred Dollars ($2,700,000). 10. The Applicants submit that the right to freedom of expression and the press is guaranteed in Article 25 and 26 of the Togolese Constitution respectively. 11. The Applicants are therefore claiming for the following reliefs and orders: a. A Declaration that, in shutting down the Internet, Togo violated its human rights obligations under international human rights law, in particular, the right to seek and receive information and to express and disseminate opinions under Article 9 (1) and 9 (2) of the African Charter, to freedom of expression under Article 19 (2) of the ICCPR and the rights of journalists under Article 66 (2) (c ) of the Revised ECOWAS Treaty; b. A Declaration that, in shutting down the Internet, Togo violated the eight Applicant’s human rights under international law, and in particular her rights as a journalist under Article 66 ( c) of the Revised ECOWAS Treaty; c. A Declaration that the development of a draft law on cyber criminality giving the Togolese Government power to shut down the Internet whenever it wishes represents an undue restriction with the right to freedom of expression and has a chilling effect on the Applicants and on press freedom more generally; 4|Page