(ICCPR), and Article 1 of the International Covenant on Economic, Social and Cultural Rights (ICESCR), the Defendant submits that this court lacks the jurisdiction to entertain this suit on grounds of the plaintiffs lack of standing and identity, res judicata, lack of reasonable cause of action, and that the suit constitutes an abuse of process of the court. In purported response to the Defendants objections, the Plaintiffs submit that the Defendant is treaty bound by international law to acknowledge and recognize that the Niger Delta people are the de facto, natural and legitimate owners by birthright of the Niger Delta land with all its antecedent natural resources. That this inalienable and incontestable fundamental human right is absolutely sacrosanct and guaranteed by the International Law Treaties, Charters and Covenants. That their application is perfectly in accordance with the Court’s Protocol, Rules of Procedure, and the Revised Treaty. That the objections raised by the Defendant are just legal technicalities. The Plaintiffs further state that the Defendant is in serious breach of its Treaty obligations in the ceaseless, incessant and relentless violations of the Human rights of the Niger Delta people for decades. The plaintiffs failed to address the issues raised by the defendant in the preliminary objection. This court in its inherent jurisdiction to do justice at all times will however proceed to analyze the issues raised in line with the facts presented by the plaintiffs in the initiating application. This is more so as jurisdiction is determined from the facts presented in a Plaintiffs application and not from the defence. 13

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