96.In fact, the decision to detain Mr. Mado was taken by a Togo judicial authority. 97.It follows from the foregoing that the application must be declared inadmissible, because the facts are statute-barred or not in accordance with the case law of the Court of Justice. b. Pleas in Law: 98.The Respondent based its claim on Articles 11, 15, 19, 21, paragraphs 1 and 2 of the Togolese Constitution; 29 of the Law on the General Status of Military Personnel of the National Army, of December 17, 1963; 3, 4, 5, 6 and 7 (1) (d) of the African Charter on Human and Peoples' Rights; 5, 10, 23 (1) of the Universal Declaration of Human Rights of December 10, 1948, 7, 9 (1), 10 (1), 14 (3) (c) of the International Covenant on Civil and Political Rights of 16 December 1966; 4 of the Declaration on Fundamental Principles of Justice for Victims of Crime and Abuse of Powers; the Amnesty Act of December 22, 1994 and 6 (1) of the International Covenant on Social, Economic and Cultural Rights. c. Reliefs Sought: 99.The Respondent submitted that the Court should: With regards to the form: i. Grant the reliefs sought by the Togolese Republic; ii. On the other hand, declare the application dated 8 December 2016 inadmissible, based on the grounds relied on by the Togolese Republic; On the merit: 16

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